Please note that the Pennsylvania Speech-Language Hearing Association (PSHA) is neither a governing body nor a credentialing body. As such, PSHA is able to offer factual responses, but not interpretation of law. Your employer, the Pennsylvania Department of Education (http://www.pde.state.pa.us), and the State Board of Examiners (Licensure Board)
(http://www.portal.state.pa.us) are other sources for relevant information.
Licensure FAQs
Are you able to provide speech pathology services with a Masters degree and no Pennsylvania license or CCC-SLP?
In order to work privately in PA you MUST have a license.
If you are completing an ASHA Clinical Fellowship Year, you can work for a private practice as your supervisor can bill temporarily under their license. If you are not working on your CF, you cannot work in a private practice without a license.
We are in the process of revising our licensure laws in Pennsylvania at this time to allow for a provisional license for those in their ASHA Clinical Fellowship Year.
Malpractice insurance is optional but you incur your own liability if you are sued. You only need liability insurance if you are billing a third party payer and they require it, such as an insurance company or a school.
How will the new licensure bill affect Clinical Fellows in Pennsylvania?
PSHA is actively advocating for passage of a new licensure law in our state legislature which will require universal license in Pennsylvania for all practicing SLPs and Audiologists. It will allow for a Provisional License period during the Clinical Fellowship Year. The Clinical Fellow will be eligible to bill for services under federal programs, such as Medicaid and Medicare. The Provisional License holder may also be eligible to bill other medical insurers for services provided.
I have completed the CFY and am waiting for the official Certificate of Clinical Competence from ASHA. How do I continue to practice as a Speech-Language Pathologist in Pennsylvania if I don't have the state license yet?
The State Board of Examiners in Speech-Language and Hearing provided the following information:
The Clinical Fellow may continue to practice while waiting for their CCC to be officially approved by ASHA as long as they continue to be supervised in the same way as they were during the CF, whether by their CF supervisor or by a new employer. However, the CF should apply for the ASHA CCC and then the PA license without delay.
The rules and regulations of the current state licensure law are available at the following link: Click here for the State Licensure Board Rules and Regulations for YSPE (Year of Supervised Clinical Experience - the same as the Clinical Fellowship Year).
The new licensure bill, currently introduced in the Senate, would allow for provisional licensure, which would eliminate this confusion.
Clinical Fellowship (CF) FAQs
What are the requirements for ASHA Clinical Fellowship Year supervision in Pennsylvania?
Every state has the right to specify how they want to have their Clinical Fellows supervised, so the requirements for CF supervision in Pennsylvania are slightly different from the ASHA requirements.
These requirements are stated in the rules and regulations of our current state licensure law. Click here for the State Licensure Board Rules and Regulations for YSPE (Year of Supervised Clinical Experience - the same as the Clinical Fellowship Year).
However, there is a waiver option that allows you to wait to apply for state license until you obtain the Certificate of Clinical Competence. If you choose this waiver option, you can bypass the information in the regulations and just follow ASHA regulations. After you have obtained the CCC, then you can apply for PA state license.
SLPA FAQs
What are recommendations from PSHA regarding the use of Speech Language Pathology Assistants (SLPAs)? Who is qualified to supervise the SLPA? Are there any continuing education requirements for the SLPA?
PSHA has compiled several responses to questions about SLPAs and Audiology Assistants located on our website under www.psha.org/member-center/slp-assist-info.htm. These responses and recommendations were produced in collaboration with the State Licensure Board and several PSHA members involved in hiring and supervising Assistants.
Where can I find more information regarding Speech-Language Pathology
Assistants and Audiology Assistants?
State Board of Examiners in Speech-Language and Hearing
P.O. Box 2649, Harrisburg, PA 17105-2649
Attention: Sandra Matter
Phone - (717) 783-1389
Fax - (717) 787-7769
ST-SPEECH@pa.gov
Documentation FAQs
What are the Pennsylvania State requirements concerning the length of time documentation (evaluations, therapy records, etc) must be archived for services already rendered?
As health care providers, we are bound to adhere to the following, found at these links:
http://www.hpi.georgetown.edu/privacy/stateguides/pa/pa.pdf
What You Need to Know About Your Medical Records Brochure.
http://www.pacode.com/secure/data/028/chapter563/chap563toc.html
"Under Pennsylvania law, your doctor must keep your medical record for at least 7 years after the last treatment date. Doctors must keep records of minors until 1 year after the minor reaches the age of majority or for 7 years, whichever is longer. Similarly, hospitals must keep medical records for at least 7 years after you are discharged from the hospital. Hospital records of minors must be kept until age of majority plus 7 years. In practice, many health care providers keep their medical records longer."
We suggest that you consult with the Medical Records department of your facility.
Members of the Executive Board who work in the public school sector agree with the 7 year span, as per guidelines for Medical Access billing. Consult with your school district for local mandates and further guidance.
School-Based SLPs FAQs
What is the legal limit for a school based SLP's caseload in the state of Pennsylvania?
According to Pa. Regulations for Chapter 14 (Special Education guidelines) an itinerant special educator's caseload has a maximum of 65. The school based SLP position is equivalent to the itinerant special educator. http://www.pacode.com/secure/data/022/chapter14/s14.105.html
(c) Caseload.
(1) The following words and terms, when used in this subsection, have the following meanings, unless the context clearly indicates otherwise:
(i) Full-time. Special education supports and services provided by special education personnel for 80% or more of the school day.
(ii) Itinerant. Special education supports and services provided by special education personnel for 20% or less of the school day.
(iii) Supplemental. Special education supports and services provided by special education personnel for more than 20% but less than 80% of the school day.
(2) Click Here for a chart represents the maximum number of students allowed on a teacher’s caseload.
Can the number of students on caseload be higher if the SLP is working together with an SLP-A? What is the limit for the caseload size/number of students that can be seen by an SLP-A?
No, the SLPA may not carry their own caseload. The SLPA is registered to a Pa. Licensed SLP, and must work under the supervision of that SLP, within that professional's caseload, which has a maximum capacity of 65, as per the Pa. Chapter 14 guidelines for IDEA.
PSHA has prepared 3 specific documents that are useful to the SLP, the SLPA and the employer of the SLPA. Follow this link to find them on the PSHA website:
http://www.psha.org/member-center/slp-assist-info.htm
The full regulations are posted on the State Board of Examiners website: http://www.portal.state.pa.us
State Board of Examiners in Speech-Language and Hearing
P.O. Box 2649, Harrisburg, PA 17105-2649
Attention: Sandra Matter
Phone - (717) 783-1389
Fax - (717) 787-7769
ST-SPEECH@pa.gov
How do I obtain the necessary credentials for working as a school-based speech-language pathologist in Pennsylvania?
We do have some information on our website under Professional Development – Credentialing.
You have to take a series of tests for Pennsylvania. This is best explained on the Pa. Department of Education website. There are some recent changes in the types of tests, but the National Speech Pathology exam will still be required (SLP Praxis II -the "ASHA Exam").
Click Here for the PA Teacher Certification requirements.
A chart on the home page explains many requirements, with a link to the Standard Teaching Application, required by all public school and charter school districts.
Our school district does not have a policy on pediatric feeding and swallowing issues. I recently noticed an unsafe feeding situation involving a student. What is my responsibility here?
SLPs are held to a Code of Ethics that requires us to refer to other professionals when the case presents something beyond our experience or training. PSHA suggests that a referral to a swallowing team at a local medical facility is the route to take here. The family should be involved in pursuing this evaluation. The school SLP should be an integral part of the process, providing specific observations of functional swallowing and any incidents of unsafe eating at school. Input from teachers and the school nurse may be prudent.
You should work with your school district to develop a protocol for this referral, which is important for liability and compliance to IDEA guidelines. Your local Intermediate Unit may have a Feeding and Swallowing Team in place that could assist you.
In the past there have been several SLP presentations at PSHA conventions regarding the development of a school protocol for feeding and swallowing. Here is a citation of an ASHA journal publication that may help you.
Establishing a Public School Dysphagia Program A Model for Administration and Service Provision -- Homer 39 (2) 177 -- Language, Speech, and Hearing Services in Schools
PSHA is receiving many questions about the provision of school-based speech-language services by other school personnel due to school districts’ decisions based on fiscal/budgetary constraints. In an effort to answer these questions, PSHA provides the following:
Although PDE requirements allow a person holding a Bachelor’s degree in speech/language and a PA teaching certificate to work as a school-based speech therapist, such an individual is not qualified nor licensed as a speech-language pathologist, cannot bill for Medical Assistance services, and does not constitute best practices for students.
ASHA-certified or licensed SLPs can bill for Medical Assistance (ACCESS) for speech-language services. There are specific guidelines set forth by the Commonwealth of Pennsylvania regarding Medical Assistance billing, including qualifications for billable professionals and for those “under the direction” of a billable professional. (See School-based ACCESS Program at http://www.leaderservices.com/services/pa/)
Situations such as these (i.e. under-qualified personnel providing speech/language services in the schools of the Commonwealth) underscore the importance of every speech-language pathologist in the Commonwealth of Pennsylvania operating under the same credentials. Currently, no license is required for employment in a school setting. Our new licensure act includes a provision for “universal licensure”. This is a term we have coined to refer to the mandatory licensing of all speech language pathologists in Pennsylvania, regardless of practice setting. You can find up-to-date information about our efforts to obtain universal licensure on the PSHA website homepage, and under the licensure/advocacy tab.
Early Intervention FAQs
Do PA SLPs need a prescription to provide services in any setting, particularly Early Intervention?
The answer is No, as SLPs we do not need a prescription to provide services in Early Intervention, or in any other service setting.
For voice disorders, we need to refer to a physician for medical evaluation to obtain a medical release from that physician, stating that therapy will not cause harm.
Under the Principle of Ethics II, the law makes it clear that the SLP is the professional who has the education and expertise to recommend therapy - the physician does not. The physician's role is simply to verify that there is no medical condition to preclude the therapy.
Click here for the exact information from the PA Code.
