This message has been developed by the Stop AAC Specialty Certification work group (stopaaccertification.org) in response to the joint statement by ASHA, CFCC, and AB-AAC on clinical specialty certification for AAC. We continue to oppose this certification effort. The joint statement did not supply any new information on the specialty certification endeavor, but rather was a compilation of responses that have occurred across the course of these discussions. The information requested has still not been provided.

The impact of this effort on SGD funding continues to be a fundamental concern of our workgroup and many SLPs in the broader community. Our group has provided actual evidence from the field of current expectations that the SLP making the SGD recommendation demonstrates expertise in AAC (NY Medicaid and MassHealth).  On the SIG 12 list serv, an affiliate recently shared her experience of having to “prove” her competency in AAC to insurers (WA state). It appears that ASHA, the CFCC and the AB-AAC are not acknowledging the real-life funding challenges affiliates and patients are currently facing. The recent joint response stated: “There is no evidence to suggest this [funding limitations] is true, has ever happened, or it going to happen.” Where is the data to support this statement?  Currently there is not an AAC specialty certification so this statement is misleading and inaccurate. We currently DO have evidence that there is a precedent being set of proving expertise and a specialty certification, endorsed by ASHA, is exactly what insurers are looking for.

Evidence for the actual NEED for this specialty certification does not exist. The joint statement speaks to a survey that was administered to affiliates of the SIG 12 and to SLPs that indicated AAC as an area of practice. Their statement indicated that the entire “need” for this effort is based upon this survey. They do not report the strength of this response rate to see if this was a statistically valid response, the exact demographics of the responders was not shared (e.g., SIG 12 affiliates vs. the broader SLP community which could imply bias in the sample), the exact response rate to all questions were not shared (was only one question asked?), and any free-text responses, if any, were not shared. In a peer-reviewed publication, this information would be required as well as a copy of the survey instrument that was administered. In short, there is still no evidence of need, only a general indication of enthusiasm for the effort. A survey is weak evidence, at best, to base an effort upon that will have drastic consequences on SGD funding for people who rely on AAC.

The AAC specialty certification effort continues to lack transparency. The joint statement has mischaracterized our question as being related to the actual process that is outlined on their website. We can read the website and are well-aware of this process. Our concerns about transparency have not been about those general steps. The transparency we are referring to is related to 1) refusal to share detailed information about the survey, 2) refusal to share the information from the town hall meetings to the broader SLP community, and 3) refusal to provide any other detailed documentation that proves this process is indeed appropriate and has a low amount of risk from an SGD funding perspective.

In summary, the joint statement from ASHA, CFCC, and AB-AAC does not adequately address the serious questions and concerns that have been posed by members of the Stop AAC Specialty Certification group and others in the SLP community.  This process continues to not allow adequate opportunities for input. Opportunities to volunteer have only been focused on advancing the effort. That is not an invitation for input; it is an invitation to be complicit. Given the serious impact this endeavor will have on SGD funding, complicity is not an option. 

Sincerely,

Concerned SLPs

Stop AAC Specialty Certification work group