New Medicaid Regulation Affects Audiologists: In CMS Rule, Payment Ties State Licensure to CCC-A The Centers for Medicare and Medicaid Services (CMS) has released its final rule addressing Medicaid provider qualifications for audiologists in the May 28 issue of Federal Register. The regulation takes effect on June 28. The final rule recognizes audiology as a separate profession, strengthens state licensure requirements to reflect the ... Policy Analysis
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Policy Analysis  |   June 01, 2004
New Medicaid Regulation Affects Audiologists: In CMS Rule, Payment Ties State Licensure to CCC-A
Author Notes
  • Ingrida Lusis, director of federal and political affairs, can be reached at ilusis@asha.org.
    Ingrida Lusis, director of federal and political affairs, can be reached at ilusis@asha.org.×
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Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   June 01, 2004
New Medicaid Regulation Affects Audiologists: In CMS Rule, Payment Ties State Licensure to CCC-A
The ASHA Leader, June 2004, Vol. 9, 1-12. doi:10.1044/leader.PA.09122004.1
The ASHA Leader, June 2004, Vol. 9, 1-12. doi:10.1044/leader.PA.09122004.1
The Centers for Medicare and Medicaid Services (CMS) has released its final rule addressing Medicaid provider qualifications for audiologists in the May 28 issue of Federal Register. The regulation takes effect on June 28.
The final rule recognizes audiology as a separate profession, strengthens state licensure requirements to reflect the wide use of the Certificate of Clinical Competence in Audiology (CCC-A), replaces the “or equivalent” clause with the Medicare standards, and requires supervision by audiologists for medicaid audiology services performed by less-qualified providers. A chart summarizing these changes can be found on page 12.
Payment Requirements
To qualify for Medicaid payment, the new regulations will require that state audiologist licensure standards meet or exceed the CCC-A or the Medicare statutory standards (the 1993 CCC-A requirements). CMS clarified its policy further by saying, “We do not believe recognition of State licensure as the sole national standard for defining qualified audiologists is in the best interests of the Medicaid population.”
The new regulation also eliminates the “or equivalent educational requirements and work experience” clause, replacing it with the Medicare standard.
“The new regulation addresses complaints we have received from many audiologists that less- qualified providers were directly billing Medicaid for audiology services, since the term 'equivalent' was widely interpreted by some states,” said ASHA President Larry Higdon, an audiologist.
Audiologists who reside in some states-those that lack licensure, have less stringent licensure standards, or exempt audiologists from licensure by institution or setting (such as schools)-also will be required to document that they have the CCC-A or meet the Medicare standard.
In comments made in the final rule, CMS states, “Our revised standards continue recognition of ASHA certification, not only because it is a recognized industry quality standard, but more importantly because it ensures continuity and reciprocity…” and would “limit the administrative burden to states.” CMS also noted that American Board of Audiology certification would not be cited as a qualifying standard.
“CMS has upheld the rigorous standards developed by audiologists for audiologists by using the CCC-A as the basis for evaluating state licensing standards,” Higdon said. “This is a victory for the thousands of audiologists who worked to earn the CCC-A, and for the patients that benefit from their high level of professional preparation and expertise.”
Guidance for “Under the Direction of...”
CMS agreed with ASHA's comments to the proposed rule to further strengthen its guidance on what constitutes providing audiology services “under the direction of” a qualified audiologist. The final rule stipulates that employment terms should provide for supervisory ratios that are reasonable and ethical and that reflect professional practice act requirements. In addition, CMS expects that individuals working under the direction of a qualified audiologist will be provided information to permit direct contact with supervising audiologists.
“The new supervision guidance is a great step forward to ensure that Medicaid audiology service by less-qualified providers are appropriately supervised and directed by audiologists, said Higdon.
Impact on SLP Qualifications
The Medicaid provider qualifications for speech-language pathology are not affected by this ruling. However, CMS has indicated that they are likely to apply the supervision guidance portion of the rulemaking to Medicaid speech-language pathology services.
“We are pleased that CMS staff and Secretary Thompson agreed with our policy positions on behalf of audiologists and Medicaid beneficiaries,” said Higdon.
The final rule is available on the ASHA Web site.
Summary of Medicaid Qualifications for Audiologists
  • Old Medicaid Regulation, ASHA Policy Position, New CMS Regulation

  • 42 CFR 440.110 (c)(2):, ASHA urged CMS to:, Federal Register Notice:

  • Combined speech-language pathologist and audiologist standard, Recognize audiology as an autonomous and distinct profession, New separate section for audiologist qualifications

  • CCC-A, Standards in all state licensing laws and regulations for Medicaid population, equal to or greater than CCC-A, State license for audiologists, providing that the state licensure requirements meet or exceed the CCC-A or the Medicare statutory definition (1993 CCC-A standards)

  • Or equivalent educational requirements and work experience, Tighten loophole in equivalency clause that has allowed lesser-qualified providers to bill directly for Medicaid audiology services, In states that lack licensure, have lesser licensure standards , or exempt audiologists practicing in specific settings (such as schools), audiologists need the CCC-A or Medicare statutory definition (1993 CCC-A standards)

  • Supervision guidance absent for lesser-qualified providers “under the direction of” audiologist, Strengthen “under the direction of” guidance to ensure that only audiologists provide or supervise audiology services for Medicaid beneficiaries, Audiologist responsible for providing or supervising each beneficiary's care. Audiologist to initially evaluate patient, prescribe treatment, and review the need for continued services. Requires contractual or other formal agreement that outlines supervision.

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June 2004
Volume 9, Issue 12