CMS Reverses Its Interpretation of a Qualified SLP: Clinical Fellows Cleared to Bill Medicare

September 25, 2025

Update: September 25, 2025

CMS has issued the long-awaited guidance reinforcing that provisional licensees, such as clinical fellows (CFs), are allowed to bill for services provided to Medicare beneficiaries under Part B. The guidance—nearly identical to the guidance CMS sent to ASHA in late July via email—states:

“[CMS will] defer to state licensure requirements to determine for SLPs in each state, allowing them to determine the SLPs that are most appropriate to provide speech-language pathology services to individuals/patients, including Medicare beneficiaries… This means that to the extent that an SLP complies with the applicable state process for licensure, certification, or registration (if the state has one) necessary to practice as an SLP, which may include provisional or temporary licensure as such individual completes required supervised experience, such individual complies with the applicable licensure requirements found at section 1861(ll)(a)(4)(A) of the Social Security Act, 42 CFR 410.62(a), 42 CFR 484.115(n), and Section 230.3 of Chapter 15 of the Medicare Benefit Policy Manual.”

Of note, CMS:

Corrects a reference to the Claims Processing Manual made in the July email to the Benefit Policy Manual;
Notes it has issued guidance to Medicare Administrative Contractors; and
Reinforces the ability of CFs to bill for Part B services by stating: “CMS is clarifying that the state-licensed SLP may include provisional or temporary licensure as such individual completes required supervised experience and these SLPs may enroll as an SLP in Private Practice (SLPPP) and work for providers furnishing outpatient Part B speech-language pathology services, consistent with state requirements.”

Update: August 20, 2025

ASHA met with staff from the Centers for Medicare and Medicaid Services (CMS) for the second time since it reversed its position on Part B billing for provisional licensees (including clinical fellows) in late July. In the meeting held on August 19, 2025, ASHA reinforced the importance of CMS issuing formal guidance stating that state licensure, including provisional licensure, meets the definition of a qualified speech-language pathologist. CMS staff made it clear they intend to issue such guidance, but could not provide a definitive timeline for when it might be available. ASHA will share it with our members once it becomes available.

Original news post: July 29, 2025

Following extensive advocacy by ASHA, its members, and key stakeholder groups, CMS has reversed its previous interpretation of the term “licensed” –a change that excluded provisional licensees, including clinical fellows (CFs), from being recognized as qualified Medicare providers.

In direct correspondence with ASHA, CMS clarified that its updated interpretation aligns with state licensing requirements and allows individuals holding provisional or temporary licenses, such as CFs, to provide services to Medicare beneficiaries—provided they meet their respective state’s licensure requirements.

CMS’ Message to ASHA:

“After further review of our prior statement about “provisional” licenses for clinical fellows as well as the CY 2015 Home Health final rule (79 FR 66107), for Part B outpatient services furnished by speech-language pathologists, we now believe that deferring to the state licensure requirements for SLPs in each state would allow them to determine the SLPs that are most appropriate to provide speech-language pathology services to individuals/patients, including Medicare beneficiaries. In other words, to the extent that an SLP complies with the applicable state process for licensure, certification, or registration (if the state has one) necessary to practice as an SLP, which may include provisional or temporary licensure as such individual completes required supervised experience, such individual complies with the applicable licensure requirements found at 1861(ll)(a)(4)(A) of the Social Security Act and 42 CFR 410.62(a), 42 CFR 484.115(n) and Section 230.3 of Ch. 15 of the Medicare Claims Processing Manual.”

Why This Matters

ASHA applauds this revision of CMS’ previous guidance, which:

Ensures compliance with Section 1861(ll)(a)(4) of the Social Security Act
Preserves states’ ability to manage their professional licensing standards
Recognizes the skills and qualifications of provisional licensees
Most importantly, preserves access to care for Medicare beneficiaries.

What This Means for Provisional Licensees and Supervisors

CFs, and others who have obtained a provisional license, can treat Medicare patients without a specific level of supervision for payment purposes. However, CF supervision requirements still apply for the purposes of obtaining the Certificate of Clinical Competence (CCC).

In facility settings, these services will be billed through the facility’s National Provider Identifier (NPI).
In private practices, CFs must obtain an individual NPI, complete the Medicare provider enrollment application, and bill services under their own NPI.

Advocacy in Action

This change is a powerful example of advocacy success. Nearly 20,000 ASHA advocates and 36 state associations signed petitions joining ASHA in urging CMS to reconsider its previous interpretation. Additional support from trade and professional associations ensured CMS understood the broad implications for employers, SLPs, patients alike.

A Word of Caution

Please note: Some private payers and state Medicaid programs do not recognize provisional licensure as meeting their personnel standards for billing purposes. ASHA members should always verify billing and supervision requirements with each payer individually.

What’s Next?

ASHA is aware that several Medicare Administrative Contractors (MACs) have denied enrollment to CFs working in private practices because of the provisional nature of their license. ASHA has asked CMS to issue formal guidance to ensure this standard is consistently applied across all MACs. Updates will be shared with members as they become available.