SLP Qualifications Clarified for Part B Outpatient Therapy Services

We are clarifying our policy related to the qualifications for speech-language pathologists (SLPs) when furnishing Part B outpatient therapy services. These Part B services include speech-language pathology services that (a) are furnished by SLPs in private practice (SLPPPs) who submit professional claims and (b) are furnished and billed by providers of outpatient therapy services as defined at 42CFR489.2.  Consistent with the CY 2015 Home Health final rule section titled Proposed Revisions to the Speech-Language Pathologist Personnel Qualifications (79 FR 66107), CMS defers to the state licensure requirements for SLPs in each state, allowing them to determine the SLPs that are most appropriate to provide speech-language pathology services to individuals/patients, including Medicare beneficiaries. CMS is clarifying that the state-licensed SLP may include provisional or temporary licensure as such individual completes required supervised experience and these SLPs may enroll as an SLP in Private Practice (SLPPP) and work for providers furnishing outpatient Part B speech-language pathology services, consistent with state requirements. This means that to the extent that an SLP complies with the applicable state process for licensure, certification, or registration (if the state has one) necessary to practice as an SLP, which may include provisional or temporary licensure as such individual completes required supervised experience, such individual complies with the applicable licensure requirements found at section 1861(ll)(a)(4)(A) of the Social Security Act, 42 CFR 410.62(a), 42 CFR 484.115(n), and Section 230.3 of Chapter 15 of the Medicare Benefit Policy Manual. This policy clarification applies only to Part B therapy services that SLPs furnish as an SLPPP and when the SLP furnishes services that are billed by a provider with the following bill types: 12x, 13x, 22x, 23x, 34x, 74x, 75x, and 85x. This clarification does not apply to the services SLPs furnish that are billed/paid under Medicare Part A. CMS has issued instructions to the MACs on this topic.