The terms clinical supervisor, clinical educator, and clinical instructor may all be used to refer to professionals who provide supervision as part of the training and education of student clinicians.
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According to ASHA's Standards for the Certificate of Clinical Competence in Speech-Language Pathology (CCC-SLP), student clinicians must be supervised by an individual who:
In addition to the CFCC standards, supervisors of graduate students need to consider requirements and regulations, including
Based on the 2020 Speech-Language Pathology Certification Standards, the amount of direct supervision provided must be commensurate with the student's knowledge, skills, and experience; must not be less than 25% of the student's total contact with each client/patient; and must take place periodically throughout the practicum. Supervision must be sufficient to ensure the welfare of the individual receiving services. As a supervisor, you are responsible for any actions taken by the student while under your supervision. You should ensure that the amount of supervision provided is appropriate to the needs of the client/patient and for the graduate student's experience and skill.
Clinical educators who are members of ASHA are expected to abide by the Code of Ethics (ASHA, 2016; hereafter, “the Code”) and have the unique opportunity to reinforce and model the importance of the Code of Ethics to their student clinicians. ASHA's documents, Ethical Issues Related to Clinical Services Provided by Audiology and Speech-Language Pathology Students (ASHA, 2017) and Issues in Ethics: Supervision of Student Clinicians (ASHA, 2017), provide additional guidance for addressing challenges in clinical supervision.
The Code provides guidance regarding the ethical issues that may arise when students are providing professional service. Although the Board does not have jurisdiction over students, the Code does apply to their supervisors, clinic directors, and mentors. Specifically, Principle of Ethics I, Rule G recognizes the professional acceptability of appropriately supervised clinical practice by students by stating, “Individuals who hold the Certificate of Clinical Competence may delegate to students tasks related to provision of clinical services that require the unique skills, knowledge, and judgment that are within the scope of practice of their profession only if those students are adequately prepared and are appropriately supervised. The responsibility for the welfare of those being served remains with the certified individual."
It is not uncommon for clinicians serving as external practicum site clinical educators to be offered incentives or compensation for the additional work involved in being a clinical educator. ASHA does not have a policy on payment of externship clinical educators. Some academic institutions may offer compensation in the form of a stipend or in-kind services (e.g., continuing education opportunities) or, for example, a “thank you” lunch at the end of the semester.
In some cases, the employer (practicum site) might offer compensation or incentives to the employee for working with student clinicians. For example, when practical, the employee may be given a temporarily reduced caseload while working with a student clinician.
If the SLP receives payment from the university for serving as an externship clinical educator, then they will need to disclose this to the employer. As the direct beneficiary of this payment, they will also need to declare the income when filing their personal income taxes.
Medicare allows limited billable interactions between students and beneficiaries. Medicare Part A has no specific student supervision restrictions for Part A patients in hospitals and, effective October 1, 2011, more restrictive regulations for skilled nursing facilities (SNFs) have been removed to promote greater conformity with other inpatient settings Medicare regulations now state "each SNF would determine for itself the appropriate manner of supervision of therapy students consistent with applicable state and local laws and practice standards."
Medicare Part B
The Medicare Benefit Policy Manual indicates that a therapist may bill and be paid for the provision of services when qualified the "qualified practitioner is present and in the room for the entire session." The student may participate "in the delivery of services when the qualified practitioner is directing the service, making skilled judgment, and is responsible for the assessment and treatment." The Medicare Benefit Policy manual further states that billing and payment are appropriate when:
These rules apply to both individual and group therapy. One-to-one patient contact is not necessary for group therapy even though constant attendance is required. See Supervision of Assistants, Graduate Students, and Clinical Fellows: Billing and Payment Compliance for more information.
Telesupervision occurs when a qualified professional observes, from a distance, the delivery of services—and provides feedback or assistance as needed. With telesupervision, the speech-language pathologist (SLP) can view and communicate with the patient, student, and/or audiology assistant or speech-language pathology assistant in real time via telecommunication software (e.g., virtual platforms), webcam, telephone, and similar devices. This enables the professional to give immediate feedback. Telesupervision does not include reviewing a recorded session later. See ASHA's Practice Portal on Telepractice and Teleassessment webpage for information on licensure and teacher certification, international considerations, and reimbursement and other topics. The page also includes a comprehensive list of resources—including checklists and videos to inform practice.
Laws and Regulations for Telesupervision
The use of telesupervision as an alternative to in-person supervision may depend on the policies, regulations, and/or laws of various stakeholders such as universities, clinical settings, the CFCC, state licensure boards, and state and federal laws and regulations.
Increasingly, state licensure laws may or may not include guidance or regulation regarding telesupervision. States may vary in terms of whether they specifically address the issue of supervising students from a distance. See practice policy for your state. In some cases, the two parties may not reside in the same state or country (e.g., provider and client live in two different states). Serving Students in Other States and Countries Through Telepractice provides information and guidance when this occurs.
Because these regulations are still changing, supervisors should refer directly to the following resources to find the most recent information about whether telesupervision is allowed and under what circumstances.
See ASHA's 2020 Certification Standards for Speech-Language Pathology and ASHA's State by State resource for state regulations on telepractice and telesupervision and state contact information.
Ethical Responsibilities for Telesupervision
According to ASHA's Clinical Education and Supervision Practice Portal, the supervisor has an ethical responsibility to determine if telesupervision is appropriate in view of the type of setting, client population, and level of competence of the individual delivering the service.
When implementing telesupervision practice and policies, consider the security of the telesupervision transmission, keeping in mind relevant state and federal laws such as the Health Insurance Portability and Accountability Act (HIPAA) and the Family Educational Rights and Privacy Act (FERPA). Policies about safety, liability, and whether a certified and/or licensed professional needs to be on site are important considerations. Considerations for Group Speech-Language Pathology Treatment in Telepractice addresses service delivery, documentation, privacy, and confidentiality of telepractice across settings.
Knowledge and Skills for Telesupervision
Delivering supervision services from a distance requires knowledge and skills for managing technology, complying with licensure and security requirements, providing feedback, and so forth. Training may be necessary to ensure that the quality and effectiveness of the telesupervision is equivalent to in-person supervision.