Speech Implementer Model and State Licensure Q&A
What is the issue with speech implementers and state licensure law?
Speech implementers provide services under a model established by the Department of Elementary and Secondary Education (DESE). (See www.dese.mo.gov/divspeced/Compliance/Guidance/speechimp.html for specific details about the model.) Speech implementers appear to function in a role very similar to speech-language pathology (SLP) assistants as described in state licensure law for speech-language pathologists (Chapter 345 of the Missouri statutes. Currently DESE is approving speech implementers to work in the schools without those individuals being registered as an SLP assistant as required by licensure law.
Can speech implementers register and provide services as SLP assistants?
Yes -- if they meet the SLP assistant requirements including training and supervision, implementers can register as SLP assistants. However, the education and supervision requirements for an SLP assistant are substantially different from those for a speech implementer. The SLP assistant must have a bachelor’s degree in communication disorders and one of every three therapy sessions provided by the assistant must be directly supervised by a licensed SLP. The speech implementer may hold a bachelor’s degree in communication disorders or hold a teaching certificate “preferably” in special education or elementary education. Direct supervision may be provided by either a licensed or DESE certificated SLP and the supervision is “periodic” at the school’s discretion. It is advisable for an implementer to check with the school district to see if the level of supervision necessary for an SLP assistant can or will be available.
Is there an exemption for schools in the speech-language pathology (SLP) licensure law?
No -- there is no blanket exemption for individuals working in the schools. The exemption in the licensure law is limited to individuals who hold the DESE SLP certificate and provide services while employed by the schools. Speech implementers do not hold a DESE SLP certificate so they are not covered by this exemption.
When will schools know if speech implementers must be registered and meet the requirements for SLP assistants?
The Board of Healing Arts, Speech-Language Pathology and Audiology (SLP/A) Commission has been reviewing information from DESE in an attempt to determine if speech implementers should be registered and meet the requirements for SLP assistants. As of January 2007, the Board and Commission asked the Attorney General’s office for an official opinion on the matter. Until that opinion is available, the issue remains unresolved.
If I supervise a speech implementer, is my SLP license in any jeopardy?
The SLP/A Commission opined that RSMo. 345.025.1(6) exempts SLPs who have a DESE SLP certificate from application of chapter 345 (the entire licensure law) while they are providing services in the schools. So even if it is eventually determined that speech implementers are practicing in violation of the licensure law by not being registered as SLP assistants, the license of supervising SLPs will not be in any jeopardy so long as they are practicing and supervising the implementer pursuant to their DESE SLP certificate as a school employee. If an SLP supervising a speech implementer does not have a DESE certificate and is providing the supervision, as a contractor pursuant to his/her license, that supervising SLP may have a problem if it is determined that implementers are practicing in violation of the licensure law.
Is there a problem with speech implementers becoming fully licensed SLPs?
Some speech implementers with bachelor’s degrees in communication disorders have a desire to become fully licensed SLPs. If it is determined that implementers are practicing in violation of the licensure law, it may be difficult for individuals who served as implementers to obtain their SLP licensure. The only apparent redress is for the implementer with a bachelor’s degree in communication disorders to register as an SLP assistant, make sure his/her supervising SLP is licensed, and make sure the level of supervision conforms to the Board of Healing Arts requirements for SLP assistants. Until the issue is resolved, this appears to be the only way to ensure the practice of an implementer does not violate licensure law.