The Centers for Medicare and Medicaid have officially reversed its prior interpretation that excluded Clinical Fellowship and Speech Language Pathologists holding provisional licenses from billing Medicare. Now, provisional or temporary license holders (including Clinical Fellowship and Speech Language Pathologists) are eligible to bill Medicare Part B for outpatient speech language pathology services so long as they meet their state’s licensure/license in process requirements.
The revised guidance defers to each state’s licensing process to determine whether provisional licensees can practice, aligning with 42 CFR 410.62(a), 42 CFR 484.115(n), and Medicare Benefit Policy Manual Section 230.3
CMS now considers provisional licensees in compliance with federal requirements if they follow their state’s licensure pathway, including temporary licensure tied to supervised experience.
This is great cause now, Clinical Fellowship and Speech Language Pathologists can enroll as Medicare providers, obtain their own NPI, and bill Part B services directly provided their state permits provisional licensing during the Clinical Fellowship year.
The Centers for Medicare and Medicaid policy reversal restores career pathways for newly graduated Speech Language Pathologists and supports access to care for Medicare beneficiaries. Private practices, employers, Clinical Fellowship and Speech Language Pathologists should review state licensure laws and payer policies to ensure compliance while maintaining quality care.
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