COVID-19: Guidance for Graduate Programs, Students, and Clinical Fellows

From the Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC)

Updated March 29, 2022

COVID-19 has created an unprecedented situation that is affecting the ability for clinical services to be provided on site and in person with clients and patients as required by the 2020 Audiology and Speech-Language Pathology (SLP) Certification Standards. This situation extends to the ability for graduate student clinicians and Clinical Fellows to be physically present with clients/patients, and for clinical educators and Clinical Fellowship (CF) mentors to provide on-site and in-person supervision.

The CFCC understands these concerns and is continuously monitoring the situation and working with the CAA to identify options for CAA-accredited programs to help their graduate students to meet the minimum clinical practicum requirements in accordance with the standards. After careful consultation with the CAA, the CFCC is unable to reduce the number of clinical practicum hours since programs not only need to meet ASHA Certification standards but also those required by state or federal organizations, such as state licensing boards, the U.S. Department of Education, and the Council for Higher Education Accreditation (CHEA). The CFCC has jurisdiction over what is required for the purposes of ASHA certification; however, ASHA does not have jurisdiction over these external agencies/bodies.

Similarly, due to state licensing requirements that mirror ASHA certification standards, the minimum number of hours (1,260) and weeks (36) for Clinical Fellows will remain the same. The CFCC wants to provide clarification about several frequently asked questions and explain allowances that have been made for graduate programs/graduate student clinicians and Clinical Fellows.

The CFCC will continue to monitor the COVID-19 pandemic and the impact that it has on the ability to deliver on-site and in-person clinical services by graduate students and Clinical Fellows as well as direct clinical supervision and mentorship. Please note that this page will be reviewed frequently and any dates (noted with *) will be adjusted accordingly.

Accommodations for Audiology Graduate Students
Accommodations for SLP Graduate Students
Accommodations for SLP Clinical Fellows
CAA and CFCC Rationale for Maintaining Clinical Education Requirements
Clarification of Frequently Asked Questions

Audiology Graduate Students

Effective January 1, 2022

COVID-19 accommodations for audiology graduate students that were effective March 16, 2020 – December 31, 2021, have ended. Revised 2020 Audiology Certification Standards go into effect beginning January 1, 2022, and include the guideline that up to 40% of clinical practicum experience may include telepractice, provided regulations permit. This guideline is no longer considered a COVID-19 accommodation; it is now part of audiology standard practice guidelines.

SLP Graduate Students

The CFCC has determined that all students who begin their graduate program at a CAA-accredited or CAA-candidacy program on or before December 31, 2022, may engage in telepractice and telesupervision using the 2022 guidelines below for the entirety of their graduate academic and clinical practicum experience.

The CFCC will conduct a widespread peer review in the spring of 2022 for proposed revisions to the 2022 SLP standards. The revisions would allow telepractice and telesupervision for students beginning their graduate program on or after January 1, 2023.

Effective January 1, 2022 – June 30, 2022

Telepractice With Telesupervision

Graduate student clinicians who are enrolled in CAA-accredited and CAA-candidacy programs may engage in service delivery through telepractice as outlined below.

For purposes of ASHA certification for students graduating on or before June 30, 2022, one of the following must be provided on site and in person: (a) at least 50% of supervised clinical practicum between January – June 2022 or (b) a cumulative 125 hours of supervised clinical practicum across the graduate program.
Multiple students may participate in the same session. Each participating student will earn the full hour toward the completion of their clinical practicum. Program and clinic directors have the authority to determine how many students can appropriately take part in an online teletherapy session with one client, keeping quality patient care, safety, and optimal clinical education in mind.
Clinical educators may supervise more than one telepractice session concurrently, provided they (a) are available 100% of the time to each session and (b) provide a minimum of 25% direct supervision of the total contact time with each client/patient, similar to in-person supervision requirements.
Programs must carefully consider which clients/patients are appropriate for telepractice. As always, programs must adhere to all local/state/federal policies.
Guidance for programs engaging in on-site and in-person therapy visits: Up to two SLP graduate student clinicians who are actively engaged with one client/patient during a session may each count the full hour toward their minimum supervised clinical practicum hours.

Effective July 1, 2022 – December 31, 2022

Telepractice With Telesupervision

Graduate student clinicians who are enrolled in CAA-accredited and CAA-candidacy programs may engage in service delivery through telepractice as outlined below.

For purposes of ASHA certification for students graduating between January 1, 2022, and December 31, 2022, one of the following must be provided on site and in person: (a) at least 50% of supervised clinical practicum between January – December 2022 or (b) a cumulative 125 hours of supervised clinical practicum across the graduate program.
Multiple students may participate in the same session. Each participating student will earn the full hour toward the completion of their clinical practicum. Program and clinic directors have the authority to determine how many students can appropriately take part in an online teletherapy session with one client, keeping quality patient care, safety, and optimal clinical education in mind.
Clinical educators may supervise more than one telepractice session concurrently, provided they (a) are available 100% of the time to each session and (b) provide a minimum of 25% direct supervision of the total contact time with each client/patient, similar to in-person supervision requirements.
Programs must carefully consider which clients/patients are appropriate for telepractice. As always, programs must adhere to all local/state/federal policies.
Guidance for programs engaging in on-site and in-person therapy visits: Up to two SLP graduate student clinicians who are actively engaged with one client/patient during a session may each count the full hour toward their minimum supervised clinical practicum hours.

Speech-Language Pathology Clinical Fellows

The CFCC has determined that all Clinical Fellows who have initiated their CF experience on or before December 31, 2022, may engage in telepractice and telesupervision using the 2022 guidelines below for the entirety of their CF experience.

The CFCC will conduct a widespread peer review in the spring of 2022 for proposed revisions to the 2022 SLP standards. The revisions would allow telepractice and telesupervision for CF experiences that were initiated on or after January 1, 2023.

Effective January 1, 2022 – December 31, 2022

The CFCC has provided an allowance for Clinical Fellows to accumulate CF experience weeks/hours through telepractice.
The CFCC has continued the relaxed work week requirement allowing Clinical Fellows to count all hours involved in case management, even if they are not directly with clients/patients in activities such as creating home programs, virtual consultations with clients/patients or their families, allied health providers, teachers, or Child Study Team members. These activities must be permissible by your employer, CF mentor, and/or state licensing laws.
Clinical Fellows may continue to count time spent in “other activities, such as professional development, as long as they do not exceed 20% of their current work week.

Clinical Fellows in locations where telepractice and/or telesupervision is permitted

The CFCC prefers that the six (6) on-site and in-person direct observations per segment be completed on site and in person. However, given the unpredictable nature of the pandemic, telesupervision may be used for direct, on-site, and in-person observations of Clinical Fellows by CF mentors. As a reminder, a minimum of six (6) hours of direct observations are required per segment (one-third of the CF experience) and up to six (6) hours may be completed in one day.
Clinical Fellows may utilize telepractice provided an appropriately credentialed speech-language pathologist (see Standard VII) is available to assist in a similar manner to the supervision/assistance that is provided when services are delivered face-to-face. In addition, (1) the Clinical Fellow, the supervisor/CF mentor, and the client/patient/student must all be located in the United States, (2) the Clinical Fellow, the supervisor, and the CF mentor must be appropriately credentialed to provide services both in the state they reside and in the state(s) that they provide services. It is the responsibility of the CF mentor and the Clinical Fellow to contact the necessary state licensure agencies to determine what credentials are required.

As a reminder, for the purposes of ASHA certification, Clinical Fellows have 48 months from the date their CF experience began to complete their experience. Your end date may be extended past your original expected end date.

Please keep in mind that all local, state, and federal regulations, and employer policies, must be followed at all times. This is an unprecedented and fluid circumstance. We know that everyone is doing their best continue client/patient/student care and that Clinical Fellows need to continue to increase their skills/readiness for independent practice. The CFCC understands the uniqueness of the situation; however, we have the responsibility to ensure that CF experiences are completed in a reasonable and responsible way to ensure Clinical Fellows are prepared for independent practice without sacrificing client/patient/student care.

In all cases, CF mentors must meet the requirements as outlined in the 2020 certification standards, which includes (a) 2 hours of professional development in the area of supervision completed at least once after receiving the CCC-SLP, and (b) 9 months of full-time equivalent post-certification experience. Please remember that all clinical educators, graduate students, Clinical Fellows, and CF mentors must ensure that telepractice and telesupervision are completed in accordance with HIPAA, FERPA, and prevailing local, state, and/or federal regulations.

CAA and CFCC Rationale for Maintaining Clinical Education Requirements

The CAA and CFCC have the responsibility to assure stakeholders that graduates, Clinical Fellows, and certificate holders are clinically competent to practice. The accreditation and certification standards have been developed and refined throughout the years by undergoing a vigorous vetting process to protect the public, students, and payers. These standards ensure standardization in the amount and quality of education and training that students receive prior to beginning their Clinical Fellowship (CF) and that a Clinical Fellow receives before practicing as an independent clinician.
Reducing standards could pose potential risks to students and Clinical Fellows who (1) may not be competent and/or qualified to practice as those who were educated and trained before them or those who will be educated or trained in the future, (2) may not be able to meet state licensure or insurance requirements, and (3) most importantly, would put clients/patients/students at risk.
It has been requested that the CAA and CFCC lower the total amount of clinical practicum required for graduation/certification and roll those hours into an extended CF. This was also rejected because (1) it does not comply with the range of state credentialing requirements across the country and (2) it has the potential to endanger client/patients/students.
These accommodations are for purposes of ASHA certification only and do not supercede state licensing requirements. If you have questions about telepractice within your state please contact your state licensure boards or visit the ASHA website for state-by-state regulatory information on telepractice and temporary practice.
To assist all stakeholders, the CFCC has made a variety of accommodations that allow hours/experience to be counted for ASHA certification in ways which were previously not allowed. The CFCC’s timeframes for these accommodations are:
- SLP graduate students: March 16, 2020 – December 31, 2022
- SLP Clinical Fellows: March 16, 2020 – December 31, 2022
- During this time, academic programs are encouraged to find ways to accommodate various methods for students to meet the standards, such as distance education, tele options, program extensions, etc. Once programs and clinical placement sites are able to provide on-site and in-person services, they must comply with the 2020 certification standards.
The CFCC will conduct a peer review during the summer of 2022 to gather stakeholder input regarding changes to the 2020 SLP standards to replace the COVID-19 accommodations.

Clarification of Frequently Asked Questions

The CFCC will continue to support programs as they outline plans to ensure that their students are meeting certification standards. As such, the CFCC wants to clarify the following:

ASHA Audiology Certification Standards refer to CAA standards for the amount of clinical practicum required for audiology student clinicians.
- CAA standards require a minimum of 12 months of full-time equivalent experience that occurs throughout the duration of the graduate program.
  - “Short” and “long” experience that occur in years 1–3 may be applied for the purposes of ASHA certification.
  - Students cannot graduate with less than the equivalent of 12 months of full-time clinical experience.
  - If all hours are not obtained under the supervision of a CCC-A, applicants may complete this post-graduation in accordance with the standards.
- Audiology students may earn up to 10% of their clinical practicum experience thorough clinical simulation.
- Telepractice and telesupervision may be used to obtain the required supervised clinical practicum, as stated in Standard III of the 2020 Standards.
ASHA SLP Certification Standards require a minimum of 400 clinical practicum hours for SLP graduate student clinicians.
- The standards state that applicants for certification must demonstrate competence in the areas outlined in Standards IV and V, however the programs are given flexibility in how students demonstrate competence. The standards do not specify the minimum number of sites, adult vs pediatric hours, or hours of contact with each specific client/patient population required to demonstrate competence. Programmatic or state licensure requirements may be more specific.
- 25 hours are obtained through guided observation. The CFCC does not limit the number of observation hours earned through video recordings.
  - All SLP graduate students must be supervised by someone who holds a current CCC-SLP.
  - After January 1, 2021, the clinical educator providing the debriefing or "guided" portion of observations, and/or the clinical educators responsible for verifying the observation hours were guided, must meet the additional supervision requirements as outlined in Standard V.
  - The SLPs who are being observed by student clinicians, but who are not the clinicians responsible for overseeing the guided component of the observation experiences, do not need to meet the requirement associated with the 2020 SLP standards.
- 375 hours are obtained through supervised clinical practicum.
  - 325 of these hours must be earned while the student enrolled in a graduate program.
  - The graduate program may count up to 50 hours of supervised clinical practicum that were completed within the undergraduate program. Programs may count hours earned during an SLPA preparatory program as part of the permitted undergraduate hours if the activities were within the scope of practice of an SLP and were supervised in accordance with the standards. Experience outside of a preparatory program may not be used.
  - Up to 75 hours may be obtained through clinical simulation (CS) activities. The CFCC is not adjusting the maximum number of hours permitted through CS. Programs have the authority to determine how best to debrief students and determine what documentation is required. In order to count hours as clinical practicum, the student must have direct interaction with the client/patient. Watching videos and reporting on what is seen is a great learning activity and may be used as guided observation; however, since the student does not directly interact with the client/patient, it cannot be considered a "task trainer" or an interactive computer-based simulations, and it cannot be used as a simulated clinical practicum activity.
  - A minimum of 250 hours of supervised clinical practicum within the graduate program are required in instances where the graduate student earns 75 hours through CS, 50 hours during undergraduate clinical practicum, and 25 hours through guided observation. These remaining 250 hours must be obtained through direct clinical contact with clients/patient.
  - From January 1 – December 31, 2022,* telepractice and telesupervision may be used to obtain up to 50% of the required supervised clinical practicum. At least 50% of the clinical practicum must be obtained via on-site and in-person service delivery. The following activities may be included as part of the direct clinical practicum hours:
    - Evaluations and screenings
      - informal
      - formal
      - parent/caregiver history/interviews
      - explaining evaluation results to parents/caregivers/clients/patients
    - Treatment
      - must be synchronous
      - individual or group
    - Counseling with caregivers and family
      - "wrap-up sessions"
      - advising, training, and providing education
      - demonstrating skills to caregivers
      - demonstrating to families how to program AAC devices
    - Activities such as planning, paperwork, and asynchronous therapy cannot be counted. However, time spent in meetings with the patient/family present, when the student is actively reporting evaluation results, treatment plans, progress, etc., can be counted since that is considered advising, educating, and training caregivers and family.
Grading
- Neither ASHA certification nor accreditation standards set grading requirements. This includes pass/fail or satisfactory/unsatisfactory options.
- Grading is up to the discretion of the program and must be in accordance with university policies and procedures.
Praxis examination
- The certification standards for both professions require that a passing exam score be earned no earlier than 5 years prior to the submission of an application and no later than 2 years following receipt of the application.
- Passing this examination prior to graduation may be a programmatic requirement.