The Centers for Medicare & Medicaid Services (CMS) recently updated the definition of a qualified speech-language pathologist for Medicare Part B (outpatient) services in the Medicare Benefit Policy Manual [PDF]. This update has significant implications for provisional licensees—including clinical fellows (CFs).

The revisions to the policy manual removed from the definition the reference to “meet[ing] the educational requirements for certification and… in the process of accumulating, the supervision experience required for certification,” and added state licensure as a requirement. Therefore, it was important to clarify the status of all provisional licensees, including CFs, to ensure these individuals remain compliant with Medicare regulations. 

ASHA has received guidance from CMS that provisional licensure does not meet the definition of “licensed” for the purposes of Medicare Part B (outpatient) provider enrollment. This means that an individual with a provisional license is not considered a qualified Medicare provider and: 

• cannot enroll as a Medicare provider 
• cannot bill Medicare for the services they provide.

Therefore, if a CF is currently providing services to Medicare Part B beneficiaries, those patients must now be seen by a fully licensed SLP. ASHA recognizes the significant impact CMS’ interpretation of licensure has on CFs’ employment and is committed to working with CMS to reconsider their decision. Please note that Medicare standards only apply to Medicare, and Medicare may cover services provided to Part A patients by provisional licensees under supervision in some facility settings such as hospitals and skilled nursing facilities.

If this change impacts you, please see this resource for more information. You will find an outline of the changes, description of who is impacted, details on next steps, and contact information for your questions.

ASHA is actively advocating for this policy to be reversed. We are currently communicating with CMS and making a case for recognizing provisional licensees as qualified Medicare providers. A meeting with CMS is being scheduled to explain why provisional licensure must be included in federal personnel qualifications and strongly advocate for their inclusion in Medicare.

Learn more here: https://www.asha.org/news/2025/medicare-updates-definition-of-speech-language-pathologist-in-its-benefit-policy-manual/?utm_source=asha&utm_medium=email&utm_campaign=gappcf060925&sfmc_id=333085be-321d-4e17-817a-0c86474e7f3e