ATTENTION ALL SCHOOL BASED SPEECH-LANGUAGE PATHOLOGISTS
As a result of the most recent changes to Medicaid billing in the public school system, the WV Board of Examiners has received numerous phone calls requesting information on several different issues including licensing, supervision, SLPAs/SSLPAs, etc.
Numerous licensed SLPS have questioned the legality and ethics of allowing another SLP/SSLPA to bill services provided using the licensee’s NPI#. The Board’s position is that absolutely no one is permitted to bill with your NPI#, except you. Regardless of the work setting, it is fraudulent for anyone to bill for a therapy service for which they did not provide. This position is backed by the WV Board of Examiners Code of Ethics §29-5, as well as, the US Dept. of Health & Human Services – Office of Inspector General as described in the “Avoiding Medicare and Medicaid Fraud and Abuse” Training Booklet on page 10 – . The entire document can be viewed at http://oig.hhs.gov/compliance/physician-education/roadmap_web_version.pdf
I realize this is booklet is called “A Roadmap for New Physicians” but the Medicaid billing fraud issues are the same for all health professionals.
Chapter 538 (School-Based Health Services) of the BMS Provider Manual specifically states –
“To render speech language pathology services to Medicaid members under School-Based Health Services the SLP must be licensed by the West Virginia Board of Speech-Language Pathology and Audiology and must comply with all rules and regulations under WV Code §30-32-1 thru §30-32-23.” This includes Speech-Language Pathology and Audiology Assistants; supervision requirements in §30-32-15. If you are supervising SLPAs, the rules for supervision as denoted by WV law must be adhered to regardless of your employment venue. In addition to any sanctions that might be imposed during the complaint and disciplinary action process by the Licensure Board, all infractions must be reported to “relevant state and federal authorities, ASHA, WVSHA and other applicable authorities….” §30-32-6.(5)
The majority of unlicensed School Based Speech-Language Pathologists meet the requirements for licensure by the Board of Examiners. Based on the new CMS/Medicaid policy, a license is required to bill Medicaid as a Speech-Language Pathologist.
ALL inital/first time Audiology and/or Speech-Language Pathology License applicants are REQUIRED to complete the Jurisprudence Exam. Simply click on the Jurisprudence Exam link above to begin.
ACTIVE/CURRENT LICENSEES WILL RECEIVE ONE (1) HOUR OF CONTINUING EDUCATION CREDIT BY TAKING THE JURISPRUDENCE EXAMINATION AND SUBMITTING THE COMPLETION CERTIFICATE WITH THE REQUIRED CE DOCUMENTATION FOR THE 2016 LICENSE RENEWAL.
NEW REQUIREMENTS FROM CMS FOR SPEECH-LANGUAGE PATHOLOGISTS WHO BILL MEDICAID FOR
THERAPY SERVICES PROVIDED IN PUBLIC SCHOOLS
At the 2015 WVSHA convention, Cynthia Parsons from DHHR announced that, effective August 1, 2015, there is a rules change regarding Medicaid billing requirements for speech therapy services provided in the public school system.
- Speech-Language Pathologists are required to be licensed by the WV Board of Examiners for Speech-Language Pathology & Audiology to bill Medicaid for the services provided. If a Speech-Language Pathologist does not have a license, they may continue to bill Medicaid as a Speech-Language Pathology Assistant and at a lower billing rate.
- This change was confirmed by Jeremy Brunty of the WV Dept. of Education.
Below are several different scenarios with an overview of how to apply for a license with the WV Speech-Language Pathology (WVBESLPA). If you have questions, PLEASE do not hesitate to contact our office.
1. If you are ASHA Certified but have never applied for and/or have never been licensed by the WVBESLPA:
a. Complete the “Initial Application for SLP & AUD”(found under the Forms link). The application must be signed and notarized. There are also instructions for completing the application under the Form link.
b. Include a copy of your ASHA certification card
c. Complete the Jurisprudence Exam – required for all new applicants. (Click the link at the top of the page) Print the certificate when finished with the exam and submit with the application.
d. Include the application and licensing fees - $300 thru June 30, 2015. The fee is pro-rated down to $250 from July 1 thru December 31, 2015.
2. If you are NOT ASHA Certified and have never applied for and/or have never been licensed by the WVBESLPA:
a. Please call our office @ 304-473-4289 to discuss the qualification requirements for WV licensure per WV Code §30-32 & WV Code Rule §29-1.
3. If you were previously licensed by the WVBESLPA and your license expired on 12/31/2014:
a. Complete the renewal application via the Online Renewal link. You will be
required to enter your SLP license number (SLP-XXXX) and the last four of your social to access the renewal process. If you do not know your license number, please call 304-473-4289 and we will be glad to assist you. The total fee is $250.00
b. If you prefer to mail a renewal application with a check; download, print and complete the Renewal Application under the Forms link. Submit the application with a check for $250.00
c. Submit 20 hours of approved Continuing Education completed during the years 2013 & 2014. If you renew online, please either fax or email the continuing education documents. If you mail the application, please submit the continuing education with the application and renewal fees.
4. If you were previously licensed by the WVBESLPA and your license expired on 12/31/2010 or 12/31/12:
a. A license reinstatement is required. Complete the renewal application via the Online Renewal link. You will be required to enter your SLP license number (SLP-XXXX) and the last four of your social to access the renewal process. If you do not know your license number, please call 304-473-4289 and we will be glad to assist you. The total fee is $275.00
b. If you prefer to mail a renewal application with a check; download, print and complete the Renewal Application under the Forms link. Submit the application with a check for $275.00.
c. Submit 10 hours of approved Continuing Education for each year your license was inactive or a maximum of 25 hours. If you renew online, please either fax or email the continuing education documents. If you mail the application, please submit the continuing education with the application and fees.
5. If you were previously licensed by the WVBESLPA and your license expired prior to 12/31/2010:
a. You are required to apply for a new license. Please follow 1 and/or 2 above.