School Services

Vice President for School Services,
Beth McKerlie, MS, CCC-SLP

Welcome to the School Services News portion of the MSHA website. The purpose of this portion of the website is to provide information related to practice of Speech-Language Pathology and Audiology in Missouri public schools. Also included are items of interest to professionals practicing in Early Childhood Special Education settings. MSHA members’ suggestions for additions or changes in the format of the Schools News section are appreciated. You can comment by emailing Beth at msha@showmemsha.org

Latest Information from the VP for School Services

Posted 3/25/2011

Proposed Changes to SLP-A Guidelines:

The winter MSHANews included information about proposed changes in guidelines for Speech-Language Pathology Assistants (SLP-As) in Missouri.  I’ve received questions and comments that indicate there is some confusion about this issue and the reason for the current discussion.

In Missouri, those of us in school settings are more familiar with the implementer model than with the SLP-A guidelines.  “SLP-Assistant” is NOT a DESE title.  SLP-As are registered with the state Board of Healing Arts.  There are clear guidelines which specify what supervision is required, who can supervise, how many assistants an SLP can supervise, what duties SLP-As can complete, etc.  For that information, you can go to the State Board website at http://www.sos.mo.gov/adrules/csr/current/20csr/20c2150-4.pdf .  Go to page 13 and be sure you are not looking at SLP-aides information rather than SLP-assistants which begins in the middle of the page.  Please recognize that the current Rules are quite restrictive and not very practical.  The proposed Rules changes will make this credential a more practical option.
The Implementer model IS a DESE model and is not overseen by the State Board.  It was created in 1993 as a temporary measure to address shortages of SLPs in schools.  An implementer must be supervised by a qualified SLP, but requirements for supervision are very vague.  However, use of the implementer model MUST be approved ANNUALLY by DESE, the school MUST be actively recruiting an SLP, and there is specific information that must be provided to DESE.  For the DESE implementer guidelines, go to http://www.dese.mo.gov/divspeced/Compliance/Guidance/speechimp.html .

Beginning in summer of 2010, a group of Missouri stakeholders began meeting to discuss recommendations for revision of regulations for Speech-Language Pathology Assistants (SLP-A).  Among participants were representatives of the State Board for the Healing Arts, Missouri Speech-Language-Hearing Association, Missouri School Board Association, Missouri Council for Administrators of Special Education, the Department of Elementary and Secondary Education (DESE), and the 8 higher education institutes that have training programs in Communication Sciences and Disorders.  As you would expect, there was much discussion of the concerns with the current system.  Since SLP-A guidelines currently in state statute in Missouri are so restrictive, they are very rarely used and almost never in schools. 

Over several months, a proposal was developed for changing SLP-A guidelines to make them more appropriate for all settings, including schools.  The proposal included changes in credentialing of the SLP-A and a scope of practice that could be appropriate for all settings.  It was the understanding of most of the group that, if approved, the use of SLP-As in school settings would eventually take the place of the implementer model.  A DESE representative stated that if the proposal was approved, DESE would support it.

Some of the highlights: 

1. SLP-A requirements would include a bachelor’s degree in Communication Sciences and Disorders or the equivalent.
2. SLP-A would be supervised by a fully credentialed SLP.   Requirements for the amount of supervision would be specified.
3. Unlike the implementer model, an SLP-A could be used any time support personnel are determined appropriate for delivering services.  It would not be linked to inability to hire an SLP and would not require annual approval by DESE.
4. The 8 universities with SLP prep programs would establish programs to produce individuals trained to work as SLP-As.  All of the universities who sent representatives to participate in the stakeholders group expressed support for this.

So where are we now?  The proposal was submitted to the Board of Registration for the Healing Arts in December and was approved to proceed through the rulemaking process.  It will likely take another 6 to 9 months to finalize any revised regulations. There will be a public comment period when the proposed rules are published in the Missouri Register.  You are encouraged to watch for this comment opportunity and share your thought at that time.  If final rules are adopted that revise the SLP Assistant requirements that will not directly change anything related to the Implementer Model. It will be necessary for DESE to determine if and how the Implementer Model could be phased out.

As we get further information, MSHA will keep you posted on the ListServe and website.

SOCIAL SECURITY/PSRS:
Historically Speech-Language Pathologists (SLPs) employed by Missouri public schools have participated fully in the Missouri Public School Retirement System (PSRS). On October 22, 2008, the Office of Administration (OA) which administers and helps interpret the federal Social Security regulations for Missouri sent out a memo to all school districts regarding Social Security withholding for school employees who had previously participated in the PSRS and were exempt from Social Security withholding.

In a nutshell, what the changes would have done for a number of school employees, including SLPs and Audiologists is change the way they pay into the PSRS system. Employees not on the original 50+ year old agreement exempting them from Social Security would be required to pay 2/3 of the PSRS withholding and full Social Security withholding. This would be a total of 15.2% withholding from each check. It is assumed that because of the Windfall Elimination Provision of Social Security, most of these professionals would receive little benefit from the portion paid into Social Security and the PSRS benefits would be reduced.

On 11/18/08, the OA issued the decision that Counselors will continue to be exempt from Social Security based on documentation from 1948 that Counselors were required to hold a teaching certificate. The same decision stated that “other similar positions including, but not limited to, School Psychological Examiners, School Psychologists, Adult Education Supervisors, Career Education Counselors, Career Education Placement Coordinators, and Speech-Language Pathologists are still under review and are not considered exempt at this point.”

As a result of the numerous contacts from a number of education-related agencies (including MSHA), the Missouri Delegation consisting of senators and representatives from Missouri to Washington, D.C. requested and received a meeting with representatives of the Internal Revenue Service and the Social Security Administration (12/12/08).

The SSA, IRS, Public School Retirement System, and the Missouri Office of Administration formed a task force that was to begin meeting on Monday, December 15 to address this issue and was given 60 days to complete its work. The final meeting (of three) of the Federal Task Force for Missouri Public Schools with MO educational association leaders was February 5, 2009. At that time it was confirmed that SS changes would begin on 7/1/10, “no earlier or later.” The PSRS stated that, “Generally, however, it appears that fewer PSRS-positions would be required to contribute to Social Security than was originally thought. “ Other than that announcement, further word was not being made public.

Click here for a copy of the letter which ASHA submitted to the Social Security office
on MSHA’s behalf.

The Section 218 Task Force released its report on April 13, 2009. The most critical recommendation of the Task Force was that a full time "teacher" who has both a license to teach and is employed in a position that Missouri law requires a license to teach will continue to be excluded from Social Security coverage and from paying SS taxes. This will be decided based on DESE Core Data codes to determine if certification is required.

Core Data Codes from 10 through 60 require a license to teach which is essentially all "teachers," including Speech-Language Pathologists who are employed full-time in that position! Your Student Services Certification falls in that category regardless of which path you took to obtain it.

This will apply to full time employees only. If you are a part time employee (less than 17 hours per week), it is more difficult to determine and will depend on the category the school district falls into. For more info, check the above link. Also, it appears that retirees, who return to work in a position covered by PSRS less than 550 hours per year, will not be exempt from SS and will be required to pay SS taxes beginning July 1, 2010. There are also some SLPs who are considered Critical Shortage Hires. If you fall in that category, you would also NOT be exempt and will have to begin paying SS taxes July 1, 2010.

Many, if not most of you made a lot of contacts early in this battle. Please now take the time to thank the people who worked on our behalf...especially Claire McCaskill and Kit Bond.

CCC/NBT:
In July, 2008, in an attempt to obtain the same stipend for CCC’d SLPs as is provided Nationally Board certified teachers, SLPs in the Springfield Public Schools petitioned the Department of Elementary and Secondary Education (DESE) to evaluate the credentials of SLPs and determine that they are equivalent to those of Nationally Board Certified teachers.

On December 15, Rusty Rosenkoetter, Coordinator of Educator Certification for DESE, responded that she had completed a side-by-side review of the CCC standards and the National Board Teacher standards. She asked for an official letter from the MSHA Executive Board (EB) to take the request to the advisory committee and then, depending on the committee’s decision, to the State Board of Education.

The MSHA VP for School Services presented a formal request to DESE January 14, 2009 and was informed that it would take 5-8 months to receive a response since changes can only be made twice a year. She was contacted by DESE on February 25 and informed that the request had been tabled until April, 2009 due to some opposition on the advisory committee. More information was requested and immediately provided. Members will be advised of further updates via the Listserv as they are received.

Click here for a copy of MSHA’s formal request to DESE.

Missouri Has Seals?
State Education Advocacy Leaders (SEALs) are appointed by ASHA-recognized Speech-Language-Hearing Associations to act as advocates on issues related to education. The State Education Advocacy Leaders were established in 1999 under ASHA's Priorities. The mission of the SEALs network is to “enhance and perpetuate the advocacy, leadership, and clinical management skills of school-based ASHA members at the state and local levels to influence administrative and public policy decisions that affect the delivery of speech-language pathology and audiology services in school settings.” (www.asha.org). Missouri’s SEAL is Brenda Martien (bmartien@centurytel.net).

School Certification and Licensure
Important: The Missouri Speech-Language-Hearing Association is NOT a licensing agent. MSHA supports ASHA, the State Board of Healing Arts, and the Department of Elementary and Secondary Education, the agencies which license or credential professionals.
Missouri has a dual certification system for SLPs practicing in the public schools of the state. The Department of Elementary and Secondary Education (DESE) requires a Student Services Certificate of License to Teach as a Speech-Language Pathologist. This can be obtained by completing specific requirements in a teacher education program including professional course content in Speech Pathology and a minimum of 300 practicum hours or it can be obtained by possession of a Missouri license as a Speech-Language Pathologist from the Missouri Board of Registration for the Healing Arts. In either case, it is necessary to apply for the Student Services Certificate.

Click here for information about certification.
Click here for an application form for the Student Services Certificate.
Click here for an application form for renewal of the Student Services Certificate.

Click Here for information about obtaining a Missouri license through the Missouri Board of Registration for the Healing Arts as either a Speech-Language Pathologist or Audiologist.

Eligibility
Federal law requires each state to establish criteria for qualifying children ages 0-21 as eligible to receive Special Education and Related services. DESE’s criteria for each category of disability are summarized in the State Plan for Special Education.

Click here for to access further information about eligibility for Sound System Disorder.

Substitute SLPs & Missed Therapy Sessions
The question of how to handle missed therapy sessions in the public schools comes up frequently. On 11/2/06, ASHA requested clarification from the federal Office of Special Education Programs (OSEP) as to interpretation based on the IDEA Amendments of 2004. On 3/8/07, OSEP responded by addressing ASHA’s question about the need to use substitutes and to schedule make up sessions when speech/language sessions are missed as a result of either the child’s absences, the SLP’s absences, or other causes such as school activities. OSEP stated that these issues are not addressed in the federal law or the federal regulations. According to OSEP, it is up to each state to ensure a Free Appropriate Public Education (FAPE). Therefore, each school entity needs to consider the effect of absences (child’s or SLP’s) or other causes of missed sessions on the child’s progress toward IEP goals. If the goals are not likely to be met, missed sessions may be a denial of FAPE.

In an attempt to receive written clarification from DESE as to the state policy and ask them to consider the OSEP opinion, the MSHA Executive Board developed a Position Statement about missed sessions and presented a draft to Heidi Atkins Lieberman, assistant commissioner of education, on May 19, 2008.

Click here for a copy of the Position Statement.

DESE responded quickly and on 5/23/08, the following message was sent to school administrators via the DESE SELS List: ”The U. S. Department of Education, Office of Special Education Programs (OSEP) issued a policy letter in March 2007 (Letter to Clarke). That letter included several issues; one of those issues was compensatory services. In the letter, OSEP changed its mid-1990's position on compensatory services by noting that IDEA really does not provide for compensatory services, that the issue boils down to a free appropriate public education (FAPE) and that whether a child is in need of compensatory services is an individualized issue. It "encouraged" schools to convene IEP teams to address compensatory services when there has been a failure to implement due to things like provider absences.
After careful consideration and discussion, we have reached the conclusion that our long-standing position that provider absences requires either full make-up services OR an IEP team meeting and decision on the extent, if any, of compensatory services needed, is without authority. However, we strongly recommend that responsible public agencies consider continuing to address provider absences by either full make-up of services OR convening the IEP team to address the need for compensatory services. This is one way to ensure FAPE has been addressed. We also encourage you to discuss this with your school district lawyer.”

Early Childhood News

Click here for DESE’s FAQ Re: First Steps

School Affairs News

Check back soon for updates.

Links

ASHA

Missouri State Board for the Healing Arts

Missouri Department of Elementary and Secondary Education

Parents as Teachers National Office

Project ACCESS

Missouri Council for Administrators of Special Education

SLP/Audiology Job Site

Eligibility Criteria for Sound System Disorders in Missouri Public Schools
Following is information to assist SLPs determine eligibility for diagnosis of children with Sound System Disorders (SSD) in Missouri public schools.

1. DESE System for SSD with Single Error Sound
   The first item is the chart accepted by the Missouri Department of Elementary and Secondary Education (DESE) in September, 2007 for initial diagnosis of a single sound disorder. Click here for the chart.
   
   For further information about initial determination of eligibility for Sound System Disorder, go to http://dese.mo.gov/divspeced/PDF/SSQA.pdf for a Q&A on the DESE website.
   
2. System for Guiding Professional Judgment for SSD with Multiple Sound Errors
   A procedure for using professional judgment in determining eligibility when sound system disorders involve more than a single sound was developed by Dr. Julie Masterson and Sarah Basye (Missouri State University) with input from a team of clinicians working in Missouri Schools, including Susan Borgmeyer, Elaine Kempker, and Brenda Martien. The system is based on current research on typical phonological development in children. A "Quick Start" for Recommendations for Using Professional Judgment can be obtained by clicking here. For the accompanying research base, click here.



3. DESE-MSHA 2001 Chart for Developmental/Non-Developmental Errors
   This chart was developed by a task force including DESE and MSHA representatives in 2001 that is based on studies by Shriberg, 1993. School districts that were using this chart prior to the publication of the DESE chart in 2007 may continue to use it when considering initial eligibility for SSD on the condition that there is more than a single sound error present.