By: Carmen Vitton, MS, CCC-SLP, Business Management Committee Member

Important Update as of July 29: The Centers for Medicare and Medicaid Services (CMS) have cleared clinical fellows (CFs) with a provisional license to bill Medicare Part B. According to the American Speech-Language-Hearing Association (ASHA), in direct correspondence, “CMS clarified that its updated interpretation aligns with state licensing requirements and allows individuals holding provisional or temporary licenses, such as CFs, to provide services to Medicare beneficiaries—provided they meet their respective state’s licensure requirements.”

Read more at https://www.asha.org/news/2025/cms-reverses-its-interpretation-of-a-qualified-slp-clinical-fellows-cleared-to-bill-medicare/

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.

See ASHA Advocacy News: Medicare Updates Definition of Speech-Language Pathologist in Its Benefit Policy Manual for more information.  

Together, we acted as a profession by signing a petition to seek a modification to the CMS language, and ASHA, along with other significant agencies, supported us by responding with the following request to CMS:
 

Deputy Administrator, Center for Medicare
Centers for Medicare and Medicaid Services
U.S. Department of Health and Human Services

Dear CMS,

The American Speech-Language-Hearing Association (ASHA), ADVION (formerly the National Association for the Support of Long Term Care), the National Association of Rehabilitation Agencies and Providers (NARA), American Medical Rehabilitation Providers Association (AMRPA), and the Alliance for Physical Therapy Quality and Innovation (APTQI) are urgently requesting a meeting with Centers for Medicare & Medicaid Services (CMS) staff regarding significant disruptions to speech-language pathology (SLP) services.

We request confirmation that the update to Chapter 15 of the Medicare Benefit Policy Manual, defining a qualified SLP from the 2015 Home Health rule, does not alter policy or long-standing practice of Medicare Part B enrollment for SLPs. Our associations are concerned that recently emailed communication from CMS to ASHA, is contrary to current policy which has created widespread confusion in the field. This has caused significant challenges for Medicare beneficiaries in accessing needed speech therapy. Additionally, this interpretation is disrupting currently licensed SLPs completing their clinical fellowship and the pipeline of future SLPs entering a variety of medical settings and across the continuum of care including long-term care, hospitals, private practices, and pediatrics causing detrimental cascading effects in access to care. Thank you in advance for your consideration of this issue. We request this meeting with you as soon as possible to mitigate the disruption to speech therapy services for Medicare beneficiaries and many others. Please contact Sarah Warren, ASHA’s Director for Health Care Policy for Medicare, at 301-296-5696 or swarren@asha.org to schedule the meeting or for additional questions.

Sincerely,

American Speech-Language-Hearing Association (ASHA)
ADVION (formerly the National Association for the Support of Long Term Care)
National Association of Rehabilitation Agencies and Providers (NARA)
Alliance for Physical Therapy Quality and Innovation (APTQI)
American Medical Rehabilitation Providers Association (AMRPA)
CC: Alec Aramanda, Principal Deputy Director, Center for Medicare