Pennsylvania, Alabama Issue Provisional Licenses to Clinical Fellows Pennsylvania and Alabama have begun issuing provisional licenses to speech-language pathology clinical fellows (CFs), solving a licensure/billing conundrum that continues to plague six other jurisdictions. Unlike most states, these six other jurisdictions have no provisional, limited or temporary license for CFs. Without licensure, the CFs can’t bill Medicare and other ... News in Brief
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News in Brief  |   December 01, 2017
Pennsylvania, Alabama Issue Provisional Licenses to Clinical Fellows
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Professional Issues & Training / News in Brief
News in Brief   |   December 01, 2017
Pennsylvania, Alabama Issue Provisional Licenses to Clinical Fellows
The ASHA Leader, December 2017, Vol. 22, 15. doi:10.1044/leader.NIB2.22122017.15
The ASHA Leader, December 2017, Vol. 22, 15. doi:10.1044/leader.NIB2.22122017.15
Pennsylvania and Alabama have begun issuing provisional licenses to speech-language pathology clinical fellows (CFs), solving a licensure/billing conundrum that continues to plague six other jurisdictions.
Unlike most states, these six other jurisdictions have no provisional, limited or temporary license for CFs. Without licensure, the CFs can’t bill Medicare and other insurers that require providers to be licensed (see “The Clinical Fellow Licensure Conundrum,” from the November 2016 ASHA Leader).
Pennsylvania’s new regulations went into effect in spring 2017, and Alabama’s in October. Two other jurisdictions have taken steps—but have not completed the process—to correct the situation.
  • In New York, Gov. Andrew Cuomo signed legislation in August 2017 that provides for a limited licensure for the clinical fellowship period. Proposed regulations were published in the New York State Register on Nov. 1, 2017. The public comment period ends Dec. 18, 2017. If there are no changes proposed, the regulations will be presented to the Board of Regents for approval in January 2018 and will be implemented prior to the effective date of the law, Feb. 17, 2018.

  • The District of Columbia passed regulations to register clinical fellows. As of October 2017, however, there was no mechanism to issue registrations, and it is not clear if insurers will consider registration an appropriate substitute for licensure.

In the six states with no provisional licensure, clinical fellows may be considered students for reimbursement purposes and, therefore, may be subject to 100-percent direct supervision regulations.

Four other states—Connecticut, Hawaii, Massachusetts and Tennessee—have no provisional CF licensure. In the six states with no provisional licensure, clinical fellows may be considered students for reimbursement purposes and, therefore, may be subject to 100-percent direct supervision regulations. CFs and their supervisors in these states should confirm payer requirements for reimbursement.
Information on each state’s interim licensure policies is available at www.asha.org/advocacy/state (click on the state, then on the licensing link, scroll to “interim practice”).
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December 2017
Volume 22, Issue 12