What Changed

On July 29, 2025, the Centers for Medicare & Medicaid Services (CMS) reversed its earlier guidance that prevented clinical fellows and other SLPs with provisional licenses from billing Medicare Part B services. The reversal came after extensive advocacy efforts by the American Speech-Language Hearing Association (ASHA), state associations, and thousands of speech and hearing professionals nationwide.

CMS now clarifies that its updated interpretation aligns with state licensing requirements and allows individuals holding provisional or temporary licenses to provide services to Medicare beneficiaries – provided they meet their respective state’s licensure requirements. This means that states determine who is licensed to practice, including clinical fellows with temporary or provisional licenses.

Background on the Issue

The controversy began when CMS updated Chapter 15 of the Medicare Benefit Policy Manual in early 2025 to align SLP qualifications with existing regulations. While CMS stated that this contained “no new policy,” confusion arose when ASHA sought clarification on the impact to clinical fellows.

Initially, CMS staff clarified that provisional licensure did not meet the definition of “licensed” for Medicare provider enrollment purposes. This interpretation excluded clinical fellows and other provisionally licensed SLPs from billing Medicare Part B services.