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Medicaid Eligibility for Audiologists and Speech-Language Pathologists

Do Audiologists or Speech-Language Pathologists need to be ASHA Certified to bill Medicaid in New York State?

The following information is being provided in response to inquiries the New York State Education Department Office of the Professions has received regarding what licensure and/or certification requirements Audiologists and Speech-Language Pathologists must meet in order to bill for speech, language and hearing services they provide to a patients with Medicaid in New York State. Currently, as will be explained below, there are differences in the licensure and/or certification requirements for Medicaid reimbursement purposes for Audiologists and Speech-Language Pathologists.

Audiologist

According to the New York State Department of Health (DOH), which administers the Medicaid program in this State, in order to participate in the Medicaid program, an Audiologist must be licensed and registered in New York State and certified by the American Speech-Language-Hearing Association (ASHA). DOH’s position is based on 42 CFR §440.110, which establishes the reimbursement requirements for health care providers who provide services for individuals with speech, hearing and language disorders.

Pursuant to 42 CFR §440.110(c)(3), a qualified audiologist means an individual with a master’s or doctoral degree in audiology that maintains documentation to demonstrate that he or she meets one or more of the following conditions:

  1. The State in which the individual furnishes audiology services meets or exceeds State licensure requirements in paragraphs (c)(3)(ii)(A) or (c)(3)(ii)(B) of this section, and the individual is licensed by the state as an audiologist to furnish audiology services.
  2. In the case of an individual who furnishes audiology services in a State that does not license audiologists, or an individual exempted from State licensure based on practice in a specific institution or setting, the individual must meet one of the following conditions:
    1. Have a Certificate of Clinical Competence in Audiology granted by the American Speech Language Hearing Association.
    2. Have successfully completed a minimum of 350 clock-hours of supervised clinical practicum (or in the process of accumulating that supervised clinical experience under the supervision of a qualified master or doctorate-level audiologist); performed at least 9 months of full-time audiology services under the supervision of a qualified master or doctoral-level audiologist after obtaining a master’s or doctoral degree in audiology or a related field; and successfully completed a national examination in audiology by the Secretary.

This federal regulation contains the minimum requirements for participation in the Medicaid program for Audiologists. Since New York State licensure requirements do not meet or exceed the requirements in 42 CFR §440.110(c)(3)(ii)(A) or (c)(3)(ii)(B), it has been determined that ASHA certification, as well as New York State licensure is needed for an Audiologist to participate in Medicaid in New York State. This is the requirement for Medicaid participation regardless of when the Audiologist obtained his or her degree or experience.

Speech-Language Pathologist

However, unlike Audiologists, Speech-Language Pathologists only need to be licensed in New York State and are not required to hold ASHA certification in order to participate in the Medicaid program.

Pursuant to 42 CFR §440.110(c)(2), a speech pathologist is an individual who meets one of the following conditions:

  1. Has a certificate of clinical competence from the American Speech and Hearing Association.
  2. Has completed the equivalent educational requirements and work experience necessary for the certificate.
  3. Has completed the academic program and is acquiring supervised work experience to qualify for the certificate.

This federal regulation contains the minimum requirements for participation in the Medicaid program for Speech-Language Pathologists. Since New York State licensure requirements are equivalent to the educational and work experience requirements for ASHA certification, it has been determined that ASHA certification is not required for Speech-Language Pathologists to participate in the Medicaid program.