Minnesota Speech-Language-Hearing Association Presentation to the Board of Teaching

1. Minnesota Speech-Language-Hearing Association Presentation to the Board of Teaching August 2, 2013 Temporary Limited Licenses for Speech-Language Pathology Vacancies in the Schools

2. SCOPE of PRACTICE:WHAT DO SPEECH-LANGUAGE PATHOLOGISTS (SLPs) DO?

3. Clinical Service Populations • Potential causes of communication and swallowing disorders include: • neonatal problems (e.g., prematurity, low birth weight, substance exposure); • developmental disabilities (e.g., specific language impairment, autism spectrum disorder, dyslexia, learning disabilities, attention deficit disorder); • auditory problems (e.g., hearing loss or deafness); • oral anomalies (e.g., cleft lip/palate, dental malocclusion, macroglossia, oral-motor dysfunction); • respiratory compromise (e.g., bronchopulmonary dysplasia, chronic obstructive pulmonary disease); • pharyngeal anomalies (e.g., upper airway obstruction, velopharyngeal insufficiency/incompetence); • laryngeal anomalies (e.g., vocal fold pathology, tracheal stenosis, tracheostomy); • neurological disease/dysfunction (e.g., traumatic brain injury, cerebral palsy, cerebral vascular accident, dementia, Parkinson's disease, amyotrophic lateral sclerosis); • psychiatric disorder (e.g., psychosis, schizophrenia); • genetic disorders (e.g., Down syndrome, fragile X syndrome, Rett syndrome, velocardiofacial syndrome). (From American Speech-Language-Hearing Association. (2007). Scope of practice in speech-language pathology [Scope of Practice]. Available from www.asha.org/policy.)

4. Academic Preparation for SLPs • A master’s degree is the entry-level degree to the profession of speech-language pathology. A minimum of 75 semester credit hours is required to fully address the pertinent knowledge and skills. • SLPs receive a Certificate of Clinical Competence (CCC) from the American Speech-Language-Hearing Association. • Standards to obtain the CCC include: • A graduate degree obtained from an accredited program, which guarantees that coursework will cover all necessary topics • Undergraduate programs are not accredited • 400 hours of supervised clinical practicum during the graduate program, followed by a clinical fellowship year

5. SLP Services in Public Schools – Part I • Students can receive speech and/or language services from a SLP due to an identified disability in the area of Speech/Language Impairment (primary or secondary disability) OR as a Related Service need due to a disability in another area (13 disability categories) • SLPs are not classroom teachers and as such, may not provide independent classroom teaching. • When licensed by the Minnesota Department of Education, SLPs serve integral roles in buildings/districts and are essential members school faculties: • Working across all grade levels (Pre-k through Transition) • Serving a range of disorders

6. SLP Services in Public Schools – Part II • SLPs range of responsibilities and professional expertise include (but are NOT limited to): • Prevention and pre-referral intervention • Assessment (standardized and non-standardized) to determine existence of a disability and/or eligibility for specialized instruction • Specialized instruction and therapeutic intervention • Individual Education Program design employing a range of clinical/intervention skills and service delivery models (Least Restrictive Environment) • Data collection, analysis, and program progress determination • Compliance with policies, as well as State and Federal mandates • Parent and staff communication and collaboration (both general AND specific to areas of student service and disability needs) • Third-party billing

7. Professional SLP Shortage • Speech-language pathology has been identified by the U.S. Department of Education as a shortage area. • Temporary Limited Licenses (TLLs) have been granted in Minnesota to individuals attempting to fill speech-language pathology vacancies who are not eligible for a Speech-Language Pathologist license. • Across the state, 32 individuals were filling SLP positions using a TLL in the 2012-2013 school year, which represents an increase from 18 individuals working as SLPs using a TLL in 2011-2012.

8. Minnesota Statute 8710.1250 • Subp. 2. Criteria for issuance. The Board of Teaching shall grant a temporary limited license authorized by subpart 1 to an applicant if it finds that the following conditions are met: • A. the designated administrator of the employing school district or charter school requests a temporary limited license according to this part; • B. the designated administrator of the employing school district or charter school verifies in writing that: • (1) no applicant holding a license in a subject or field for which a temporary limited license is requested can fulfill the requirements of the position; • (2) the position has been advertised, and if the position is one-half time or more, the position has been advertised statewide; • (3) the school district or charter school will provide a mentor to give support and assistance in necessary skill development for the person holding a temporary limited license; • (4) the applicant for whom the temporary limited license is requested holds a baccalaureate degree from a college or university accredited by the regional association for the accreditation of colleges and secondary schools; and • (5) the applicant has completed a college or university degree with at least a minor in the area for which teacher licensure is requested, or a degree directly related to the professional preparation for which educational speech/language pathology, school nurse, school psychologist, school social worker, or school counselor licensure is requested. An applicant for a temporary limited license as a school nurse must also provide evidence of current registration to practice as a licensed registered nurse and current registration as a public health nurse under the Board of Nursing. An applicant for a temporary limited license as a school social worker must also provide evidence of current licensure to practice as a social worker under the Board of Social Work.[Emphasis added]

9. Concerns Regarding TLLs for Speech-Language Pathologists • Untrained or undertrained professionals (those with potentially no previous clinical experience) are not qualified or psychometrically trained to be performing standardized assessments and making decisions regarding evidence of a disability or service eligibility/dismissal, and should not be writing IEP goals or documenting treatment effectiveness. • Without the proper training, individuals providing therapy to remediate articulation, fluency, and voice disorders could do more harm than good, thereby worsening a student’s communication impairment. Also, without proper training in feeding, the individual providing the therapy could be putting the student’s health and well being at risk.

10. Concerns Regarding TLLs for Speech-Language Pathologists - I • An employee with a TLL is able to operate in the capacity of a fully licensed and credentialed professional. It is unclear how the individual can represent themselves and their qualification to students, families, and other professionals (e.g., what title is being used). • Districts appear to vary in the duration and extent of their efforts to find fully qualified professionals. • The state statute governing TLLs indicates that a “mentor” must be provided by the school district to the individual holding the TLL. • Many SLP vacancies are in rural areas; therefore, the school district may not employ any other SLPs who are able to serve as mentors. • It is not stated that the mentor must be a professional licensed in the area of the TLL.

11. Concerns Regarding TLLs for Speech-Language Pathologists- II • In a letter dated January 27, 2010, the acting director of the Office of Special Education Programs through the U.S. Department of Education informed the New Jersey Speech-Language-Hearing Association that Part B of IDEA in 34 CFR §300.156(b) states: qualifications for related services personnel and paraprofessionals [must be] consistent with any State-approved or State-recognized certification, licensing, registration, or other comparable requirements that apply to the professional discipline in which those personnel are providing special education or related services; and … related services personnel who deliver services in their discipline or profession…[must not] have not had certification or licensure requirements waived on an emergency, temporary, or provisional basis; and [must] allow paraprofessionals and assistants who are appropriately trained and supervised, in accordance with State law, regulation, or written policy, in meeting the requirements of this part to be used to assist in the provision of special education and related services under this part to children with disabilities.

12. Current Strategies to Resolve SLP Shortages 1. Minnesota’s five universities with SLP graduate programs are accepting more graduate students. • The universities have increased their graduate programs over the past 10 years—some more than doubled their graduate student admissions—without increasing their faculty size. Further increases could jeopardize the university’s accreditation because it affects the quality of the program. • To be certified, graduate students obtain clinical experience in medical and education placements. Availability of medical placements, in particular, prevents programs from accepting more students than they can accommodate with proper clinical experiences.

13. Current Strategies to Resolve SLP Shortages - I 2. Alexandria Tech is developing an associate degree program for Speech-Language Pathology Assistants. • The program will begin with its inaugural cohort in Fall 2013. Nineteen students have been accepted. • Students in the Alexandria Tech program are asked to determine their own clinical placement to obtain the required 100 supervised clinical hours. • SLP Assistants are not licensed in Minnesota, but are recognized under Minnesota statute. • Minnesota Statute 148.5192 outlines the duties that are appropriate, and inappropriate, for SLP Assistants to provide. They may not assess, diagnose, develop goals, or consult with families.

14. Current Strategies to Resolve SLP Shortages - II 3. A dozen or so universities around the country are offering online coursework to individuals pursuing a master’s degree in speech-language pathology. • Some programs allow students to secure practicum placements in their hometown, whereas others require that students travel to the university to obtain their clinical experience. • Tuition for practicum goes exclusively to the online university, so local universities are unlikely to assist distance-education students with practicum placements. • The closest online program to Minnesota currently is at the University of South Dakota. The University of Wisconsin Eau Claire is developing an online program that is expected to begin enrolling students in 2014.

15. Current Strategies to Resolve SLP Shortages - III 4. According to the U.S. Department of Education, individuals filling speech-language pathology vacancies may be eligible for student loan deferment or forgiveness. 5. Telepractice has been used by rural school districts to allow licensed and certified SLPs to provide speech-language therapy to eligible students.

16. Request to the Board of Teaching • As Minnesota moves forward with measures to increase the number of SLPs and SLP Assistants, the hope is that the number of SLP vacancies in educational settings will diminish. • Meanwhile, MSHA would like to discuss measures that will tighten the eligibility criteria for TLL for SLP positions. • These measures are vital in order to protect students and families by ensuring that the highest quality of speech-language services are being provided.

17. Thank You for your Time! • Any questions or concerns?