Understanding the Audiology & Speech-Language Pathology Interstate Compact: Development, Benefits and Limitations

Amyn Amlani
Welcome to This Week in Hearing where listeners get the latest information on all things happening in the hearing care space, from device technology to practice management, to pharmaceuticals to regulatory actions. My name is Amyn Amlani and I have the privilege of serving as your host. The ability to provide services to patients across state lines, either in person or through remote care, and without having to obtain additional licenses is becoming a reality. Through an occupational licensure compact to discuss this issue with me today are Susan Adams, Director of ASHA state legislative and regulatory affairs, and Tracy Ambrose, an audiologist at Children’s National Hospital located in Washington, DC. Thank you so much for being here.

Amyn Amlani
Well, let’s start with a little of an introduction, if you don’t mind, and I’ll start by looking on my screen here, we’ll move left to right. So Tracy, if you wouldn’t mind sharing with the audience a little bit about yourself, please?

Tracy Ambrose
Sure. Absolutely. So I became an audiologist. I graduated in 2008. I did my extern, my fellowship here at St. Jude Children’s Research Hospital in Memphis, Tennessee. And then I started my career at the Children’s Hospital right there and LeBonheur, Children’s Hospital in Memphis, and I was there for about seven years. And then I came to Children’s National in DC. And I’ve been here as a lead audiologist for again, about six, seven years now.

Amyn Amlani
Well, wonderful, wonderful. And, Susan, what about you a little bit about yourself, please.

Susan Adams
So as you mentioned, I work at ASHA and am the director of state legislative and regulatory affairs. And that basically means I review all of the legislation and regulations that come out that affect audiologists and speech language pathologists. I’m a lawyer by training, but I’m more interested in the kind of behind the scenes of creating legislation and getting legislation passed.

Amyn Amlani
Well, I tell you, right now, we’re in one of those periods where this legislation component seems to be happening quite a bit, which is exciting. But our viewers may not be up to snuff on something. So today, we’re going to talk about this thing called an interstate compact. What is that?

Susan Adams
So, in, in the most simple terms, an interstate compact is just a contract between two states to act in a certain way, it has the force of a statutory law. And it allows the states to work together to fix a problem or recognize a standard or cooperate in a public policy area, I think the most popular interstate compact that you’ve probably never heard of is the driver’s license compact. So you have a driver’s license from your home state, and you can drive anywhere in any other state. And that’s because all of those states have agreed to let you do so.

Amyn Amlani
That’s interesting. That’s interesting. So this compact now is permeating into healthcare in some form or fashion. And we’ll get into audiology and speech pathology here in just a moment. But my understanding is it already exists in some of the other occupations. Can we talk a little bit about that?

Susan Adams
Sure. I mean, we are the seventh interstate compact in the healthcare field to come out. There are nine Now there’s two more that have come ahead of us. So there’s medicine, nursing, EMF, psychology, physical therapy, advanced practice nursing, occupational therapy counselors, and then our compact for audiologists and speech language pathologists.

Amyn Amlani
Wow, that’s a there’s quite a bit and it’s it’s, it’s exciting. So for the audience, what are some of these advantages of this interstate compact?

Susan Adams
I think for our compact in general, the advantages is simply access to care, you know, getting getting audiologists, and speech language pathologists access to those underserved populations, geographically isolated populations, and then also allowing their military and military spouses to better keep up with their practice as they’re moving every two to three years.

Amyn Amlani
Let me ask you this, as I’m thinking about it, did COVID have a role in maybe accelerating this process? to any degree,

Susan Adams
I think maybe a little bit, a lot of states during COVID allowed for a lot of telehealth waivers, making it easier for people to practice across state lines. And the interstate compact is just a way to formalize that relationship that that we’ve already been kind of marching toward.

Amyn Amlani
Okay. So how are these things developed? I understand that there’s a relationship between these two states. But what actually goes into this handshake between these two different regional areas? I mean, how does that work

Susan Adams
usually takes a couple of years to get to that point, the CSG the Council of State governments has a national center for Interstate compacts, and they’ve worked with most of the compacts that are currently out there. And they had this three phase approach to creating a compact so phase one would be developmental phase. So you would conclude a

advisory group of stakeholders to come together to say is a compact right for us? What would we want it to look like? What are you know, what do we think it should have in it, they would come up with a set of recommendations that they would then hand off to our drafting team. And the drafting team would take those recommendations and kind of put it in a formalized legal document. Once that’s done, the stakeholders would look at it and make any comments to it. Once the advisory group would sign off on the compact, it would kind of go to the enactment phase or the and and the education phase. So we would educate legislators and regulators about what the compact does and how it does it. And we would get states to pass the legislation to enact the compact, once you hit your threshold of states, you would move into phase three, which is the transition and operation. So you would transition from individual states to a compact commission overseeing the compact and all of those individual member states coming together as a compact commission to make decisions on rules and bylaws, the database, you know how the compact would work from day to day. And then during this time, you’re still kind of going through the enactment phase where you want more states to join our compact had a threshold of 10 states. So once we hit 10 states, we could kind of transition to that that last phase, we currently have 15 states that have adopted the compact at this point.

Amyn Amlani
Wow. That’s amazing. That’s amazing. So let’s now dive into the interstate compact as it relates to audiology and speech language pathology. So where are we at? I know, you mentioned that we’re up to 15 states, you know, where are we at in in? what’s, what’s next for us? And then how is this going to work, so to speak

Susan Adams
our next phase is that initial contract commission meeting, and we’re scheduling that right now, we’re hoping that’s going to happen in this winter. So we’ll have 15 states attend to that meeting. There will be two members from each state one, addressing the audiologist and one addressing the speech language pathologists. So they’ll come together and take this framework of this legislation that’s been passed and say, Okay, how do we operationalize this now how do we implement it? So that’s the phase that we’re in now.

Amyn Amlani
So I know ASHA curated the the brunt of the work for this? Are there any other professional organizations that are behind the scenes that are collaborating on this on this agenda?

Susan Adams
Yeah, we’ve been working with the National Council of State boards of examiners in Speech, Language Pathology, and audiology. They’re a group of licensing represented. We’ve also been working with the Academy of Doctors of Audiology and the American Academy of Audiology, behind the scenes stakeholders to make sure that we’re including everybody in this process and being as transparent as we can.

Amyn Amlani
And then, as we’re, as you alluded to earlier, there’s it takes a little bit of time before this thing actually kicks in. I think I read somewhere we’re looking at 2022 or 2023. Before it’s, it’s enacted. And we can expect the privileges to be issued. Am I.. did I read that correctly?

Susan Adams
Yeah, I think that’s accurate. Like I said, right now we’re we’re waiting to have that first commission meeting, when the commission meets, they’re going to have to implement bylaws for the commission, how the commission itself will act, and then rules to implement the legislation that they’ve passed. Once they do all that, then we have to create a database and get all of the states to be able to talk back and forth between their licensing systems and the compact commission. Once that happens, that’s when we can start actually implementing the compact and issuing privileges to practice

Amyn Amlani
sounds like a lot more work to be done. And we’re very, very grateful for everything that you’ve done, because I again, I think this is going to really be a huge game changer in how we access or how consumers access us and how we’re able to provide some services for them. So let’s get into the requirements and the role of the audiologist. I mean, how does this compact affect how the audiologist is going to perform his or her duties?

Tracy Ambrose
from the audiologist standpoint, you know, it wouldn’t change how we perform our daily activities with our patients, it wouldn’t change how we treat our patients just to give you kind of a little idea from where I’m coming from. So in DC, you know, obviously, we were in a small area where we’re touching a bunch of different states. And so we have offices in Maryland and Virginia as well. So each one of our audiologist has to have licenses in DC, Maryland and Virginia. And so and in Virginia, we have to have two licenses because they actually have a separate hearing aid dealer dispensing license. And so each one of our audiologists has to have four licenses before they can start practicing. And so if I you know, as a manager, if someone you know, resigns or we have a new position opened, I have this huge gap in time where I’m trying to fill that position and have this person get four licenses before they can start. So it really just becomes for us a barrier to care because we don’t have that provider to to you know, be able to see the patient

But as far as we’re seeing the patients and how we’re delivering our care, there’s, there’s no difference to me if I’m licensed, you know, my home state is Maryland, or if I’m licensed in DC, and how I’m actually practicing and providing that, that care to the patient.

Amyn Amlani
So let me ask you this, because I worked in industry for a while. And when COVID hit we were looking at, at some remote care opportunities through some screeners and what have you. And we ran into a little bit of issue because of differences in state licensure, allowing for certain tests to be performed. So I’ll give you an example State A said that in order for you to consider this a diagnostic test, you have to have this this and this, and State B would be a little bit different, where you have to have a room and some other things, does the compact equalize those differences in the state regulatory differences? Or does it equalize them so that you can get a license in one state and it permeates across all the other states without having or looking at these differences that may exist in their statutory requirements? A loaded question, sorry,

Susan Adams
I think for the state, you always have to follow the law of the state where your client is located. So even through the compact, if your home state allows you to do one thing, but your remote state doesn’t allow you to do that, then you would not be able to do that in the remote state. So you would still have to follow the scope of practice in the state where your client is located.

Amyn Amlani
So that brings up an interesting point. And I’m going back to your database comment, because I’m not sure if if this will be a part of that. How does the provider then know that I’m in my home state and these other remote states that are participating as part of this compact? These guys are restrictive in doing this? And I’m able to do it in my state? How is that going to be available to the provider? Or is he or she gonna have to do that all of them

Susan Adams
I think we’ll be able to provide some of that information, generally, through the database through through the website will provide some of that information. But it really is the onus is on the practitioner to know the laws of the state where they’re practicing, which is how it is currently

Amyn Amlani
Tracy, do you run into any of those issues where you’ve got these differences in state licensure across the state, the three states that you talked about you run into any issues and differences? And how do you manage those?

Tracy Ambrose
Honestly, we really don’t, um, you know, we were pretty standard through Maryland, DC and Virginia in the services that we’re able to provide and that we’re able to build for. So we don’t have I mean, we certainly and when you you know test in each state, each state has a separate little test or exam you have to take and then sometimes when you renew your licensure in that state, you need to kind of take an updated little exam just on specific different regulations that they may have. But as far as the services that we’re able to provide were pretty, pretty equalized across across the board for at least Maryland, DC and Virginia.

Amyn Amlani
Okay. Okay. So let me ask another question here, because I’m sure this will pop into the minds of the license holders. What about continuing education? Is that going to be a part of this compact? Is that something that’s going to have to be considered so that we’re equalizing what those might be as we look at these different states, or is each state going to be different, just like the licensure laws might be?

Susan Adams
I think that’s one of the benefits of the compact and the one of the things that we really tried to focus on to make sure that we can make things as easy as possible. So the compact is based on your home state license. And that means you just have to meet the requirements of your home state license to get a privilege to practice in another state, that privilege is going to renew at the same time as your home state license. And you won’t have to meet any additional continuing education requirements for the remote states, you would just focus on maintaining your home state license doing your continuing education for your home state license. The only caveat is if a remote state has a particular piece of continuing education that they require you to do, you might have to do that. So if your home state doesn’t say that you have to do anything specific about say cerumen management, but your remote state says you need to have one continuing education credit into room and management, every renewal period, then you would just have to make sure that you do have that one continuing education credit. Otherwise, it’s all based on your home state license.

Amyn Amlani
That’s interesting. Can the remote state revoke your privileges for them? So they still stay a part of the the compact, but can they say hey, you know, we’re not sure we want you practicing in our state. Is that a situation that has occurred or that could occur?

Susan Adams
The only way that you’d be able to revoke somebody’s privilege to practice is on the basis of disciplinary action? I don’t know that any compact out there any healthcare compact out there that can arbitrarily revoke a privilege to practice?

It would have to be based on some disciplinary action.

Amyn Amlani
Let me also ask this. How will this impact students who are in

Various graduate training programs is that going to affect them in terms of the apprentice licensures that they get as as they’re being educated. And then as you supervise those students across these different states

Susan Adams
The license is based on your home state license. So it’s based on a full license. So you have to be a fully licensed audiologist to access the interstate compact. Okay. Okay.

Tracy Ambrose
And if I can speak a little bit to that, too, I think, you know, we, we always take students at a Children’s National, we have multiple at the same time, and we’re always -what we’re looking at is more of the governing bodies to make sure that the students fulfill all the requirements. So we’re really looking more towards ASHA. Because I can’t anticipate if my student is going to, you know, move to California and start practicing there. So we’re going to look more towards the governing bodies have the entire, you know, field or practice like ASHA, to give us more of those regulations for the students to make sure they have everything they need.

Amyn Amlani
That’s, that’s interesting point. Thank you. Yeah. So consumers, you know, the reason for these protections is to, for the safety of the consumer, at the end of the day, let’s talk a little bit about that, how did these compacts not only input.. impact the provider, how is it going to be a safeguard for these consumers?

Susan Adams
I think for the compact, it really extends the reach of consumer protection for right now, you know, a state can only take away that which it has given. So if it has given you a license, it can take away that license. But if you move to another state, it has no reach for you. When you’re in the compact, if you have your home state license, and you have privileges to practice in other states, if you’ve done something in another state, some disciplinary action in another state, your home state license can decide to investigate that too, because you’re part of this compact. And the privilege to practice really is a privilege. If you lose your home state license, you lose all of your privileges to practice. So it benefits audiologists and speech language pathologists to follow all of the rules and and, you know, protect the consumers, it gives the state licensing boards a lot more reach if they need it to get those bad actors.

Amyn Amlani
So let’s talk about kind of as we come to the end of this, what is other than the accessibility of the audiologist to reach more patients? Are there any other advantages to this, that you all can see, either from a practice standpoint, or from a legislative standpoint that we haven’t talked about yet?

Tracy Ambrose
I think we covered a lot of,

you know, I think the biggest for for audiologists and for providers, and is that access to care, honestly, from from my standpoint, because we want, you know, we want to make it uniformly available and and, you know, on the provider side, the expense is going to be less for getting, you know, we wouldn’t have to have three licenses for Maryland, DC and Virginia. That’s To start off, you’re looking at 800 $850, you know, there we would to become a provider, you wouldn’t have to put that expense out at first. So from the provider side, that would certainly be a nice little benefit. That would be a little bit less costly to enter into the field. But yeah, I think mostly looking from the patient standpoint, is that really access to care that we’ve discussed.

Susan Adams
Yeah, I would agree, I think it’s really the access to care, you know, facilitating that continuity of care if people are moving around, we saw a lot of that during COVID. And then like we just discussed the higher degree of consumer protection.

Amyn Amlani
Let me ask this as this just popped into my head, does the compact have anything to do with assistants in those states that allow those? So in other words, is it going to be able to make the model maybe a little more efficient, where the assistant can do some of the things that he or she is able to do given the governing body that oversees them, that then will allow the audiologist to see another patient? So we’re seeing more patients through this accessibility model. That’s, that’s absolutely wonderful and being created.

Susan Adams
So the contact does not apply to assistants. And the reason that is is because there’s no uniformity and licensure first, yeah, so we can’t create the standard, we can only take what’s already there and make it more equal. That’s what we’ve done with audiologists and speech language pathologists, because every state requires the same basic things for a license. But again, with assistannts, some states don’t license them at all. Some of them license them at a high school level, or an associate’s level or a bachelor’s level. So there’s just no uniformity there for us to work with.

Amyn Amlani
Yeah, yeah. So as we wrap up here, gonna go to final thoughts or any final thoughts that you all would love to share, or can share with the audience as they’re starting to embrace this? become educated about it, and

Hopefully utilize this in the future.

Susan Adams
For us, we’re just excited that we’re finally to this point started this project in 2017. We’re up to 15 states passing it now we’re really looking forward to 2022, where we can introduce even more states. And I would just urge, anybody who’s interested in the compact, you can go to the compact website, which is aslpcompact.com and you can reach out to us through the comp- through that website, if you want to send an email if you’re interested in learning more, or anything like that.

Amyn Amlani
Tracy, any any final words for your fellow practitioners?

Tracy Ambrose
I mean, I would just echo kind of what Susan said, you know, we’re really excited that this is kind of taking off a little bit more. And I think that, as we spoke about in the beginning, COVID has kind of highlighted some of the benefit of the telehealth and, and being able to have more of a far reach for patients and to make it a little bit easier for patients to access care, both audiologists, and speech language pathologists. So you know, I think we’re really excited as well, this is moving forward and to have this opportunity.

Amyn Amlani
Well, I really appreciate all the insights that you all have shared, it’s educational for me, and I’m sure it’ll be educational for our viewers. And I know that this is a fluid development, it’s going to continue to hopefully grow as we go from 15 states to 25, and eventually to all 50 plus the District of Columbia that will participate in this at some point and we’ll hopefully be in touch later down the road. And maybe we can get some updates as as things go on. But really appreciate your time, we’ll make sure that the website is embedded inside of the video here so those individuals can access that information online. And thank you so much for your participation and, again, wealth of knowledge that you shared with us today.

Susan Adams
Thank you so much.

Tracy Ambrose
Thank you.

Amyn Amlani
Thank you.

Transcribed by https://otter.ai