November 21, 2019

Dear ASHA Board of Directors and Council for Clinical Certification in Audiology and Speech-Language Pathology,

The National Joint Committee for the Communication Needs of Persons with Severe Disabilities (NJC) is made up of eight professional member organizations that include representatives from ASHA. The purpose of the NJC is to advocate for individuals with significant communication service and support needs resulting from intellectual disability, which may coexist with autism spectrum disorder, sensory and/or motor limitations. The NJC has reviewed the most recent joint statement released on October 30th on clinical specialty certification for AAC by ASHA, the Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC), and the American Board of Augmentative and Alternative Communication (AB-AAC). We found it dismissive of the concerns expressed by many ASHA members. The response letter did not provide a critical evaluation of risks and benefits of specialty certification. The joint statement provided conclusions regarding reasons we should support it, but no data to permit members to draw their own conclusions. We remain extremely concerned about the negative consequences that may arise from AAC Specialty Certification. This is a critical time for the NJC to advocate for individuals who receive AAC services, and we have the following requests:

·       We request that the CFCC withdraw approval of the AB-AAC and provide a new opportunity for peer review about the need for AAC Specialty Certification. Even though a survey was sent out, it obviously did not pick up the concerns of a substantial number of ASHA members. Limited information has been shared regarding how the need for specialty certification was determined other than the survey mentioned in the joint statement. There was no information about the results of the survey. No one has shared information regarding the investigation of risks that may arise from specialty certification. We believe it is in the interest of ASHA members to have an opportunity for review of board materials and independently determine the need for AAC Specialty Certification given all the concerns expressed.

·       We ask that the CFCC convene a panel of individuals with experience with health benefits sources’ (i.e., Medicaid, private insurance) and speech generating device (SGD) funding barriers to conduct a study about the funding implications of AAC specialty certification. There has not been adequate attention given to the implications that AAC specialty certification may have on public and private health benefits sources’ access to care and approval for funding of AAC devices as Durable Medical Equipment (DME). Because AAC specialty certification doesn’t yet exist, we can’t prove harm with insurers – but neither can it be proven that there will not be harm. AAC is different from other areas of specialty certification because it involves approval for DME – not just services. We do have data that shows Medicaid, and private insurers are quick to add new barriers to access (that don’t exist in other areas of SLP practice), e.g. trial periods with an AAC speech generating device before funding; high bars for authorization. There are reports of third party payers now requesting, in some states, for the SLP writing the SGD evaluation report to prove their competency to make the recommendation. Our fear is that if a specialty certification exists, such certification will be used as a point of denial for SGDs. Medicaid programs have been permitted to exclude or limit the scope of coverage of some health benefits providers, forcing services within their scope of practice to be performed by other professionals. We feel that restricting AAC service delivery to SLPs holding AAC specialty certification won’t be any different. Also, our concern is not limited to Medicaid. We have not been told of any way to prevent insurers or health plans from imposing similar SLP practice restrictions, the effect of which will be to dramatically reduce the availability of client access to AAC services and treatment.  One of our own NJC members saw these same attempts to deny services when the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) established certification for assistive technology (AT) providers. Funding agencies raised the bar, and perfectly legitimate funding requests were denied, with lack of certification being the excuse.

·       AAC should be ‘everybody’s business’, and specialty certification would send the wrong message to not only funders, but to practicing SLPs regarding their role in AAC service delivery. We fear that specialty certification may impact overall SLP perspective towards their need to be involved in AAC service delivery. AAC service delivery is already within the scope of practice of certified SLPs.

·       Finally, we worry about the impact of specialty certification on interprofessional efforts to address the communication needs of persons with severe disabilities. There is a risk that specialty certification will leave SLPs to stand alone to provide AAC assessment and service delivery, rather than alongside a team of providers (teachers, special educators, occupational therapists, physical therapist) that we know is the ideal treatment approach (Ogletree et al., 2017). The SLP who has specialty certification may be seen as the only credible expert, when other team members have critical knowledge regarding seating and positioning for optimal access of the SGD (OT/PT) and knowledge of how to best adapt the academic curriculum (teachers/special educators) for education settings of a student using an SGD.

All of these issues converge around our most pressing concern, which is the very likely reality that specialty certification will end up restricting access to services and supports for individuals with severe disabilities. That violates our ethical obligation to promote the welfare of those with communication limitations above all else. We expect that the ASHA Board of Directors, the Council for Clinical Certification in Audiology and Speech-Language Pathology, and the American Board of Augmentative and Alternative Communication will take the significant number of concerns expressed by a substantial number of ASHA members of SIG 12 seriously. SIG 12 has investigated the issue of developing specialty recognition and specialty certification three times in the past. Each time SIG 12 decided that they would not seek specialty recognition/certification for a number of reasons. They argued that what was needed was pre-professional training (which now is included in most graduate training programs) and professional development in AAC. We ask that the CFCC withdraw its approval, and provide the opportunities for independent review of board materials as noted above. We are happy to discuss our concerns with you if it would be helpful. Thank you for your consideration of our requests.


Members of the NJC

Bill Ogletree, PhD, CCC-SLP; At large representative, Committee Chair, ASHA Fellow

Andrea Barton-Hulsey, PhD, CCC-SLP; American Speech-Language Hearing Association representative

Amy S. Goldman, MS, CCC-SLP; American Speech-Language Hearing Association representative

Beth Mineo, PhD, CCC-SLP; Association of Assistive Technology Act Programs representative, ASHA Fellow

MaryAnn Romski, PhD, CCC-SLP; American Association on Intellectual and Developmental Disabilities representative, ASHA Fellow, ASHA Honors

Susan Bruce, PhD; Council for Exceptional Children/Division for Communication, Language, and Deaf/Hard of Hearing representative

Karen Erickson, PhD; TASH representative

Judith Schoonover, MEd, OTR/L, ATP; American Occupational Therapy Association representative

Rose Sevcik, PhD; United States Society for Augmentative and Alternative Communication representative, ASHA Fellow, Former SIG 12 Steering Committee Member (1995-2001); Associate Coordinator 1996-1998; Coordinator (1999-2001)

Mari Therrien, PT, DSc, PCS; American Physical Therapy Association representative