Does Medicare require my SLP license to be in the patient's state?

Medicare's Benefit Policy Manual defines a qualified SLP as one licensed by the state in which the individual furnishes services, and a private practice office must be in a state where you are legally authorized.

Can I bill Medicare for services my SLPA provides?

No. The Benefit Policy Manual says SLPA services are not recognized for Medicare coverage, even when the assistant is state licensed, and are denied if billed as therapy.

Can Medicare patients see an audiologist without a doctor's order?

For non-acute hearing assessments, yes, once every 12 months per beneficiary, billed with modifier AB, under the policy CMS finalized for dates of service on and after January 1, 2023.

Which form does an SLP in private practice use to enroll in Medicare?

Form CMS-855I, the individual practitioner application. Reassignment to a group is captured on the same form; CMS discontinued the separate CMS-855R.

After the License: Medicare Enrollment for SLPs and Audiologists

Getting licensed in a new state is the first half of being able to treat Medicare patients there. The second half is Medicare itself: meeting its definition of a qualified practitioner, enrolling, and billing under the right rules. They are separate systems run by separate agencies, and finishing one does not finish the other.

What follows comes from the CMS Medicare Benefit Policy Manual (chapter 15), the Medicare Program Integrity Manual (chapter 10), the CY 2023 Physician Fee Schedule final rule fact sheet and the CMS Telehealth FAQ. Your Medicare Administrative Contractor (MAC) applies these rules to your enrollment, so put any question about your specific situation to it in writing.

What makes an SLP "qualified" for Medicare?

The Benefit Policy Manual, chapter 15, section 230.3, says that effective January 1, 2015, a qualified speech-language pathologist is someone with a master's or doctoral degree in speech-language pathology who either:

"Is licensed as a speech-language pathologist by the state in which the individual furnishes such services"; or
in a state that does not license SLPs, has completed 350 clock hours of supervised clinical practicum, at least 9 months of supervised full-time SLP services after the degree, and a national examination approved by the Secretary.

In other words, Medicare looks to the license in the state where the patient is treated. The manual adds that for outpatient services billed incident to a physician or NPP, the licensure requirement does not apply but the degree requirement does.

What makes an audiologist "qualified"?

Section 80.3.1 of the same chapter, repeated in the Program Integrity Manual, defines a qualified audiologist as an individual with a master's or doctoral degree in audiology who "is licensed as an audiologist by the State in which the individual furnishes such services," with a similar fallback for states that do not license audiologists. Both manuals note that a fourth-year AuD student with a provisional state license does not qualify unless they also hold a master's or doctoral degree in audiology.

Are SLPA services covered?

No. Section 230.3 says: "Services of speech-language pathology assistants are not recognized for Medicare coverage. Services provided by speech-language pathology assistants, even if they are licensed to provide services in their states, will be considered unskilled services and denied as not reasonable and necessary if they are billed as therapy services." Aide services are not covered either, even under a therapist's supervision. Practices that use SLPAs for other payers need a separate plan for Medicare patients. See who the ASLP Compact does not cover for the licensing side.

How does an SLP in private practice enroll?

Through Form CMS-855I, the individual practitioner application. The Program Integrity Manual (chapter 10, section 10.2.3.15) sets out the requirements for an outpatient speech-language pathologist in private practice, citing 42 CFR 410.62(c):

Be legally authorized (licensed, certified or registered, if applicable) "to engage in the private practice of speech-language pathology by the state in which the individual practices," and practice within that scope.
Engage in private practice on a regular basis in a solo practice, partnership, group practice, or as an employee of one of these.
Bill Medicare only for services in the practice's own office space or the patient's home. The office must be "in the state(s) where the therapist (and practice, if applicable) is legally authorized to furnish services," and owned, leased or rented by the practice for its exclusive use. A patient's home does not include a hospital, CAH or SNF.
Treat patients of the practice, for whom the practice collects fees.

The Benefit Policy Manual (section 230.4) adds that each therapist employed by a group "should enroll as a TPP," and that in the private practice setting, services of an unenrolled therapist must be directly supervised by an enrolled therapist who is present in the office suite. Reassignment of benefits to a group is now captured on the CMS-855I itself; the manual notes the separate CMS-855R has been discontinued. For the mechanics of the application, see White Glove Credentialing's guide to enrolling in Medicare through PECOS.

How does an audiologist enroll and bill?

Audiologists also enroll individually on the CMS-855I (Program Integrity Manual section 10.2.3.2). The billing rules are different from SLPs':

Diagnostic tests. Hearing and balance assessment services are covered as "other diagnostic tests" and are payable under the Physician Fee Schedule when furnished by a qualified audiologist (Benefit Policy Manual section 80.3).
Direct access. CMS finalized a policy in the CY 2023 Physician Fee Schedule letting beneficiaries see an audiologist without a physician or practitioner order for non-acute hearing assessments, billed with modifier AB, for dates of service on and after January 1, 2023. Audiologists can bill this direct access once every 12 months per beneficiary. It does not cover assessments related to disequilibrium, hearing aids, or examinations for prescribing, fitting or changing hearing aids, and tests ordered by a physician are not affected.
No therapeutic services. Section 80.3 says there is no provision for Medicare to pay audiologists for therapeutic services such as vestibular treatment or auditory rehabilitation, and that services for hearing aid evaluation and fitting are not covered however they are billed. Treatment related to hearing may be covered under the speech-language pathology benefit when an SLP provides it.

Does a compact privilege count as a license for Medicare?

Ask your MAC before you bill under one. Medicare's definitions refer to being licensed, or for private practice SLPs, "legally authorized," by the state where services are furnished. The ASLP Compact Commission describes a privilege as "equivalent to a license," and the model law calls it "a legal authorization permitting the practice of audiology or speech-language pathology in a remote state." How your contractor records a privilege on an enrollment is a question for the contractor. Get the answer in writing. See compact privilege or a state license?

When does Medicare telehealth end for SLPs and audiologists?

The CMS Telehealth FAQ, updated February 26, 2026, says that through December 31, 2027, "an extended range of practitioners may bill for Medicare telehealth services," and that starting January 1, 2028, speech-language pathologists and audiologists, along with the other therapy professions on that list, "can no longer furnish Medicare Telehealth services." Through the end of 2027, beneficiaries can receive telehealth anywhere in the United States. Licensure still follows the patient's location throughout. See teletherapy for SLPs across state lines.

What changes when you treat Medicare patients in more than one state?

Each state's rules apply separately. Because Medicare's definitions tie qualification to the state where you furnish services, an SLP who sees patients in two states needs to be authorized in both. A private practice SLP can bill only for services in an office located in a state where the SLP and the practice are legally authorized, or in the patient's home. And because practice follows the patient, a telehealth visit with a patient in another state needs authorization in that state too. Ask your Medicare contractor how it wants your practice locations and any compact privilege reported before you submit, and keep the answers with your enrollment file.

Which order should you do things in?

Get licensed in the state where you will treat Medicare patients, or confirm a privilege is acceptable to your MAC.
Confirm your NPI and that your practice location is in a state where you are authorized.
Enroll on the CMS-855I, with reassignment to your group if you are employed.
Set up billing for your profession's rules: therapy for SLPs, diagnostic tests and the AB modifier for audiologists.
Track both renewals. A lapsed state license undermines the qualification Medicare relies on.

Medicare enrollment and payer credentialing are covered in depth at White Glove Credentialing, and contractor and billing questions at White Glove Medical Billing. White Glove ASLP handles the license underneath: License by Endorsement at $599 per state, a Full State License Application at $749 per state, and Annual Renewal and CE Compliance at $299 per license, per year. See the state license index.