The world is a much different place than it was just a few weeks ago, and we understand the affects the Coronavirus/COVID-19 is having on you—especially our graduate student clinicians and our Clinical Fellows. We understand this unprecedented time is affecting your ability to be physically present with clients/patients in order to meet the requirements of the 2020 Audiology and Speech-Language Pathology Certification Standards. It’s making the upcoming months feel like a very uncertain and difficult time as you take the next steps in your career.

The National NSSLHA and ASHA Certification teams have received a lot of questions about whether student clinical hours can be reduced, or what happens to Clinical Fellows if their sites are closed. On your behalf, we’ve reached out to the Council on Academic Accreditation (CAA), who govern ASHA accreditation of graduate programs, and the Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC), who govern ASHA certification, for clarification. Here’s what we’ve learned:

Maintaining Clinical Education Requirements

The CAA and CFCC have been meeting regularly to discuss your questions and concerns. Although they are not reducing the number of clinical practicum hours, please understand that these decisions were not made to penalize students, Clinical Fellows, or their programs, but to uphold client/patient/student safety by ensuring all certificate holders meet certification requirements that have been vetted and required for practice for many years.

Rationale for Maintaining Clinical Education Requirements

Clarification about why the decision has been made to maintain these clinical education requirements:

Jurisdiction of Program Requirements

In addition to ASHA certification and state-level requirements, graduate programs follow requirements set by additional entities, like the U.S. Department of Education, and the Council for Higher Education Accreditation. Programs must also follow their university policies, procedures, and requirements for graduation. The CFCC has jurisdiction over what is required for the purposes of ASHA certification only; however, ASHA does not have jurisdiction over requirements set by the other entities.  

Responsibility to Assure Clinically Competent Practitioners

The CAA and CFCC have a responsibility to assure stakeholders that graduates, Clinical Fellows, and certificate holders are clinically competent to practice. The accreditation and certification standards have been developed and refined throughout the years by undergoing a vigorous vetting process to protect the public, students, and payers. These standards ensure standardization in the amount and quality of education and training that students receive prior to beginning their CF and that a Clinical Fellow receives before practicing as an independent clinician.

Risk Factors

Reducing standards could pose potential risks to graduate students who

• may not be competent and/or qualified to practice as those who were educated and trained before them or those who will be educated or trained in the future,
• may not be able to meet state licensure or insurance requirements, and
• most importantly, may put clients/patients/students at risk.

All of this said, the CFCC has identified ways for students to complete the required clinical practicum hours, and for Clinical Fellows to continue to accrue hours toward the completion of their Clinical Fellowship (CF) experience . . .

Allowances for Graduate Student Clinicians

The CFCC has made some accommodations over the past several weeks allowing hours/experiences to be counted for ASHA certification in ways which were previously not allowed. These accommodations are permitted between March 16 – May 31, 2020. Future extensions will be considered, as needed.

Telepractice with Telesupervision

Graduate student clinicians in both professions who are enrolled in a CAA-accredited or CAA-candidacy program may engage in service delivery through telepractice with the clinical educator providing 100% direct supervision of the sessions in real time.

It’s up to the discretion of each program to determine

• the decision to allow telepractice with telesupervision,
• which clients/patients are appropriate for telepractice,
• how many students may take part in an online teletherapy session with one client (with each student receiving the full hour), and
• the number of hours that may be earned through telepractice (separate from hours earned through clinical simulation).

Clarification of Clinical Practicum Hours

As you know, 400 total hours are required for ASHA Certification:

• 25 guided observation, and
• 375 supervised clinical practicum. 
  • 325 hours are required to be completed at the graduate level, while up to 50 hours may be completed during your undergrad program.
  • 75 hours (approximately 20%) may be obtained through clinical simulation.

If the clinical simulation and undergraduate hour allowances are used, only 250 “knee to knee” graduate clinical practicum hours are required. In most cases, this has been spread throughout your graduate program.

The ASHA Certification Standards do not state how many hours are required for each population type, age range, or in a particular setting. Your graduate programs have the authority to require a specific number for the purposes of ensuring competence, however ASHA’s Certification Standards are not prescriptive.

Allowances for Clinical Fellows

The CFCC has made some accommodations over the past several weeks allowing hours/experiences to be counted for ASHA certification in ways which were previously not allowed. These accommodations are permitted between March 16 – May 31, 2020. Future extensions will be considered, as needed.

Remember: As a Clinical Fellow, you are an independent service provider, not a student. You must follow all state licensure laws, even if they are different from what ASHA permits.

For Those Who Can Use Telepractice with Telesupervision

• Clinical Fellows may utilize telepractice with telesupervision if
  • telepractice and telesupervision are permitted by state law;
  • mentoring activities are completed in accordance with Standard VII;
  • your CF Mentor must meet the requirements for supervision in accordance with the standards under which you applied (or will apply):
    • 2014 Standards: Holding a current CCC-SLP
    • 2020 Standards: Holding a current CCC-SLP, with at least 9 months of full-time experience after earning the CCC, and a minimum of 2 hours supervisory professional development.
• The Clinical Fellow, supervisor/CF mentor, and client/patient/student must all be physically located the United States.
• The Clinical Fellow and CF Mentor must be appropriately credentialed/licensed in accordance with local/state/federal licensure laws and requirements. Sometimes, this means holding state licensure in 2 or more states.
• Telesupervision may be used for direct, on-site, and in-person observations of Clinical Fellows by the CF mentor(s) for a segment of the CF experience that occurs between the above-mentioned time period. Remember: A minimum of 6 hours of direct observations are required per segment.

For Those Who Cannot Participate in Telepractice with Telesupervision

The CFCC understands telepractice is not an option in all CF settings. For the above-mentioned time period, the CFCC will not require 80% of your work week in “knee to knee” direct client/patient contact. You may instead count hours:

• Report writing, notes, billing, IFSPs/IEPs, plans of care, etc.
• Virtually consulting with teachers or Child Study Team members, allied healthcare providers, family/patients, and CF mentors may observe these activities as “direct” observations.
• Planning and preparing testing schedules for the end-of-year testing.
• Preparing additional take-home packets for their clients/patients/students or setting up home programs.
• Completing indirect observations with your CF mentor in the form of reviewing documentation/cases.
• CF Mentors may count the time they observe you preparing home programs or virtually consulting/counseling as part of your “direct” supervisory activities.

Additionally, you may count up to 20% of your work week doing the other activities like in-service activities or professional development.

Reminder: For the purposes of ASHA certification, Clinical Fellows have 2 years from the date their application is submitted to start their CF, and up to 48 months from the date their CF experience began to complete their experience.

Ensuring Client, Patient, and Student Care

The CFCC understands the uniqueness of the current situation; however, they have the responsibility to ensure that CF experiences are completed in a reasonable and responsible way to ensure you—our Clinical Fellows—are prepared for independent practice without sacrificing client/patient/student care.

The CAA and CFCC are continuously monitoring the situation. For more detailed info, please visit asha.org/Certification/COVID-19-Guidance-From-CFCC. This webpage will be updated frequently as the situation unfolds.

If you have further questions, please contact certification@asha.org.