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MacIntosh, Weston (LARA)

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FW: Comments on Speech-Language Pathology General Rules

Tuesday, January 19, 2021 12:31:28 PM

MSHA Response to SLP Rule Changes 2021.pdf

From: Kelli Pierce <kelli@therapyjackson.com>

Sent: Tuesday, January 19, 2021 12:28 PM

To: BPL-BoardSupport <BPL-BoardSupport@michigan.gov>

Subject: Comments on Speech-Language Pathology General Rules

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Hello,

Attached please find MSHA's comments on SLP General Rules MOAHR #2020-78 LR.

Thank you for your consideration.

Sincerely,

Kelli Pierce M.A., CCC/SLP

Speech/Language Pathologist

Assistant Director of Clinical Compliance & Development

VP for Advocacy, Michigan Speech-Language-Hearing Association

Comprehensive Speech and Therapy Center, Inc.

Phone: 517-750-4777

Fax: 517-782-4717

www.therapyjackson.com

http://www.facebook.com/CSTC.Jackson

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Michigan Speech-Language-Hearing Association

Assistance, Awareness & Advocacy in Communication Sciences & Disorders

To:

Department of Licensing and Regulatory Affairs

Bureau of Professional Licensing – Boards & Committees Section

P.O. Box 30670

Lansing, MI 48909-8170

Attention: Policy Analyst

Email: BPL-BoardSupport@michigan.gov

RE:

Response to Speech-Language Pathology – General Rules (MOAHR #2020-78 LR)

Date: January 19, 2021

The Michigan Speech-Language-Hearing Association (MSHA) represents speech-language pathologists

(SLPs) in the state of Michigan. We are writing in response to general rule changes included in MOAHR

#2020-78 LR.

One of the changes proposed includes a change in the educational limited license to a 12 month nonrenewable

license. Previously, the educational limited license was issued for two years, with the option to renew two

times.

The educational limited license requires 1,260 supervised working hours and is aligned with the American

Speech-Language-Hearing Association’s (ASHA’s) requirements for completion of a clinical fellowship

program, a time where recent graduates receive direct and indirect supervision from an experienced and

certified SLP. ASHA proposes that this supervision experience be completed in a minimum of 36 weeks

working 35 hours per week and cannot exceed 4 years following the beginning of the clinical fellowship

experience. Following completion of the 1,260 supervised program, the SLP is able to become fully certified

by ASHA and practice independently. This is similar to the State’s current educational limited license; upon

completion, the SLP is able to apply for a full license and practice and bill independently. While the hours and

supervision requirements are similar between ASHA’s clinical fellowship program and the educational limited

license in the State of Michigan, the time limits differ greatly.

The proposed changed to a 12 month, nonrenewable license is untenable for many SLPs across the state. There

are many circumstances in which an individual holding an educational limited license may not be able to

complete the required 1,260 hours within 12 months. Some examples include an unplanned, extended medical

leave from work or lack of full-time employment. Should an SLP with an educational limited license obtain

employment in a school setting, there is a significant chance that s/he may not work for the three months over

the summer, putting further strain on the supervised clock hour and time sensitive requirements for their

license. Part-time employees, working less than 24 hours per week, would not be able to complete 1,260 hours

within a 12 month time frame. Additionally, as we have all learned while living and working through a global

pandemic, there are many unknown circumstances that can arise, limiting working hours and places of

employment, thereby reducing the ability to gain experience and clinical hours toward the 1,260 hour

requirements.

Our concern is that recent graduates in the field of speech-language pathology may leave the State of Michigan

to complete their clinical fellowship, perhaps never to return. This puts a tremendous strain on the field of

speech-language pathology in the State of Michigan, as many employers are already indicating the need for

more SLPs and the trajectory for the need for SLPs in a variety of settings is not decreasing. This limitation

encourages recent graduates of speech-language pathology programs to look beyond state lines to complete the

certification requirements in order to practice at the fullest extent of their license and certification.

We at MSHA are working with our lobbyist to propose legislative changes to MCL 333.17609(4) to extend the

current 12 month limit. While we understand that these General Rule changes are being made to align with

Public Act 368, we are asking that considerations for temporary renewal of a 12 month educational limited

license be made until the time that updates to the Public Act can enacted.

Thank you in advance for considering our concerns regarding changes to the licensing requirements for

educational limited licenses in the State of Michigan.

Sincerely,

Gregory J. Spray, Ph.D., CCC-SLP

Kelli Pierce, M.A., CCC-SLP

President

Vice-President of Advocacy

Michigan Speech-Language-Hearing Association

spraygre@msu.edu

kelli@therapyjackson.com