MEDICARE UPDATES DEFINITION OF SPEECH-LANGUAGE PATHOLOGIST

IN ITS BENEFIT POLICY MANUAL 

 From ASHA.org: Please go to this link for updated information from ASHA

Since the policy update removed the reference to “meet[ing] the educational requirements for certification and… in the process of accumulating, the supervision experience required for certification,” it was important to clarify the status of all provisional licensees, including CFs, to ensure these individuals remain compliant with Medicare regulations. In follow-up communications to ASHA, CMS clarified that provisional licensure does not meet the definition of “licensed” for the purposes of Medicare provider enrollment. This means that an individual with a provisional license is not considered a qualified Medicare provider and:

• cannot enroll as a Medicare provider
• cannot bill Medicare for the services they provide

Each employer should assess their risk and determine how to proceed accordingly, but conservatively, employers should apply Medicare student supervision standards to provisional licensees at this time. Key points to remember are:

• Under Part B (outpatient services), individuals with a provisional license should not provide services billed to Medicare without the same supervision as required for a student.
• Under Part A (hospitals, SNFs), individuals with a provisional license may provide services billable under the facility’s NPI only if a licensed SLP is on-site and available to assist if needed.

For specific questions, please email reimbursement@asha.org.