We respectfully ask that the San Diego Regional Center reconsider their current policy that RPE (Required Professional Experience)/Clinical Fellow Speech-Language Pathologists may not provide early intervention home visits under code 116.  In addition to the information provided in this letter, we submit for your review a letter from the Director of the School of Speech-Language and Hearing Science at San Diego State.

 

Per Jeannette W. Reiff, M.S., CCC-SLP, the Associate Director, Clinical Issues in Speech-Language Pathology at the American Speech Hearing Association, “ASHA's Scope of Practice in Speech-Language Pathology identifies early intervention to be within the scope of practice for an SLP, and thus an SLP Clinical Fellow, as we work with individuals across the life span.”

 

The California Speech-Language Pathology & Audiology & Hearing Aid Dispenser’s Board does not exclude required professional experience (RPE) temporary license/Clinical Fellows from providing early intervention services.  

 

The California Department of Developmental Services Vendorization guidelines do not exclude SLP clinical fellows from providing early intervention services.  Neighboring county regional centers including the Inland Regional Center, Regional Center of Orange County, Harbor Regional Center, and Eastern Los Angeles Regional Center, just to name a few, all allow clinical fellows to provide early intervention.

 

First, it is important to clarify some of the terminologies, the RPE and CF are the same.  Clinical Fellow is an American Speech Hearing Association term and it refers to the 1260 hours that must be obtained to receive the clinical certificate of competence (CCC).  RPE refers to the California Speech-Language & Audiology & Hearing Aid Dispenser’s Board's required professional experience to obtain a permanent license after completing the 1260 hours.

 

RPE/CFs are not the same as SLPAs.  RPE/CFs have obtained a master’s degree versus SLPAs who have obtained an associate’s degree.  RPE/CFs have completed 400 supervised hours whereas SLPAs have completed 100 hours.  RPE/CFs are only required to be supervised for 18 of their 1,260 RPE hours, that’s 1%, whereas SLPAs are expected to have 20% direct supervision weekly for their first 90 days and then direct supervision every 2 months.  Due to their higher level of education and clinical training, RPE/CFs can administer feeding screenings, discharge clients, modify plans of care, make referrals, select AAC devices, and provide services to medically fragile children, whereas SLPAs cannot.

 

We also would like to point out that the San Diego Regional Center allows ABA Technicians (also known as Registered Behavior Technicians) to provide early intervention home visits.  RBTs are only required to have a high school diploma and complete 40 hours of training, versus an RPE/CF with a Master’s degree and 400 clinical hours, that is simply unfair.  

 

Per the San Diego Regional Center Board of Director Meeting Minutes, November 8, 2022, Wendy Forkas, representing the Vendor Advisory Committee, reported “that staffing shortages are causing significant challenges for vendors, not just in San Diego, but throughout the state. Waiting lists continue to grow for services.”  Vendors need to recruit newly trained SLP clinicians to the field of early intervention, however, new graduates who are interested in early intervention are seeking employment with schools, clinics, and private practices because they cannot receive RPE/CF placements in San Diego.  

 

We appreciate the San Diego Regional Center’s thoughtful reconsideration of this policy and request a written response.