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Date: February 18,2026
Qualifications for Speech-Language Pathologists Treating Medicare Outpatients
The Centers for Medicare and Medicaid Services has updated the Medicare Benefit Policy Manual to match the regulatory provision for the qualifications of speech-language pathologists (SLP’s) providing outpatient therapy services. This update has significant implications for the use of Clinical Fellow (CF) SLP’s.
In this article, I will answer the following questions:
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This is very harmful for services provided in rural settings. The only way we have been able to recruit SLP’s is to offer them a CF position. There is also an extreme shortage of medical CF opportunities even in urban areas which makes recruiting again difficult because of the lack of medical vs school district experience.
Often, a patient is admitted to the hospital as an inpatient, and then, after discharge through the billing cycle, the patient’s stay is ‘flipped’ to observation status. When therapy treated the patient, they would have been Part A, but then it gets billed as Part B. Are we covered in this scenario, or should we do something different?
Great question. In this scenario, you would not be covered if the service was provided by a CF SLP.
Is there any guidance for PTs that operate under a temporary license? Or is there preferred language that would help prevent this within a state practice act for such licensees?
Here is the language from CMS for PTs:
The regulation provides that a qualified physical therapist (PT) is a person who is licensed, if applicable, as a PT by the state in which he or she is practicing unless licensure does not apply, has graduated from an accredited PT education program and passed a national examination approved by the state in which PT services are provided.
For clarification to the reply: Is it to be interrupted that you must be licensed, pass the national exam and graduated from an accredited education program before Medicare will recognize a physical therapist provider? Or does the regulation allow the state to determine licensure (temporary or full) and if licensed they are accepted as a provider (i.e. not sat for the national exam due to the gap between graduation and national exam dates)?
Thank you for your expertise.
I can’t interpret for you. If you have questions, please contact advocacy@apta.org
In addition, read what CMS said to ASHA about what a license is.
Hello,
Our outpatient hospital based speech therapy department bills under the facility NPI, not the individual therapists, would this still apply?
Please read the answer to the 6th question in this article.
re: NPIs. We (hospital based OP department) work under our Hospital’s NPI (all therapists). Does the SLP supervising therapist need to have their own NPI to comply or can we still treat under the hospital’s NPI while still complying?
Please read the answer to this question
What settings does the clinical fellow speech-language pathologist change impact?
Thank you Rick but I guess I am asking – yes we (hospital based outpatient) are impacted but the change mentions NPIs, do we need to get individual NPI per SLP or is using the one hospital NPI still ok as we currently use.
CF SLPs can’t do OP therapy in any setting for Medicare patients at this time. Does not matter how you do the billing.
Do you know of any Medicaid state program that has followed this Medicare rule?
Read this article:
https://gawendaseminars.com/update-on-cf-slps-treating-medicare-beneficiaries/