The Myth of the Mandatory CCC

Dr. Jeanette Benigas, SLP, and Preston Lewis, MS/SLP, tackle common myths in speech-language pathology, focusing on the necessity of the CCC. They debunk the misconception that the CCC is required to bill Medicare, emphasizing that Medicare policy is federal and does not vary by state. They clarify that reinstating the CCC involves only a fee, a passing Praxis score (if needed), and professional development—no college courses or back pay. Additionally, they confirm that only two and a half states (Nevada, Delaware, and Virginia) require the CCC for initial licensure. They discuss the role of the CCC in completing AAC assessments and dispel fears that removing the CCC requirement will hinder Medicaid reimbursement efforts, sharing real-world case studies to prove otherwise. Through their discussion, they empower SLPs to challenge misinformation, advocate for transparency, and make informed decisions about their professional credentials.

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Creators & Guests

Host

Jeanette Benigas, PhD, SLP

Host of Fix SLP

Host

Preston Lewis, MS, SLP

Co-host of Fix SLP

What is Fix SLP?

Fix SLP is grassroots advocacy firm here to challenge the status quo in speech-language pathology by driving real change—from insurance regulations to removing barriers to full autonomy like the CCC. This podcast is your space to learn, engage and take action in the field of SLP. We don’t wait for change, we make it. So let’s fix SLP!
Hosted by Jeanette Benigas, PhD, SLP

Jeanette Benigas 0:00
Hey, fixers. I'm Dr Jeanette Benigas, the owner of fix SLP, a grassroots advocacy firm here to challenge the status quo in speech language pathology by driving real change from insurance regulations to removing barriers that prevent full autonomy like the CCC, this podcast is your space to learn, engage and take action in the field of speech language pathology. We don't wait for change. We make it so let's fix SLP!

Preston Lewis 0:46
Well, hello again. Fixers. Preston Lewis joining you today. Dr Jeanette Benigas, who was of course, on our intro, is with me as well. And Jeanette you and I were just joking that I think the last two or three pods, I didn't even get introduced. I just sort of repelled in to the podcast and dropped in like Skylab falling from the sky.

Jeanette Benigas 1:07
Everybody just knows who you are.

Preston Lewis 1:09
Oh, well, you know, sometimes we really piece these things together in different elements and then edit them. And so sometimes it's like many moving parts coming together. But glad to be with you this morning, and I hope you had a great Thanksgiving.

Jeanette Benigas 1:22
Yeah, we're post Thanksgiving. We're recording Thanksgiving weekend. Did you ever work retail?

Preston Lewis 1:29
Yes, oh God,

Jeanette Benigas 1:31
I don't miss those days.

Preston Lewis 1:32
Oh no. That was awful. I worked in a men's clothing store, so that was kind of fun. I mean, there was a lot of interesting clients and neat merchandise, but did not like retail.

Jeanette Benigas 1:44
I worked Old Navy, and

Preston Lewis 1:46
I can see that

Jeanette Benigas 1:47
end of high school into college, and that was awful. It was a huge store inside of the mall, and on Black Friday, the lines would go to the back of the store, we would have every single register open, and I worked the register, and you would just stand all day. It was awful. I don't miss it that. After that, the managers left in that next Christmas, after I was in college, they asked me to follow them. So then I did a brief stint of Victoria's Secret for Black Friday. I'm not doing that again. So, yeah, retail, I don't miss that at all. But anyway, we've got, we've got some things to start our episode with. Today we have a podcast review that I'll just quickly give. It's from NJ Fab Four. That person says, so insightful. And then the work that fix SLP is doing is critical to SLPs. Thank you so much for your advocacy to bring about change and transparency. Thanks, Fab Four. We appreciate those. We appreciate those five star reviews and written reviews. Not so much to like give us praise, but because what it does is it makes the show more visible. So when it's giving recommendations, it's more likely to pool ours, and that's what we need, because we reach SLPs in many different ways. Not everybody accesses our content the same way that you do, and so having this podcast is one of those avenues, and if we can reach more SLPs in that manner, that would be awesome, because not all SLPs are on social media, and we're always thinking about, how do we reach the SLPs who aren't on social media? And right now, this is one of the only ways we have to do that. So it's really important that this podcast continues to get out there so more people know about the work that we're doing and can start making important changes in their state.

Preston Lewis 3:50
Hear, hear. So today we are myth busting.

Jeanette Benigas 3:56
Yeah, so we're myth busting. We have already done a deep dive into a lot of the topics we're going to talk about today, but we continue to see this misinformation spread on social media, so obviously we need to keep saying these things, put the content out in different ways, so you all can share it and just keep Talking about it until it's part of our vocabulary, just like we now see people saying the CCC is not a license. We see that often on social media. It is now part of our vocabulary as a group of clinicians, but some of these other things are not so we're taking a little spin on the old show, Myth Busters. We're going to do a series of posts this week that are myth busting some of these myths, but Preston and I are going to discuss each of them in this episode briefly. Just give our thoughts, and you'll get more information throughout the week.

Preston Lewis 5:00
And when it comes to myth busting, it is, it's something that you have to be just constantly vigilant about. And as I've said, we've had just decades, and now generations of sort of indoctrination, kind of thinking when it comes to our profession, and some of the things that are necessary and maybe are not necessary, ways that we could advocate for ourselves, rather than that paternalistic attitude. But, I mean, I run into these myths all the time. In an email this week with one of our state teams, I got that myth. Well, actually, I'll save this one. But they come just like down, like cockroaches everywhere. So you have to have a cockroach policy, you know, you've got to or like termites, I suppose, where you have to just take these things and just stop them with your foot. And so, yeah, that's, that's kind of what we're up to today. Is, let's go ahead and say them, because you as an SLP are going to go out. And if you talk about something different in your profession, if you talk about fixed SLP, you will encounter these myths. So let's dive into it.

Jeanette Benigas 5:58
yeah, okay. The first one is that you need the CCC to bill Medicare and Medicaid. This is one of those ones on Mythbusters. They say, is it plausible, confirmed or busted? And in this case, it's both busted and plausible. So we'll go with busted first, let's deal with Medicare. Medicare is the big one. First of all, Medicare is a federal policy. It doesn't change by state, it doesn't change by jurisdiction. It doesn't change by setting it is one policy. So if a beneficiary is receiving Medicare, this policy applies in every single setting across the US and DC, you do not need the CCC to bill Medicare. What Medicare says is to qualify as a provider under Medicare, SLPs must meet 111, big, bold, one of the following. Hold the CCC in speech language pathology or meet the educational and clinical requirements for the CCC, including being in the process of completing the supervised experience. That's what it says. That's what CMS says. And yet, clinicians all across this country insist that we have to have the CCC to bill Medicare.

Preston Lewis 7:50
So getting into some of the weeds of Medicare, Jeanette, there are those Medicare administrative contractors, and some of you may have heard those. They're called Max. I think there are seven of them. I believe in the United States, there may be a couple more than that, but I think there are about seven. They will put forth policy manuals for their individual regions, which are kind of squarely looking if you've ever seen a map of how they're laid out. In the United States, there are these LCDs that will specify sort of minimum requirements that a speech language pathologist has. And they do mention, as you said, that there are requirements that are similar to the requirements for a CCC, but they do not get into specifically saying that you have to have a certificate. We've done a lot of checking on that. And so I think in the past, when people have bumped into this and they see those requirements, they think, Oh, well, that's the CCC. N o, it's not.

Jeanette Benigas 8:46
Yeah, you're referring to the local coverage determination.

Preston Lewis 8:50
Thank you.

Jeanette Benigas 8:51
Are there times where people are being asked to provide the CCC during credentialing? Certainly, yeah, there are certainly times where clinicians are being asked to provide their action number for credentialing, push back. Push back. That's either them not knowing any better, or being lazy because they don't want to collect the information that shows you met the educational and clinical requirements for the CCC. We ran into this up in Michigan, didn't we? Preston with their yes Cross Blue Shield Medicare Advantage plan was asking for the ASHA number at credentialing. It wasn't in their policy. It was part of the checklist that the people on the phone or the people reviewing the applications had to go through, it was still on the checklist. We tried for months and months and months and months and months to get a hold of them to work through this. It took months. We finally. It got a little bit creative and figured out some other ways, perhaps, to reach them. And so we filed a CMS complaint. And wouldn't, you know, within, I don't know, a week and a half, we heard from Blue Cross, Blue Shield, and it was changed in a week. The complaint said this isn't required per Medicare, and yet they're requiring it. How is this okay? And they changed it, and they were also able to see in their system, they called it a legacy policy. They said, Oh, this must be a legacy policy. We can see in the system that this was supposed to change in 2011 when this Michigan State License went active, and so it changed in their policy, but it didn't change on the credentialing checklist. That's what had to be changed. So all they did was make a new checklist.

Preston Lewis 10:53
Well, in fairness to insurance companies and sometimes state policy were all guilty, including these people, of sometimes doing a copy and paste. And in many cases, like you said, there was a time before state licensure where they had to have something to use as a metric. But that exists. And so when you're like you just said, Jeanette, when you're working in the field, and somebody says, We need to have your Asha card every year. It's incumbent upon you to ask why show me, and that sometimes can make people uncomfortable, and you can think that you'll get a reputation of being contrary if you want to go ahead and just submit it absolutely. But there are those times where some things are just not necessary. And I found in some instances, companies kind of appreciate less paperwork sometimes Jeanette, so you could be doing them a favor as well.

Jeanette Benigas 11:53
So we kind of have a call to action with this one. You won't see it in our post because we ran out of tiles, but if you are a private practice owner. Stop submitting the CCC for credentialing for your employees and see what happens. We have state teams who are already doing this. There are several private practice owners on some of our state teams, and as they hire new grads or new clinicians, and they're working on credentialing for their practice, they aren't submitting that stuff, and we have yet to get a denial letter. We have yet to get any kind of documentation from anywhere, and this is private insurance too, that the ASHA number is needed, and when we get that, we will go after it. Preston goes after those things like a bull in a china shop.

Preston Lewis 12:47
I'm ready. Bring me denial letters I want...

Jeanette Benigas 12:49
Mmm-hmm, but we have to have that stuff in order to take action. And all this is doing is confirming that what we are saying, in addition to providing you the regulations, what we're saying is true. People are practicing all over the US without the CCC and billing Medicare, and in some states there are recently, we did get a private insurance that it's in the contract, and I think it's going to be something we can very easily address, but we can't do it unless we have it in writing, so saying, oh, many private insurances, or you need it for Medicare. No, you don't, and you don't, until you show us that paperwork, it's not true. It's just a myth that is being said over and over and over again or in the paperwork, it has the or, and you haven't paid attention to that. You just read number one and went with it. And one more comment that I will make, because I have gone hard with some private practice owners. I'm sorry you get to do whatever you want with your private practice if you're going to be the person who digs in and says, I will never hire a clinician without the CCC, cool, go, be that person, but you're going to be on the wrong side of history pretty quick here. I have gotten into it with private practice owners before, who say, well, that number two is meant for CFS, okay, who are who are you again, that you know better, that you know the Medicare regulations. There are people again, all over the US, billing Medicare, without the CCC, they mention the nine month supervised experience in number two, it says, including being in the process of completing the supervised experience, including it's not the only part of the point it was or meet the educational and clinical requirements for the CCC, including someone in their nine month experience.

Preston Lewis 14:49
So particularly for private insurance, Jeanette, that gets into sort of a conflict of interest, if you will, for one private company to mandate. State a purchase of some other third party entities, certificates. That's that's delicate, especially when you have state licensure absent that that's a different matter. However, we have 50 states now with licenses, all speaking of, you know, states. How about the word reinstatement? Are you ready to discuss that?

Jeanette Benigas 15:22
Yeah. Myth number two, reinstatement. We thought we explained this pretty well a couple weeks ago, and yet we see people continuing to insist that you have to take college courses to reinstate the CCC if anything has changed, or pay back pay from all of the years that your your CCC wasn't active. Even under the post that we made, the content that we made, people were still asking and saying these things.

Preston Lewis 15:58
For some of them, it's not necessarily spreading myth. But, I mean, it's a fear for a lot of them, and so they want to discuss their fears. So let's, let's dive into that. Let's put them on the sofa and talk Jeanette.

Jeanette Benigas 16:11
For the people in the back, one more time. You do not have to take additional college courses to reinstate the CCC will circle to that in a second to reinstate the CCC, you also do not have to pay years of back pay to reinstate the CCC. You can go to ashes website and confirm that there are three things you have to do, pay a fee provide a passing practice score, if it's been more than five years since you passed the Praxis and submit up to 30 hours of professional development, that's it. Could these things have been required in the past? Sure, sure. What gets me is that when someone is asking on social media, because, like Preston said, they have these fears. Should I do it? Should I let it go? Should I shouldn't I? Because that's the big conversation right now. As people are making these decisions, as the end of the year approaches, we have people who maybe did have real life experiences where those things did happen in the past, but they aren't a requirement anymore. And so when people respond to well meaning clinicians really trying to explore what's going on, and someone jumps in and says, Oh, it's not worth it. Don't ever let your CCC go. You'll have to go back to school. I had to do it, and it was awful. Okay? That was your lived experience, but that is not the requirement now. So stop making people afraid. We are existing in a profession that is full of fear. We got a mini van meltdown this week where someone gave it to us anonymously, didn't even put their name in and then sent us an email that said, Please don't share it on your podcast. I wanted that communication just for you all, because that person is so afraid for their voice to even be out there in the ethos that we live in this profession of fear, and we are never going to be able to move forward if we keep scaring the hell out of each other. And I'm not afraid to call people out either, right Preston?

Preston Lewis 18:35
No, no! Very clearly.

Jeanette Benigas 18:38
I'm going to be blunt if I see people doing that on social media, I will say very clearly, this is misinformation. Here's the truth. I got into it. You might even see some of this this week. We haven't made it yet, but I got into it with someone because I called her out. She shared misinformation about reinstatement, perpetuated a spirit of fear with her statement, and I made a comment that said, this is misinformation and gave the truth, and she was so bothered by it that she took the time to argue with me in Messenger and call me a troll because I was an awful colleague for calling her out. Well, maybe you're an awful colleague for trying to scare the poor original poster who was asking a question and you gave misinformation. The person deserved to know the truth to make an educated and informed decision, and the only way to stop this is by calling out misinformation and telling the truth.

Preston Lewis 19:42
I think I would advocate also that there is a difference between trolling and, I think, being a very spirited person to try to set the record straight. And that's what I see, is that when you encounter these things, they're very frustrating, like I said earlier. I mean, we feel like we need a termite policy. Need to kill all these myths, because they just pop up everywhere. So Jeanette, are you a little bit vigilant about it? Perhaps? Are you spirited about it? Most definitely, however, that's the thing. If you are part of that, and you've We've all made mistakes, and we've all said things that we believe to be true at one time, and turns out, maybe we weren't there. Have a conversation with us if, you know, if we jump in and you know we've got a differing point of view, let's, let's discuss that. Give us fact. You know, if you've gotten a denial letter on something, or if you had to do something the last year, tell us something, but don't come at it with just an attitude of, well, I'm, you know, how dare you come at me? You're trolling me. No, we're just trying to have a conversation that goes beyond some of these old tales and this fear that's been out there, because it's been crippling and it's paralyzed us for some time.

Jeanette Benigas 20:54
Yeah, and so before we move on to the next myth, I said we'd circle back to reinstatement. There is a difference between a new application and a reinstatement, a reinstatement, and this isn't super clear in the ASHA policy. It says one year. So I would advise anyone so this is new grads and CFS, if you are going to purchase that CCC and and discontinue holding it later. Make sure that you have held it for 365 days, because you don't want Asha to find a loophole. Hold it for one year, 365 days, if you let it go after 365 on day 366, if you don't renew, then you are in the reinstatement category, and the reinstatement category includes those three things that I've already said. A new application means you've never held the CCC, or, from what I can tell, you held it less than a year, and new applicants are held to the standard at the time of application, not at the time of graduation. So if you graduated 15 years ago, the standards have changed several times. So when you apply, you are held to today's standard, which means you might have to go take some college courses, and they change stupid crap that doesn't even reflect you as a competent clinician. It's like biology to chemistry or life science to like psychology. I mean, the stuff that they change is dumb. It's not even SLP related coursework. Typically, if you go back a whole bunch of months to march 19, was when I dropped this episode The CCC dilemma, making informed decisions as students and CFS. That's up there in our top probably seven podcast episodes of all time. I recorded it specifically for you new grads, for you students who are still in school, to help you with the decision making process. And it's why I say in that episode, at least, I think I say you're probably wise to apply for the CCC at least once, because that puts you into the reinstatement category. And it just kind of saves you down the road. If you find a job that's going to require it, or you decide for whatever reason that you want to have it, then you're not facing college courses. So right now, because we aren't in an atmosphere yet where we're full of jobs that don't require the CCC, everybody's supportive. We don't live in that space yet. It's coming, hopefully in less than 10 years. We live there, but we don't live there right now. And so getting it once probably advisable. After that, it's reinstatement. So all of these, I had to redo my CF. I had to take classes. Those people probably never held the CCC in the first place. Maybe they held it for less than a year. We don't know their stories, but it's not a thing now. And so with that, I will say with reinstatement, as we have looked at the progression over the last 30 years, ASHA has only made the requirements for reinstatement easier, not harder. And I can guarantee you, as we plug along with this movement, it may get even easier, because so many people are going to let this thing go that they're going to be dying to recoup their money, and they're going to find a way to get that money to entice people to reinstate and send them their bucks so they can get their money. Might be five years out, but it's probably coming when enough of us let this thing go. It's coming because they're going to need money. So it will eventually likely get easier. It's never. Gotten harder.

Preston Lewis 25:01
Last week, I bumped into Arkansas SLP that I haven't seen in many years. And they asked me, they said, what's this thing, this podcast, thing, fixing that you're doing? And I explained it a bit more, and immediately I got this look of just like wonder that came over this SLP space. And they said, but don't I have to have a CCC to get my Arkansas State license. And I buried my hands or my head just in my hands, and I thought, oh, here we go. Which leads us to that myth, how many states are there Jeanette, that really require a certificate of clinical competence for state licensure. And I always like it we have, like, a half number there. I'm going to let you explain.

Jeanette Benigas 25:54
We've been saying one and a half and Preston. I think you and I can probably agree at this point that it's two and a half. Yes, we've not self corrected yet. I think we've sort of just been waiting to see how it plays out. So probably at the end of January, beginning of February, we will officially update our map, because there's, there's no reason to update anything right now until we're sure on on how we see this one state play out. But the one and a half we've been saying is Nevada and Nevada, everyone needs the CCC at the time they apply for state licensure. After that, you can let it go. It's just initial licensure in the state that you have to have the CCC for everyone, every SLP in Virginia, you need it if you are not practicing in the schools again for initial licensure only after that, you can let it go. So there's our one and a half Delaware is our third state, so this makes it two and a half. We are incorrect. It is not marked on our map, but Preston and I feel now that we've been deep in this enough that you have to have your CCC for initial licensure in Delaware, and then you can let it go. That could change from the time of this recording in two months. Less than two months, they are meeting. If you want to hear a Delaware story, we're not talking about it again on this episode, go look in our content. Go look at fix slp.com, or listen to the last couple podcasts you will hear what's going on in Delaware. So I think we can safely say at this point it's two and a half states where you have to have the CCC at the time of initial application, and after that you can let it go. Currently, there is no state in the United States, nor DC, where you have to have the CCC on an ongoing basis to hold a state license.

Preston Lewis 28:10
And it's been that way now for over a decade. I would have guess, since Colorado went online state license eight years this is not something that just happened in the last 18 months,

Jeanette Benigas 28:23
and we have to ask ourselves, why didn't Asha go away at that point? Why didn't they concede and that was the time for Asha to come forward and make a big deal about it. All of our states have a state license. This is a big deal. Why didn't they do that? Because what that says is we are less relevant. We're gonna hold on to collecting your money for this. CCC, as long as we possibly can. They never expected fix. SLP, to come out of the woodwork and call their shit out. But guess what? It happened. Here we are.

Preston Lewis 28:59
I have that image. You know, you painted it very beautifully with words. But I sort of think about the movie Annie, and the play Annie, when they're singing Easy Street, especially that Tim Curry version, you know, and they're, they're jumping up and down with the money because they're so excited about what's about to fall down on them. And, yeah, that, you know, it was easy street, you know, it's got to keep this, gotta keep this myth going. This is, this is a very profitable myth.

Jeanette Benigas 29:38
You just got my heart Preston, because little known fact, the 1983 version of Annie...

Preston Lewis 29:47
That's it.

Jeanette Benigas 29:48
It's it. I mean, it is my favorite movie, and I know it hasn't really aged well in some aspects. Certainly, it is my dream. I'm a theater kid. It my dream going growing up was to be Annie, and it never happened. There was never a production. And plus, I didn't have the I can sing, but I don't have the the stage voice for for musical theater. I've certainly held quite a number of roles, leading roles, in just plays, but never musical theater. I've always been supporting roles. Oh man, I just wanted to be Annie. And I'll tell you what, in college, I was probably 21 maybe 22 I was the youth pastor at my church, and one of the girls in my youth group got the role of Annie. I'm gonna tear up now. This is like 25 years later, and I went and saw her, and I got her flowers, and I just cried. I just cried the whole time she was living my dream. So if anyone needs an adult Annie, I am available for hire, or I'll just do it for free, please for adoption. Anyway.

Preston Lewis 30:59
All right. I'm gonna go back in time to a young Preston in the SLP world. And I can remember being told early on, oh, you've got to get the CE registry. You just have to. That's just one of those things that just, yeah, just do it. Make sure you do that. That'd be great. I never did it. I just maybe one year. I think my employer paid for it, and then I thought, oh, I can keep my own records. I think I'm different than a lot of people, but there's that thought out there that this is just part of the membership, and that it's kind of what you do. And of course, if you look at that invoice, it's easy to think that Jeanette, let's bust this myth.

Jeanette Benigas 31:40
You don't need the ashes. CE, registry, you don't now listen, fix SLP has been around now 14 months. Fix SLP has also brought me to the point of realizing that I have a very, very severe ADHD, I am now medicated and doing better, but that registry saved me. I'm not gonna lie. I used to have such a hard time keeping track, especially back in the day when everything was on paper, keeping track of those certificates, keeping track of the hours. I tried to have a file. It just didn't work for me. And I always say this on social media. Look, I can fix SLP in my sleep. I can blow up Michigan Medicare and lead 20 state teams and do and have a family and a husband and do all these things, but I cannot keep track of PDH. I don't, I don't know what it is. So do you have to have it? No. Do we recognize there are two different groups of people, people like Preston, who absolutely can do it on their own and should because it's easy, or people like me who are not, for lack of a better word, stupid, we can achieve many great things, but for whatever reason, we just can't track the PDH, for the people like us, speechtherapypd.com, now has a tracker that is free to everyone. This is not sponsored. It is not an ad. Truly. We are putting it out there because it is a useful tool that they set up for any speech pathologist who wants to use it. You do not have to buy their product. You go to their website, you create an account, and you get going, and it's going to be the closest thing you can get to that paid tracker without paying to set the system up for automation so you don't have to have it, and you shouldn't stop paying for it. You want an award? You want to we will send you the fixer ace award. I keep joking about it. We're going to put Elizabeth, our content coordinator, all over that. Elizabeth, if you're listening, we need a certificate.

Preston Lewis 34:00
Are you ready to discuss AAC?

Jeanette Benigas 34:02
Oh boy, Preston, we go...

Preston Lewis 34:05
I feel like I need to gift you some brass knuckles for Christmas. On this one.

Jeanette Benigas 34:09
We go way back. So AAC was one of the first things that I personally took on as a fearless leader, because at the time, 14 months ago, these companies were asking for the CCC. They were requiring your action number to set up accounts. They were requiring your action number to use their free products online. They were collecting your action number, regardless of payer source for billing. It was just required. And I spent a lot of time on the phone with these companies, lawyers with these companies. Representatives with these companies, sales reps advocating on our behalf, explaining why they shouldn't be doing this. And when my mom got sick with breast cancer, I kind of had to let that fall by the wayside, and then everything changed in fixed SLP, and I haven't been able to circle back. There is an open invitation for me to meet with someone from Tobii DynaVox that I will eventually circle back to. But at this point, it's not our biggest fish to fry, because it has been addressed enough to the point where we can confidently say that for the big players, the big companies in the field, you do not have to have your CCC, and I'm specifically talking about Prentche Romich and Tobii Dynavox. You don't have to. In fact, a couple months ago, I ordered a device for an adult, and I said to my rep from PRC, I said, you know, I'm not giving you my Asha information, right? And she's like, I expected nothing less. I said, let me know if there's a problem and there wasn't. And she said, you know, we actually have someone putting one through for Medicaid right now too, without the CCC. She said, I'll let you know if there's a problem and there wasn't. So at this point we believe, and if this is not what you are experiencing, please let us know we believe. At this point, these companies are allowing you to create accounts. They are allowing you to submit devices without the CCC. There are some exceptions in these states where Medicaid is required. If Medicaid requires it in a state, you're going to have to submit it, and at this point, we are pretty transparent on what states those are. In fact, our map is showing more states require it than do because we've made big changes this year. At the time of this recording, Elizabeth is getting that map up to date for us. One of our posts this week will have an updated map so you can see what states require the CCC for Medicaid billing, and we have teams in a good handful of these states who are now taking this on. And what we're finding even in one of these states, it's not even in the regulation, sort of like in Arkansas and North Carolina, it's part of the credentialing paperwork, even though it's not in the regulation. And we have found that that is very easy to change. So I can confidently say by this time next year, more of these states will be knocked out because we're simply just dealing with paperwork, not legislation and regulation and those big things this is simple, like make an attestation form like you have in North Carolina, change it like you did in in Arkansas. That's what we're looking at in some of these states. And so in that case, you know, if you have to have your CCC, you'll submit it, or if you don't, they'll ask for it. But for it to be a requirement across the board that, for the most part, has gone away. If you're still having trouble, please email us. I have a file. I'm keeping this stuff. I get the emails. I move it to the AAC file, and someday, I promise I will circle back and bring this thing home. But because we've made enough movement to where it is generally fixed, I haven't done much. I want to call something out, though that is very concerning to me, and we're gonna tag Tobii DynaVox on this stuff. When I started this, they weren't addressing this issue at all. Now, thankfully, they do have a spot on their website under the funding tab that you can click that addresses the CCC, right. They're trying to contribute to addressing this problem. However, point number one under General Information says, What is a certificate of clinical competence? The American Speech Language Hearing Association Asha defines the CCC certificate, as the CCC SLP demonstrates to patients, employers and organizations that you are committed beyond the basic requirements for state licensure in the field of SLP. Point number two, why is a certificate of clinical competence needed right there? Why is it needed? Excuse me, the certification of clinical competence is designed to ensure that recipients can independently practice and provide high quality clinical services to patients. Yes, those two paragraphs right there better come off, because it's an FTC violation period. Asha is regulated by the FTC. Tobii DynaVox is regulated by the FTC. They are breaking the law by having those statements on their website. Tobii DynaVox, I'm calling you out right now. FTC guidelines on misleading claims. Here we go, straight from their website. The FTC Act prohibits unfair or deceptive acts or practices in commerce. A claim is considered deceptive if it misleads consumers acting reasonably under the circumstances and is material to their decision making. Let's analyze that statement for a second. Do they imply superiority? Absolutely, they're suggesting that holding the CCC demonstrates a commitment beyond the basic requirements of state licensure, which we all know now are not true, except in two states, Hawaii and North Dakota, we're calling you out. Get it together. Are they misleading consumer perception? Absolutely. If patients, employers or organizations are interpreting the statement to mean the CCC holder provides superior care compared to those of us without the CCC that can influence hiring, that can influence who they're choosing to care for them, it's potentially disadvantaging qualified professionals. These are concerns that stuff has to come down, tag them, and if it's still on the ASHA website, don't, don't, don't. Get me started. Preston, I need to drink.

Preston Lewis 41:53
No, that's okay. Would you like me tend bar? Quite alright. And no, I think that that first line that they had where they defer to, you know, Ash's definition, that's fine. But then when you start imparting different meanings of something, and you make subjective judgments about a certificate without a basis of fact on it, then that's where it becomes problematic, and whether you have liked the spirit of it, it's a bit much to advertise another product. When you are trying to you yourself, sell a product, it gets into conflict of interest, and that's why those FTC regulations exist. It prevents, sometimes too cozy of a business relationship.

Jeanette Benigas 42:45
Yeah, because we all know we can be just as competent, or more competent, without the CCC, I think that's a myth we busted a long time ago, right?

Preston Lewis 42:56
I think anybody who doubts that needs to go meet Dr. Humbert.

Jeanette Benigas 43:00
Yeah, so it's it's time we see that. We're glad that Tobii DynaVox has started to address this formally on their website, but we still need to see some changes there absolutely. So let's talk Medicaid real quick. Sure. Do you need the CCC to bill Medicaid? This is one of those ones where in the in the post, we say, confirmed, busted, or what's the other word, plausible. It's plausible that you need the CCC to bill Medicaid, but only in eight situations, right Preston>

Preston Lewis 43:37
Yeah, we've narrowed it down quite a bit. Within the last year, we've reduced that number by like two or three?

Jeanette Benigas 43:45
Three.

Preston Lewis 43:45
Three. it is the case where there are a few states that are out there. I would question, in some of those states, if denial letters are actually being sent out, could be a policy that needed updating, as in the case of Arkansas, and so indeed, some places have just been doing things on a copy and paste basis the way they've always been done. There are a few out there that we still have to work on. That's why we have state teams. But, you know, we're looking at now, I guess, 38 jurisdictions, if you include DC, perhaps, where it's not the case, we're going to get to 50 or 51 if you include dc, we will get there, but it is not as ubiquitous as some SLPs would have you believe.

Jeanette Benigas 44:36
Very specifically, Arkansas or North Carolina, there are people practicing now without the CCC, billing Medicaid. I know our team has identified in North Carolina, there are still many, many people who do not know that that change occurred. But if you're practicing in one of those states, you can bill Medicaid without the CCC now, there are people doing it. Michigan. I think that's just changing. So until November 1, people did have to have the CCC to bill Medicaid. Also, interestingly, in both Michigan and North Carolina, there are additional updates, removing the ASHA language from their manuals, which is huge. These are things that our teams have been working on that they're they're seeing come to fruition. And it's very exciting when you've been walking beside people trying to make change, and then seeing their efforts just flourish. And it just shows that there's power here. There's power in this movement. You don't have to have experience. You don't have to have 20 of you. These things are happening with teams of two, four, one. Doesn't take a lot of people.

Preston Lewis 45:54
Well, I want to bust another myth, because

Jeanette Benigas 45:55
Do it!

Preston Lewis 45:56
this week. I and I, we've talked, we've discussed this one before, and this week, trying to put together a team in Nevada, I encountered this, and my blood just ran cold, and I hadn't heard it in about two months, and it was, well, any effort to claw back the CCC in our state, I've been told, will hurt us in our efforts to increase Medicaid reimbursements within our state, and I just recoil at that. First of all, it's assuming that politicians and bureaucratic boards are going to be punitive in the category of not allowing for increased reimbursements because of a policy change. These are two entirely separate things. Believe me, there is no one out there that's going to say, well, we changed that policy, so To hell with you. We're not going to increase your reimbursements. You know, your patients can just go pound sand. That doesn't work that way, and I understand that that is out there in the mythville. And if you're spreading that rumor, stop. If you are the person who created that myth, there is a special place in hell for you. Because first of all, you were saying something that is not rooted in fact, you were spreading fear and likely for profiteering purposes, for someone else, stop it. It's insulting, and it assumes that our profession can't walk and chew gum at the same time, and that everyone out there is going to be punitive to the point of the not allowing for reimbursements to say that, well, you know, you poisoned us because you asked to modernize your profession. Give me a break. I'm just, I'm really tired of that one, Jeanette, it's, it assumes I think that we're just a certain degree of stupid.

Jeanette Benigas 47:58
Yeah, and we have case studies. I have two case studies. I'll share that help to further debunk this myth. Case Study one in Ohio, there is no mention of Asha, no mention of the CCC, no mention of any membership body, anywhere in our regulations, and this last year, Medicaid reimbursement went up. So it's not you have to have one to get the other, so that we know that Medicaid will increase reimbursements if you aren't publicly claiming these things in your regulations. Number two, the day that Medicaid in Michigan announced that they were discontinuing the requirement of the CCC, I believe was also the same day they announced rate increases, reimbursement increases. Am I wrong there?

Preston Lewis 49:00
no that was that went down that way.

Jeanette Benigas 49:03
Yeah. So both, both happened, if anything, I think it works to our advantage, because if legislators, if policy makers, if administration in Medicare, have their eyes on our stuff already, they're probably more likely to make all of those changes all at once because they're paying attention than they are to again, to be punitive, right? They're paying attention to our profession. Let's fix a whole bunch of stuff and help these people out and increase access to care and pay our providers more, all at the same time. It just makes sense.

Preston Lewis 49:41
It's more voices in the choir. It's more feedback to the public stakeholders to say, wow, I've got a lot of SLPs that are contacting me, and it's not just the same lobbyist from a state organization that contacts me every year and says, Hey, sure. Love to have a bigger reimbursement this year. No, I've got a dozen SLPs that are barking at me about changing a regulation, but also reimbursements, and these people are on my ass. So yes, we are stronger together. And there's a bit of an irony that I think I ran into that, you know, we're hurting reimbursement efforts, particularly in Nevada, where the CCC is intertwined. So, you know, tightly within their state licensure process, yet, you know, it's a good it is an argument, I think, for Nevada to say, well, you know, I don't know how aggressive we might be about reimbursements, because you allow SLPs in your state to not have a master's degree, in some cases, in the public school. And so, Gee, thanks a lot there. I thought that the purpose of the CCC was to, you know, increase this gold standard and mean something more. But in the case of Nevada, if you've got several SLPs in the schools that are practicing without a master's what the hell it seems very, you know, there's a lot of mental gymnastics that goes into that argument. So no, I we are not here to hurt reimbursements. If anything, we would love to pick up that mantle and run with our state organizations. That's why we're promoting them. That's why we want to give them more resources. So we're all in this together. And for anybody that wants to turn that lie around on us, to create a wedge, you know what? I'm just I have no time for you. Go off and wander into the desert and get lost.

Jeanette Benigas 51:33
Boom.

Preston Lewis 51:34
Yeah.

Jeanette Benigas 51:36
Alright, I think that's it for this week.

Preston Lewis 51:40
We all right, we will reconvene next week.

Jeanette Benigas 51:44
Yeah, we keep circling. We've got our topics, but like this, Myth Busters week came out of nowhere, and here we are. So we're heading towards Asha finances, which is a hot, hot topic for our fixers. I know those are our posts that go viral. You guys. Every time we talk about money in a post, the crowd goes wild. We've got our hands on their tax forms. Elizabeth is our resident money person and content coordinator. I think we're going to ask her to come on the pod a little bit too. That's coming.

Preston Lewis 52:20
We may get Gordon Ramsay as well, because we've got to discuss that elite catering bill. So we're bringing in some chefs and some people knowledgeable in the culinary arts and so that that could be coming. And isn't convention happening next week?

Jeanette Benigas 52:37
It is. Yeah, we are going to be having a few guests post convention that would have some things they'd like to say that we said to both of them, why don't we wait until after convention? So you can add some commentary there as well. So that will also be coming, and we're just going to ride to the end of the year here with money talk, I think probably starting next week.

Preston Lewis 53:00
Anybody wants to call from the convention and call the hotline number, please. It'll be a great week to do that too.

Jeanette Benigas 53:07
Yes, I'll get that up on the website

Preston Lewis 53:11
Right? Anybody? Yeah, and don't be fearful, you know, go, you go back to your hotel room, you know. But if you are fearful, it's okay. You can whisper into the phone you can, you know, just be really quiet, hush voices. That's okay, too. But yeah, give us a call. Let us know how it is. I already heard that the parking I already heard, excuse me, that Arkansas and me coming out there. I already heard that the parking is like 60 plus dollars a day at some of these hotels there in the SeaTac area for the convention. So, yeah, good luck. Let us know. You know, send us, send us some shock bills, and we'll discuss finances very soon.

Jeanette Benigas 53:49
Yeah, a lot of people, not a lot. I've, I've gotten quite a few messages and emails asking if there's going to be a fixed SLP meetup at convention. You guys, if we showed up at that convention, you would cancel us. You think we're doing that? No, we are not. We are not. No one on this team is going to Asha. More power to you if you're going we love you anyway. This is about choice. But we couldn't justify all of us. Most of us live in Ohio, Michigan, Illinois. We couldn't justify taking time off work, paying for that trip out of our own pockets, to not even get any PDH but just to go for a meet up, or, you know, use fixer money for that. We were never going to use sustaining partner money to do something like that. So we're all staying home. We'll take your voice messages.

Preston Lewis 54:41
Frankly, we're too damn busy.

Jeanette Benigas 54:45
That too. All right. Preston, I think that's it. We gotta go. Thanks fixing it everybody!

Transcribed by https://otter.ai