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SCHOOLS FREQUENTLY ASKED QUESTIONS

 Speech Implementer Model and State Licensure Q&A

Does a child have to demonstrate reduced grades or achievement test scores in order to qualify as Sound System Disordered in Missouri Public Schools in order to meet the "adverse educational impact" requirement?

The U.S. Department of Education has provided clear interpretation of the phrase "adversely affects educational performance" as it applies to children with speech-language impairments.  This interpretation clearly states that a child who has a disability can not be denied services because she or he does not demonstrate concurrent academic problems (ASHA, 2005).  Following is a quote from a letter from Edwin Martin, Acting Assistant Secretary of Special Education and Rehabilitation of the U.S. Department of Health, Education, and Welfare (Office of Education in Washington, D.C.):

    "The meaning of educational performance" cannot be limited to showing of discrepancies in age/grade performance in academic subject-matter areas.  The extent of a child's mastery of the basic skill of effective oral communication is clearly includable within the standard of "'educational performance' set by the regulations.  Therefore, a speech/language impairment necessarily adversely affects educational performance when the communication disorder is judged sufficiently severe to require the provision of speech pathology services to the child."   "It is clear that, in establishing the existence of a speech/language impairment that is 'handicapping' in Part B (IDEA), a professional judgment is required.  The basis for that judgment is the child's performance on formal and/or informal measures of linguistic competence and performance, rather than heavy reliance on the results of academic achievement testing.  The impact of the child's communicative status on academic performance is not deemed the sole or even the primary determinant of the child's need for special education services.  It is the communicative status - and professional judgments made in regard to assessments of communicative abilities - which has overriding significance. 

In the event that the speech-language pathologist establishes through appropriate appraisal procedures the existence of a speech/language impairment, the determination of the child's status as a 'handicapped child' cannot be conditioned on a requirement that there must be a concurrent deficiency in academic performance."


Although the current Missouri Compliance Plan does not define the term "educational performance," an excellent explanation was included in previous state plans as follows:  Educational performance shall be interpreted as not only classroom applications of academic skills and concepts, but also as generalization of skills and behaviors such as social interaction, functional communication, and prevocational and vocational skills and behaviors in other environments.

Is it okay for a Special Education teacher to provide the services to a student with a language disorder, instead of the SLP?

It depends on what the IEP team determines is needed for the child.  If the IEP says that the child needs speech/language therapy, then the only acceptable models in MO to provide this therapy are from an SLP or through the approved implementer model.  If the IEP has goals and objectives addressing language skills and the team determines that those needs can be addressed in the regular education program or through specialized instruction, then the IEP would not indicate speech/language therapy and those identified needs would be addressed by someone other than the SLP.

I would like some different views on the roles and responsibilities for SLP's and dysphagia in the school setting. Is the school responsible for the nutrition of the student or is it a medical issue? Who pays for the swallowing eval? I would like any info that you could provide on this subject. I have listened to a lot of different views. Are there any official guidelines through DESE?

Often tongue-thrust and swallowing issues are viewed as medical issues and typically are not considered applicable to educational outcomes.  However, if an IEP team determines that the child needs speech therapy designed to address either of these issues in order to receive FAPE, the district would be required to provide the therapy.  Eligibility in the category of Speech Impairment based on either of these conditions alone would likely not meet the definition in the Missouri State Plan for Special Education.  If the child demonstrates other communication difficulties as outlined in the State Plan and has accompanying tongue thrust or swallowing problems, the team should consider how those problems impact the child’s overall communication skills and if needed, provide the necessary intervention.   

If it is determined that swallowing needs to be addressed, would the school district have to pay for a modified barium swallow at a hospital or would informal assessment of swallowing be used to diagnose the problem?

I think that part of the decision-making process would be a review of existing reports available to the team from the medical doctor’s assessment of the child’s condition.  I doubt that a school based team would be the first to determine that the problem exists and my response was that a school team may have to respond to the condition and the need for services as they write the IEP.  Some children in our State Schools for the Severely Handicapped have disabilities that impact swallowing and interventions for their problems are a part of their IEP when the team determines that the child needs the services in order to receive FAPE.  An example may be the child with excessive drooling stemming from cerebral palsy and a determination that oral-motor interventions would reduce or eliminate the problem and improve communication.  In those cases the team may decide that the therapy is necessary and the need directly related to the long term goals for the child in communication.  If a team determines that an assessment of the child’s swallowing function is necessary in order to appropriately program for the child, then yes, the district would pay for the testing.  However, I don’t see this as an issue that would originate at the school level but something that comes to the school team based on information from other evaluations and/or recommendations from the child’s medical team.         

If a speech therapist currently holds a PCII teaching certificate, what will they renew it as?  It was my understanding at the student services certification meetings that the new requirements and new title of student services would not apply to people already holding certificates. 

If a SLP just moved to Missouri and is interested in getting a teaching certificate, is it in her best interest to wait until the new certification requirements are approved and then pursue getting a student services certificate, or would it be in her best interest to pursue getting her certificate now?  She is not planning on working in the schools for the next year or two, but would like to get her certificate.

The old Speech Language Specialist certificates will remain under the professional certification classifications.  The Student Services classification began for individuals who apply after 8/28/03.

Typically, I would advise people not to wait for the new changes unless they are not going to be using the certificate in the near future; then I would recommend that they wait.

Can SLPs use Substitute Teachers?

The only individual that can substitute for an SLP is another appropriately credentialed SLP.  If an appropriate credentialed substitute SLP cannot be provided and services are missed because of absence or illness of the SLP, then services must be made up.

There is flexibility in how missed sessions are made up.  They do not have to be made up in the same way that they are originally scheduled.  The make-up session can be done in shorter or longer increments of time than originally indicated and can be done in a group or individual.  For example, if a child was scheduled to have one-on-one therapy two times a week for 30 minutes each session and one of those sessions was missed, then the make-up could be for two15 minute sessions with a small group.  Another option would be to make up time after school or in the summer.  I do understand that if this were done there would be an additional cost to the district to hire someone to do the make-up sessions outside of their regular contract, but it is an option.

Can Missouri school-based SLPs use the 3:1 model?

DESE does not specify how minutes must be documented (see compliance plan).  Many providers list “minutes per day” or “minutes per week,” but “minutes per month” could be listed.

For more information on the 3:1 model or creative options for scheduling, visit the ASHA website.  ASHA has published information on the 3:1 model in the ASHA leader and there are several publications available to ASHA members free of charge related to workload in the public schools.  If a 3:1 model is used, decide how many minutes the student needs per month to complete goals/objectives and then schedule services for 3 weeks of the month and have a week that is used for meetings, paperwork, consultation, and classroom observations. 

Example:  Student was previously scheduled for 60 minutes per week which would be 240 minutes per month.  Dividing 240 minutes per month over a 3 week time period would result in four 20 minute sessions for 3 weeks or two 40 minute sessions per week for 3 weeks.

Where can I find the SLP caseload formula?  Can I make my director of special education use the formula instead of the 40-60 students?  Does 40-60 students include the students I see as a related service?  Can SLPs use the special education teacher formula?

Information about caseload numbers and formula can be found within Regulation IX – Funding of the State Plan for Special Education (http://www.dese.state.mo.us/divspeced/stateplan/FY2004/Reg_IX.pdf  or in your districts compliance plan.  Districts/Directors of Special Education can chose to use the SLP formula or caseload size when applying for funding from DESE.  Many SLPs will submit both their caseload size and the formula to their supervisor so that a comparison of caseload to workload can be made.  The state plan specifically states that for district using the 40-60 count:  The pathologist provides direct services to 40-60 children with disabilities.  For some students in this count, the pathologist may not be the designated

case manager.”  The “All Other Special Education Caseloads” formula is not recommended for SLPs unless they are serving as a “teacher” with a population that is receiving a high number of minutes per week of speech-language services.

 

Speech Implementer Model and State Licensure Q&A

 

 

What is the issue with speech implementers and state licensure law? 

 

Speech implementers provide services under a model established by the Department of Elementary and Secondary Education (DESE).  (See www.dese.mo.gov/divspeced/Compliance/Guidance/speechimp.html  for specific details about the model.)  Speech implementers appear to function in a role very similar to speech-language pathology (SLP) assistants as described in state licensure law for speech-language pathologists (Chapter 345 of the Missouri statutes.)  Currently DESE is approving speech implementers to work in the schools without those individuals being registered as an SLP assistant as required by licensure law. 

 

Can a speech implementer register and provide services as an SLP assistant? 

 

Yes -- if they meet the SLP assistant requirements including training and supervision, an implementer can register as an SLP assistant.  However, the education and supervision requirements for an SLP assistant are substantially different from those for a speech implementer.  The SLP assistant must have a bachelor’s degree in communication disorders and one of every three therapy sessions provided by the assistant must be directly supervised by a licensed SLP.  The speech implementer may hold a bachelors degree in communication disorders or hold a teaching certificate “preferably” in special education or elementary education.  Direct supervision may be provided by either a licensed or DESE certificated SLP and the supervision is “periodic” at the school’s discretion.  It is advisable for an implementer to check with their school district to see if the level of supervision necessary for an SLP assistant can or will be available. 

 

Is there an exemption for schools in the speech-language pathology (SLP) licensure law? 

 

No -- there is no blanket exemption for individuals working in the schools.  The exemption in the licensure law is limited to individuals who hold the DESE SLP certificate and provide services while employed by the schools.  Speech implementers do not hold a DESE SLP certificate so they are not covered by this exemption. 

 

When will schools know if speech implementers must be registered and meet the requirements for SLP assistants? 

 

The Board of Healing Arts, Speech-Language Pathology and Audiology (SLP/A) Commission has been reviewing information from DESE in an attempt to determine if speech implementers should be registered and meet the requirements for SLP assistants.  As of January 2007, the Board and Commission asked the Attorney General’s office for an official opinion on the matter.  Until that opinion is available, the issue remains unresolved.  

 

If I supervise a speech implementer, is my SLP license in any jeopardy? 

 

The SLP/A Commission recently opined that RSMo. 345.025.1(6) exempts SLPs who have a DESE SLP certificate from application of chapter 345 (the entire licensure law) while they are providing services in the schools.  So even if it is eventually determined that speech implementers are practicing in violation of the licensure law by not being registered as SLP assistants, the license of the supervising SLP will not be in any jeopardy so long as they are practicing and supervising the implementer pursuant to their DESE SLP certificate as a school employee.  If an SLP supervising a speech implementer does not have a DESE certificate and is providing the supervision, as a contractor pursuant to their license, that supervising SLP may have a problem if it is determined that implementers are practicing in violation of the licensure law. 

 

Is there a problem with speech implementers becoming a fully licensed SLP? 

 

Some speech implementers with bachelor’s degrees in communication disorders have a desire to become fully licensed SLPs.  If it is determined that implementers are practicing in violation of the licensure law, it may be difficult for individuals who served as implementers to obtain their SLP licensure.  The only apparent redress is for the implementer with a bachelor’s degree in communication disorders to register as an SLP assistant, make sure their supervising SLP is licensed, and make sure the level of supervision conforms to the Board of Healing Arts requirements for SLP assistants.  Until the issue is resolved, this appears to be the only way to ensure the practice of an implementer does not violate licensure law. 

To submit a question, email Brenda Martien, VP for School Services at bmartien@mail.nixa.k12.mo.us