Clinical Fellows and Medicaid Reimbursement Many school systems bill Medicaid for eligible students who receive speech-language services. But can schools—and other settings—bill Medicaid if the provider is a clinical fellow? Bottom Line
Bottom Line  |   September 01, 2014
Clinical Fellows and Medicaid Reimbursement
Author Notes
  • Laurie Alban Havens, MA, CCC-SLP, is ASHA director of private health plans and Medicaid advocacy.
    Laurie Alban Havens, MA, CCC-SLP, is ASHA director of private health plans and Medicaid advocacy.×
Article Information
Speech, Voice & Prosodic Disorders / School-Based Settings / Practice Management / Bottom Line
Bottom Line   |   September 01, 2014
Clinical Fellows and Medicaid Reimbursement
The ASHA Leader, September 2014, Vol. 19, 34-35. doi:10.1044/leader.BML.19092014.34
The ASHA Leader, September 2014, Vol. 19, 34-35. doi:10.1044/leader.BML.19092014.34
Answers to questions about Medicaid billing more often than not begin with, “Well, it depends”—because each state develops its own rules for covered services, eligible providers and billing. Whether schools and others may bill Medicaid when clinical fellows provide speech-language service is, unfortunately, one of those questions.
Unlike Medicare, which for the most part allows CFs to bill in those states in which CFs are eligible for state licensure, Medicaid does not uniformly apply this guidance. The Medicare guidance, in describing a speech-language pathologist, specifically includes the wording “has completed the academic program and is acquiring supervised work experience to qualify for the certificate (of clinical competence)” to include CFs. State Medicaid programs that refer to this guidance generally allow CFs to bill for services—but many states don’t use this language.
As with most Medicaid billing questions, it is important to read the state’s guidance thoroughly and to check with the Medicaid office. Look specifically for information related to the following issues.
  • Can the clinical fellow get a full or interim license in the state? Most states do not award full licensure, but do award CFs interim licensure, which often allows for the same responsibilities. Some states, including New York, Hawaii, Tennessee and North Dakota, do not award any type of license to CFs, so their scope of practice is more limited.

  • Does the state Medicaid program require a license to treat a Medicaid patient? In New York, for example, a CF can’t get a license, but can provide service to Medicaid clients in school settings “under the direction of” a qualified provider who would sign off and bill for services. Nevada doesn’t license CFs, but they are considered to be qualified providers under the Medicare definition. In Tennessee, CFs register with the state board and work under the supervision of a licensed SLP, but because they are considered students, they may not bill Medicaid for services.

  • Are there billing limitations on interim licensure? In Alabama, Ohio and Nebraska, the CF can get an interim license, but services are billed by the fully licensed, supervising SLP. Ohio guidance, for example, states that, “A person holding a conditional license may perform services for which payment will be sought under the Medicare program or the Medicaid program but all requests for payment for such services shall be made by the person who supervises the person performing the services.” In contrast, a Wisconsin CF with an interim license is eligible to bill Wisconsin Medicaid.

  • Can the CF bill Medicaid in all settings? Some states allow CFs to bill for services provided in schools, but not in other practice settings, as in Louisiana and Georgia.

  • Although speech-language pathologists are recognized as practitioners who are able to order services, many payers require that the order comes from a physician, often depending on the practice setting. In schools, the order for service often comes through the Individualized Education Program team, but in a hospital or outpatient setting, the physician needs to prescribe the treatment. Guidance in many states, including Alabama, Michigan and Wyoming, particularly notes that speech therapy services must be ordered by a physician.

Although ASHA provides guidance for “under the direction of” supervision, many states have established their own criteria for how much and what type of supervision CFs require. Some states require more than the amount of supervision necessary for ASHA certification, and have additional requirements for the signature of the supervisor on all documentation, including billing forms.
These considerations are critical to determining who may provide and bill for Medicaid services in schools and make it difficult to develop a state-by-state chart. For more specific information, contact the appropriate Medicaid office or
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September 2014
Volume 19, Issue 9