This resource provides some guidance for speech-language pathologists (SLPs) conducting assessments of speech, language, and cognitive communication via telepractice. (Assessment of swallowing or feeding is not included.) Although many of these considerations may apply at any time, some are unique to the COVID-19 pandemic.
There are many considerations to ensure that telepractice assessments are equivalent to those completed in-person. ASHA’s Practice Portal on telepractice identifies that audiologists and SLPs should
ASHA recognizes that the COVID-19 pandemic is unprecedented and requires unique—and sometimes, less than ideal—measures to assess a person’s communication needs. It’s critical for SLPs to adhere to the ASHA Code of Ethics and federal, state, and district guidelines regarding telepractice to ensure, to the fullest extent possible, that they are providing high quality services. This includes consideration of the use of interpreters and translators during services to English learners, as needed, to provide effective clinical services.
SLPs in all practice settings should also verify state licensure requirements for telepractice and telesupervision to be aware of existing regulations and any recent telepractice policy changes [PDF] that may impact delivery of audiology and speech-language pathology services.
The telepractice Evidence Map provides an overview of evidence on the feasibility of assessments via telepractice for various clinical populations. The systematic reviews and clinical practice guidelines cover audiology and speech-language pathology topics.
Some ASHA members have expressed concerns about needing to perform evaluations and assessment in nontraditional ways without their usual fidelity. Clinicians may want to consider and discuss the following with employers and payers:
In addition to the client’s clinical presentation, SLPs should consider
Some publishers of standardized assessments have developed guidance about administration of tests via telepractice or validated assessments for administration via telepractice. Other researchers have compared the validity of in-person and remote assessment protocols (Sutherland et al., 2016; Taylor, et al., 2014).
When using a test that has been validated for telepractice administration, document the interpreted scores as you would from in-person administration. Check with the test publisher if the assessment tasks show evidence of in-person vs. remote administration equivalency for administration via telepractice. Verify that your client falls within the norming sample of that instrument.
If the test you’re using does not fall under this category, the reliability and validity of the test is in question for remote administration. Be sure to document this, including a discussion of modifications, such as collaboration with an interpreter/translator or modification of prompts. Use of a test in a nonstandardized manner may also impact billing of standardized assessment codes (see the Coding and Payment Policy section below).
Individual test publishers (e.g., Pearson) may offer free access to their digital products, including test stimuli, in response to clinicians’ needs during COVID-19.
Publisher permission is required to copy, scan, or modify test materials in any way. Permission is given on a case by case basis. Many publishers, including ProEd [PDF] and Pearson [PDF], have issued statements waiving certain requirements during this pandemic, but make sure to check with the publisher before modifying tests. Recording of test administration (such as recording a telepractice evaluation session) continues to be prohibited by most publishers.
SLPs must state modifications made to test materials, administration procedures, or other aspects of an assessment in the interpretation and documentation of the assessment. This may include skills observed by the clinician versus skills reported by others, use of an interpreter/translator, any behaviors that may have impacted performance and interpretation of results, and recommendations for reassessment.
Coding and payment considerations for telepractice services are generally the same as in-person services. SLPs providing telepractice should report Current Procedural Terminology (CPT) codes just as they would if the services were provided face-to-face and follow the same guidelines for appropriate billing. For example, time spent administering nonstandardized tools for telepractice may not be reported using CPT codes requiring standardized tests. ASHA provides additional guidance on coding and payment for telepractice as well as extensive resources on CPT coding for speech-language pathology services. Always verify coverage and payment guidelines with payers before initiating telepractice services.
The decision to accept assessment via telepractice when determining eligibility is subject to facility/employer/state agency requirements, payer regulations/requirements, as well as independent SLP clinical judgment on a case-by-case basis. Considerations of the language used in the home are reflected in the treatment plan. See IDEA Issue Brief: Part C Cultural and Linguistic Diversity.
During this time, some early intervention (EI) programs have reported using assessment tools that include parent interviews. Some ASHA members have shared ideas for EI telepractice resources on the EI ASHA Community.
The U.S. Department of Education (ED) provides the following guidance about IDEA timelines in its “Supplemental Fact Sheet: Addressing the Risk of COVID-19 in Preschool, Elementary and Secondary Schools While Serving Children with Disabilities” [PDF]:
“As a general principle, during this unprecedented national emergency, public agencies are encouraged to work with parents to reach mutually agreeable extensions of time, as appropriate.”
This statement supports flexibility in achieving timeline requirements as well as opportunities to prioritize evaluations. SLPs must follow state requirements, which include making determinations to inform school district decisions. To date, ED has not issued specific guidance on using telepractice for evaluations.
Similarly, when providing intervention via telepractice, it’s important to consider federal privacy laws like the Health Insurance Portability and Accountability Act (HIPAA) and Family Educational Rights and Privacy Act (FERPA). During this pandemic, the U.S. Department of Health and Human Services (HHS) relaxed requirements to comply with HIPAA for some videoconferencing platforms; however, relaxation of HIPAA does not impact compliance with FERPA. FERPA usually takes precedence over HIPAA when educational agencies or institutions receive direct funding from ED.
One consideration for your school district is whether a statement about allowing the disclosure of personally identifiable information to other parents and household residents during telepractice or virtual instruction should be included in a FERPA consent-to-disclose form. ED provides a sample FERPA consent to disclose form at the bottom of their “FERPA and Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions (FAQs)” [PDF].
Telepractice in health care settings has not been extensively used in the United States due to the lack of reimbursement from both public and private third-party payers. With relaxed regulations and increased reimbursement options during the COVID-19 pandemic, SLPs in health care settings may have remote service delivery options for the first time. Before starting telepractice in health care settings, ASHA recommends the following considerations:
American Speech-Language-Hearing Association. (2016). Code of ethics [Ethics]. Available from www.asha.org/policy/.
American Speech-Language-Hearing Association. (n.d.). COVID-19: Tracking of state laws and regulations for telepractice and temporary practice. Available from www.asha.org/siteassets/uploadedfiles/State-Telepractice-Policy-COVID-Tracking.pdf [PDF].
American Speech-Language-Hearing Association. (n.d.). Telepractice. (Practice Portal). Available from www.asha.org/Practice-Portal/Professional-Issues/Telepractice/.
American Speech-Language-Hearing Association. (n.d.). Telepractice resources during COVID-19. Available from www.asha.org/About/Telepractice-Resources-During-COVID-19/.
Dantuma, T. (2014). The similarities and differences of telepractice and in-person pediatric speech assessment results. Northcentral University.
Mullins, S., Lane, K., & Lowman, J. (2017, November). How a pink Post-It may improve diagnostic testing in a telepractice environment. Poster session presented at the Annual Convention of the American Speech-Language-Hearing Association, Los Angeles, CA.
Sutherland, R., Hodge, A., Trembath, D., Drevensek, S., & Roberts, J. (2016, September). Overcoming barriers to using telehealth for standardized language assessments. Perspectives of the ASHA Special Interest Groups, 1(SIG 18), 41–50.
Taylor, O.D, Armfield, N.R, Dodrill, P., & Smith, A.C. (2014). A review of the efficacy and effectiveness of using telehealth for paediatric speech and language assessment. Journal of Telemedicine and Telecare, 20(7), 405–412. doi:10.1177/1357633X14552388
Waite, M. C., Cahill, L. M., Theodoras, D. G., Busuttin, S., & Russell, T. G. (2006). A pilot study of online assessment of childhood speech disorders. Journal of Telemedicine and Telecare, 12(3_suppl), 92–94. doi: 10.1258/135763303779380048
Waite, M., Theodoros, D., Russell, T., & Cahill, L. (2010). Internet-based telehealth assessment of language using the CELF-4. Language, Speech, and Hearing Services in Schools, 41, 445–448.