During this special NSSLHA Town Hall event, ASHA staff unpacked the evolving Medicare policy change that’s impacting provisional licensees—especially those working in adult medical settings. From understanding the policy shift to advocating for solutions, here’s what you need to know.

Watch the full recording below:

1.  The Issue: Medicare’s Policy Shift Is Impacting CFs

Medicare recently revised its interpretation of who qualifies as a provider under Part B, excluding those with provisional licenses from independently billing. Most states issue a modified form of licensure to new graduates—including clinical fellows (CFs)—while they complete their supervised clinical work experience needed to obtain a full license. While this doesn’t change state licensure or certification processes, it directly affects CFs working in outpatient adult medical settings and is leading to rescinded job offers, delayed start dates, and reduced access to care for Medicare beneficiaries.

2.  What This Medicare Change Means for You

This policy update has created uncertainty and stress for many students and CFs just starting their careers. Some are facing delayed job offers or changes in clinical fellowship placements. Remember, this situation is about Medicare rules and billing—not your skills or value as a clinician. Staying informed and connected can help you navigate these challenges as they evolve.

3. What About Documentation and Supervision?

For Medicare Part B billing, those under a provisional (sometimes called conditional, temporary, restricted, intern, interim, and even registration) or must be under 100% supervision. That means the supervising SLP must be physically present, direct the service, and sign off on all documentation. Because Medicare’s current interpretation is that provisional licensees cannot independently bill for their services, all documentation must include:

• The name, signature, and NPI of the supervising clinician
• A clear record of who rendered the service and the level of supervision provided

This is specific to Medicare Part B. Medicaid and private payers may have different rules, so it’s important to check directly with each payer to confirm their requirements.

4.  What to Know as You Start Your Clinical Fellowship

When you’re interviewing or negotiating offers, it helps to ask clear questions about the setting, the supervision model, and the patient population. Understanding how the employer handles Medicare cases and supervision requirements will give you insight into how this policy might affect your day-to-day work. Being prepared shows your professionalism and willingness to be a proactive team member.

To help you prepare:

• Completing the ASHA Clinical Fellowship Experience [PDF] walks you through key steps in your CF journey.
• The Clinical Fellowship Skills Inventory [PDF] outlines core skills that you’ll be expected to demonstrate.
• The Template for Tracking Supervisory Activities [PDF] is a helpful, optional tool Clinical Fellows and mentors can use to document observations, feedback, and supervision hours throughout the CF experience.

5.  What ASHA Is Doing

ASHA is actively pushing for clarity and change. Because CMS’s guidance has been inconsistent, ASHA is calling for clear, written confirmation that CFs with provisional licenses qualify as providers—just as they have since 2009. Advocacy efforts include direct outreach, coalition letters, and a petition with over 20,000 signatures.

6.  How You Can Help Advocate

Students and new grads can take action by:

• Submitting stories through ASHA’s policy feedback form to illustrate the real-world impact. Personal stories about rescinded offers, stalled CFs, or loss of patient access to care offer real stories of the impact of this policy change and help ASHA advocate with CMS on your behalf.
• Staying up to date via ASHA’s advocacy news

Additional Q&A

ASHA has put together a comprehensive Q&A covering many common questions related to this issue.  Among these, the timeline of the policy changes and the reasons behind recent enforcement actions are clearly explained, helping you to understand how this situation has developed. The Q&A also addresses concerns about the impact on provisional licensees, clinical fellows, and medical settings, and provides guidance on how to navigate the evolving regulatory landscape.

This moment is certainly frustrating, but it’s also a powerful opportunity for community and collective action. Whether you’re a student, a recent grad, or a supervisor, you can play a role in protecting the pipeline of qualified professionals and the care they provide. Stay informed, speak up, and support each other while we push for clarity and change.