Clarification on SLP Qualifications: No Policy Changes in Recent CMS Manual Updates

• By: Maureen Carland
• On: 06/16/2025 14:33:56
• In: Quality/Regulatory

In May, the Centers for Medicare & Medicaid Services (CMS) issued MLN Matters article MM13922, which includes technical updates to Chapter 15, Section 230.3 of the Medicare Benefit Policy Manual. This section outlines qualifications for Speech-Language Pathologists (SLPs) who provide outpatient services. CMS clearly states that these updates do not represent a change in policy.
The requirements for SLPs have been in effect since January 1, 2015, and are codified in Section 1861(II)(4)(A) of the Social Security Act. The recent update simply aligns the manual's language with the longstanding statutory policy.
To be considered a qualified SLP, an individual must hold a master's or doctoral degree in speech-language pathology and either:

• Be licensed by the state in which services are provided; or
• In states without licensure, meet all of the following:
  • Completion (or ongoing accumulation) of 350 supervised clinical practicum hours;
  • At least 9 months of supervised full-time SLP services post-graduation; and
  • Successful completion of a national examination in speech-language pathology approved by the Secretary of HHS.

AHCA encourages providers to continue current staffing and billing practices for SLP services. They remain committed to advocating for ongoing clarity from CMS on SLP qualifications and will share any further updates as they become available.
 
Staff contact: mcarland@mehca.org