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May 2, 2007

STATEMENT

SUZANNE M. HARRIS, MS CCC-SLP, PRESIDENT

MASSACHUSETTS SPEECH-LANGUAGE-HEARING ASSOCIATION

House Bill 2110, An Act Relative to Speech-Language Pathologists

Background

The professions of speech-language language pathology and audiology have been in existence since before World War II. These two autonomous professions share a common focus on minimizing the significant impact of communication disorders across the lifespan. The fields of speech-language pathology and audiology are broad and complex, and include areas of practice that are connected to life functions (swallowing disorders/dysphagia) and many areas that are integrally connected to quality of life.

Licensed speech-language pathologists are health care professionals who diagnose, treat and manage individuals with a variety of speech, language, swallowing, cognitive and literacy disorders. Speech-language pathologists work in hospitals, schools, short and long-term care facilities, private practice, Early Intervention, home care and public agencies. They work to maximize functional communication skills, such as improving articulation, fluency or vocal function; speech-language pathologists also address receptive and expressive language skill deficits and improve the ability to effectively communicate in a variety of contexts. Speech-language pathologists provide direct treatment, collaborative multidisciplinary intervention and consultative services. Examples of areas addressed by speech-language pathologists include working with preterm infants in the neonatal intensive care unit; assisting patients with dementia to maximize their memory and organization skills; helping students with a variety of language based learning disabilities master academic curriculum, and assisting a stroke survivor learn to speak or swallow again. (From the American Speech Language Hearing Association website)

Licensed audiologists are health care professionals who diagnose, treat and manage individuals with hearing loss and balance problems from birth through adulthood. Audiologists dispense and fit hearing aids as part of a comprehensive rehabilitative program. Audiologists also work collaboratively with physicians when hearing and balance issues require medical or surgical intervention or treatment. Audiologists work in private practice, hospitals and medical centers, clinics, universities, rehabilitation centers and nursing homes. They work closely with government agencies, physicians and hearing aid manufacturers. Examples of areas addressed by audiologists include conducting diagnostic hearing evaluations across the lifespan; working on cochlear implant teams; providing counseling and advocacy training to adults with hearing loss; providing client education and training in the use of amplification and a variety of assistive listening devices; conducting hearing conservation programs and participating in research. Audiologists provide an important entry point for services for infants diagnosed with hearing loss. They also work collaboratively with speech-language pathologists and others in aural habilitation and rehabilitation. (From the American Academy of Audiology)

In the 1960’s, it was determined by the American Speech-Language Hearing Association that a Master’s Degree would be the entry level educational requirement for both disciplines. When licensure was enacted in Massachusetts in 1983, the Board of Registration in Speech-Language Pathology and Audiology oversaw a period of time where those who had already been practicing with a Bachelor’s degree, and who met the requirements for licensure, could be granted a license on approval from the board.

At the end of the grandfathering period required by the initial licensure law, this window was closed. Subsequently, all professionals since 1983 who have obtained a license to practice in Massachusetts have had to meet the minimum requirement of a Master’s Degree and adhere to other standards regarding continuing education. This ensures consistency, patient protection and quality of care. At this time, the profession of audiology has moved to the Doctorate Degree as the entry level for practice, and licensure regulations have been updated to reflect this change.

In the past 25 years, the depth and breadth of both fields have changed significantly. This is reflected in modifications and expansions of our Scopes of Practice, broadening of our requirements for continuing education, and an increased emphasis on evidence based practice. In addition, our codes of ethics (from the American Speech-Language Hearing Association and the American Academy of Audiology) provide structure and guidance in how to provide the highest level of clinical service while protecting consumers.

Requirements to Practice for Speech Pathology

In order to practice as a speech-language pathologist in Massachusetts, one must complete the following:

Obtain or meet the requirements for the Certificate of Clinical Competence (CCC), which includes the following components:

Minimum of a Master’s Degree in Speech-Language Pathology (including several hundred hours of supervised clinical practice)
Passing score on the National Examination in Speech-Language Pathology
Completion of a residency, known as the Clinical Fellowship Year that provides for close supervision during the first 9 months of full-time employment

Obtain a license from the Board of Registration, which includes the following components:

Completion of the Clinical Fellowship year/supervised clinical practice
Passage of the National Exam
For school based practitioners, they must also have a license from the Department of Education

It should also be noted that both national certification and state licensure carry annual requirements for documented completion of continuing education.

Requirements to Practice for Audiology

In order to practice as an audiologist in Massachusetts, one must complete the following:

Obtain or meet the requirements for the CCC, including the following:

Minimum of a Master’s Degree until 2011, after which time a Doctoral degree will be required for entry into the profession;
Passing score on the National Exam in Audiology
Completion of a residency, to consist of 12 months full time supervised clinical practice
Obtain a license from the Board of Registration, as noted above
Audiologists can also elect to complete requirements for Board Certification from the American Board of Audiology; this certification currently requires the Doctoral degree as entry level and has stricter qualifications

Currently, our certification and licensure are global in nature; the license allows for practice from “cradle to grave.” Certification and licensure are not setting specific, meaning that one can practice in multiple settings and in various clinical areas simultaneously or over the span of time. However, our code of ethics requires that we only engage in those areas of the discipline where we have appropriate training and expertise . We now also have the option of specialty certification in some areas of clinical practice, where advanced knowledge and skills are needed.

In summary, speech-language pathologists and audiologists are highly educated and rigorously trained professionals, who must meet multiple sets of requirements in order to practice. As outlined above, our training goes well beyond the advanced professional degree, and includes robust clinical training and requirements for ongoing education. It is critical that we maintain the highest standards possible for anyone who would be providing services to those affected by communication and swallowing disorders.

House Bill 2110

House Bill 2110 would provide an outlet for those who have been illegally engaged in practice as a speech pathologist or audiologist since 1983 or before, to potentially obtain a license. It waives the requirements that all other ethical professionals in the commonwealth must adhere to and puts patient care at risk.

Why we are opposed to this bill

It represents an attack on the integrity of our professions and minimizes the complexity of the services we provide;
It demeans the value of professional licensure in general, as it is doubtful that this regressive tactic would be acceptable to other professions within the Commonwealth;
It bypasses the specific authority of the Board of Registration, whose sole purpose is to maintain consistency and high standards in protecting the consumers of the state;
It provides for no oversight regarding who can apply under the bill, nor does it define “actively engaged in practice”;
It rewards the behavior of those who have exhibited blatant disregard for the law and the standards governing their profession;
It does not respect the changes that have occurred in the professions, including the significant expansion in scope of practice and preferred practice patterns;
It does not provide any limits on the kind of practice someone who might be granted a license in this context could provide;
It violates language in the No Child Left Behind Act that requires services be implemented by the highest qualified provider;
It is contrary to the requirements of CMS, which dictate that providers who bill Medicare or Medicaid meet ASHA requirements, including possession of at least a Master’s Degree;
It sets a legal precedent for further challenges to our licensure in the future;
It places an undue burden on legislators to determine who should qualify to practice as a speech-language pathologists or audiologist, rather than Board of Registration members who belong to the profession;
Most importantly, it places consumers at risk. They must rely on the validity of the credentials that are offered to ensure that they are being evaluated and treated by a competent professional who has met all requirements. Being seen by an unlicensed or unqualified professional can lead to lengthier times in treatment, greater financial burden and in some cases, harm or loss of function.

Conclusion

House Bill 2110 unwisely and unnecessarily places consumers at risk, offers an applicant with substandard credentials an opportunity to gain credibility they have not earned, and violates regulations and statutes relating to reimbursement and special education. For these reasons the Massachusetts Speech-Language-Hearing Association urges you to oppose passage of this bill and respectfully requests the Joint Committee on Public Health recommend that it ought not to pass.

Suzanne M. Harris, MS CCC-SLP

Speech-language pathologist

MSHA President