Communicologist, Volume 52 - Issue 4 | 07.31.25
Background Information for Provisional Licensees, Clinical Fellows, and Employers
The Centers for Medicare and Medicaid Services (CMS) have updated their definition of a qualified speech-language pathologist (SLP) in Chapter 15 of the Medicare Benefit Policy Manual (MBPM) for Medicare Part B (outpatient) billing. As clarified by CMS in direct communication with the American Speech-Language-Hearing Association (ASHA), the term licensed must be interpreted literally. It does not include provisional, temporary, or limited licenses unless explicitly stated. Therefore, provisional licensees, including clinical fellows (CFs), are not eligible to bill Medicare Part B, as they do not hold a full state license. This also applies to outpatient services delivered in inpatient settings (e.g., hospitals, skilled nursing facilities) and home health.
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