Supervision of Clinical Fellows

Overview

The Speech-Language Pathology Clinical Fellowship (CF) is a mentored professional experience that begins after the student completes their academic coursework and clinical practicum. The goal of the CF is to allow the Clinical Fellow to transition between being a student enrolled in a communication sciences and disorders (CSD) program and being an independent provider of speech-language pathology clinical services. CF mentors play a critical role in the preparation of speech-language pathologists (SLPs). They (1) assess the Clinical Fellow in the demonstration of skills and knowledge appropriate for independent practice and (2) provide professional support and personal guidance to the Clinical Fellow across the CF period.

On the page:

Supervision Requirements for the Clinical Fellowship
Clinical Fellow Mentor Qualifications
Clinical Fellow Mentor Responsibilities
Amount of Supervision
Feedback Sessions
Ethics
Billing and Reimbursement
Resources

Supervision Requirements for the Clinical Fellowship

The following requirements are based on the 2020 Standards for the Certificate of Clinical Competence in Speech-Language Pathology (CCC-SLP) established by the Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC).

Clinical Fellow Mentor Qualifications

All CF mentors must meet the following requirements to mentor a Clinical Fellow:

Hold a current CCC-SLP throughout the entire CF experience.
The CF mentor and Clinical Fellow cannot be related in any way.
For all applicants who apply under the 2020 standards and earn hours toward the completion of their CF on or after January 1, 2020, their CF mentors
- must have 9 months of full-time practice experience (or its part-time equivalent) working as a speech-language pathologist (SLP) after being awarded the CCC-SLP and
- must have completed 2 hours of professional development in the area of supervision and/or clinical instruction at least once in their career after being awarded the CCC-SLP.

A Clinical Fellow may not count hours earned during any time that the CF mentor does not meet the 2020 Speech-Language Pathology Standards’ supervision requirements. See Supervision Requirements for Clinical Educators and Clinical Fellowship (CF) Mentors for more information.

Clinical Fellow Mentor Responsibilities

The CF mentor helps improve the clinical effectiveness of the Clinical Fellow through meaningful mentoring and feedback and assists the Clinical Fellow in developing independent clinical skills.
The CF mentor’s ASHA certification status must be current during the entire CF experience in order for the Clinical Fellow to use those hours to apply for ASHA certification.
Each CF mentor and Clinical Fellow is strongly encouraged to read ASHA’s Issues in Ethics, Responsibilities of Individuals Who Mentor Clinical Fellows in Speech-Language Pathology.
The CF mentor must complete all records and feedback/ratings within a timely manner. See 2020 Standard VII.
The CF mentor must provide opportunities to view and accurately rate all skills listed in the 2020 CFSI [PDF].
Each CF mentor must provide the minimum required on-site and in-person supervisory activities per segment in order for the hours and weeks earned during that segment to count.
Each CF mentor must self-attest to meeting this one-time requirement. The CF mentor can check their status on the ASHA Certification and Ethics Verification webpage.

Amount of Supervision

Each mentor must complete a minimum of 6 hours of on-site and in-person direct observation and 6 hours of indirect observation during each segment (or part-segment) that they serve as a Clinical Fellow’s CF mentor. This equates to 18 hours of direct supervision and 18 hours of indirect supervision during the full CF experience.

Indirect observation typically includes reviewing diagnostic reports, treatment records, and plans of treatment; monitoring the Clinical Fellow’s participation in case conferences or professional meetings; and/or evaluating the Clinical Fellow’s work by consulting with colleagues or clients and their families.

The CF mentor and the Clinical Fellow must coordinate the observation schedule to ensure that all skills are observed and evaluated during each segment of the CF experience. It is expected that the observations are spread throughout the duration of the CF experience, with no more than 6 total observation hours completed in 1 day. You may use this template for tracking supervisory activities [PDF].

Mentors may provide more supervision if (a) their local or state policies require more and/or (b) they feel that their Clinical Fellow would benefit from more supervision.

For the purposes of ASHA certification, Clinical Fellows may work in more than one location, and they may have more than one CF mentor. If the Clinical Fellow has more than one CF mentor, each CF mentor must complete the required supervisory activities for the weeks and hours to be counted toward the completed CF unless the CF mentors collaborate to provide a robust CF experience. In these instances,

both mentors must share the same employer and
one CF mentor becomes the primary mentor and completes the CF report on the Clinical Fellow's online certification application.

For more information, see A Guide to the ASHA Clinical Fellowship Experience.

Feedback Sessions

Feedback sessions are an integral part of the CF experience. The CF mentor must provide performance feedback to the Clinical Fellow at least once during each segment of the CF. During feedback sessions, the CF mentor and the Clinical Fellow should discuss strengths or weaknesses in the Clinical Fellow’s ability to independently practice as a clinician. Through discussion and goal setting, the CF mentor should use these sessions to assist the Clinical Fellow in developing the required skills.
CF mentors are strongly encouraged to provide copies of written feedback to the Clinical Fellow during each segment and that both parties keep copies of these feedback session notes for their respective records.
The CF mentor must provide performance feedback to the Clinical Fellow at least once during each segment of the CF using the 2020 Clinical Fellowship Skills Inventory (CFSI) form [PDF].
The Clinical Fellow must receive a score of "2" or better on all skills on the 2020 CFSI [PDF] during the final segment of the CF experience.
Clinical Fellows enter the experience on their online application. Mentors verify the hours and enter the Clinical Fellow’s scores online. Mentors and Clinical Fellows should not submit paper copies to ASHA but, rather, should keep them for their own records.

Negative Recommendations

If the CF mentor anticipates at any time during the CF that the Clinical Fellow will fail to meet requirements, then the mentor must counsel the Clinical Fellow (both verbally and in writing) and maintain written records of all contacts and conferences conducted during the experience. If the CF experience is terminated at any time before completion of the CF, or if the CF mentor does not recommend approval, the CF mentor must complete the online CF Mentor Verification page in the certification application portal and provide justification for the negative recommendation.

CF experiences with negative recommendations will not be applied toward the total number of hours/weeks required to complete the CF. Within 30 days of making the negative recommendation, the CF mentor must submit to the CFCC a letter of explanation with supporting documentation. This information must be shared with the Clinical Fellow. Following a negative recommendation, the Clinical Fellow may complete an entirely new CF, a portion of the CF, and/or request an appeal by the CFCC.

Ethics

Mentors share in the responsibility of preparing future speech-language pathology professionals for a lifetime of ethical conduct. CF mentors are expected to abide by the ASHA Code of Ethics and have the opportunity to reinforce and model the importance of the Code of Ethics to their Clinical Fellows. As such, CF mentors need to be familiar with their obligations as described in the Code and with certification standards—as well as with all supervisory obligations in the pertinent sections of their respective state licensure laws. Compliance with local, state, and federal laws as well as payer policies is required.

Although the Code does not apply to the Clinical Fellow until they are applicants for ASHA certification, the fundamental principles and rules will be an essential part of their professional future. For additional guidance, CF mentors can review ASHA’s Issues in Ethics: Responsibilities of Individuals Who Mentor Clinical Fellows in Speech-Language Pathology.

Billing and Reimbursement

Medicare Coverage of Services Provided by Clinical Fellows in Health Care

To determine whether a Clinical Fellow is authorized to practice and have their services reimbursed, the Clinical Fellow and their mentor must be aware of the intersection of payment policy, state and federal laws and regulations, and ASHA’s Code of Ethics. These requirements do not exist in a vacuum; rather, they interact to drive appropriate practice and reimbursement.

Many payers—such as state Medicaid agencies, Medicare, and private insurers—can establish personnel qualifications for reimbursement that do not recognize Clinical Fellows as qualified clinicians for the purposes of reimbursement. This is often because a state does not offer licensure to Clinical Fellows. Some payers provide lower reimbursement rates for services provided by Clinical Fellows, so it is important to verify these standards as well.

Clinical Fellows who are practicing in states that grant Clinical Fellows temporary or provisional licensure are fully qualified to provide services according to Medicare regulations. However, in states without such licensure, Medicare treats Clinical Fellows as graduate students requiring "in-the-room" supervision.

See ASHA's State-by-State for more information on licensing laws. Detailed information on payer policy considerations for unlicensed Clinical Fellows is available on ASHA’s website:

Medicaid Coverage of Services Provided by Clinical Fellows in Schools

According to Alban-Havens billing for Medicaid services provided by Clinical Fellows in schools varies. Here are three examples of how states interpret this issue:

Some states issue temporary or interim licensure to CFs that allows the CFs to bill Medicaid for services provided in schools.
Some states—even those with temporary licensure—restrict the scope of practice and the services provided by the CF and require the CF supervisor to bill for the services. This rule might require the supervisor to provide more frequent supervision than mandated for ASHA certification.
In states that do not issue a temporary or interim CF license, the CF is usually unable to bill Medicaid independently. Regulations in Utah, for example, state that "Speech-language students in their final clinical fellowship year may provide Medicaid services under direct supervision, but Medicaid billing must be done by a licensed speech-language pathologist."