The Texas Department of Licensing and Regulation (TDLR) licenses, monitors, and regulates various professions to ensure compliance with all applicable rules and regulations, including those for speech-language pathologists and audiologists. Regardless of your situation, an audiologist license defense attorney can provide valuable assistance. Our goal is to represent your interests in your proceedings before TDLR and achieve the most positive outcome possible in your case. 

TDLR has proposed changes to the rules located at 16 TAC §111 that pertain to Speech-Language Pathologists and Audiologists. The proposed changes are extensive and relate to various matters that affect and govern these professions. 

Changes to Definitions

The proposed rules amend §111.2, Definitions, by adding new terms and definitions for “ABA Certification” and “ASHA Certificate of Clinical Competence (CCC).” In this section, the names of specific supervision forms are replaced with more general terms, such as “Assistance Supervision Plan” and “Intern Supervision Plan.” The definition of “intern in audiology” is amended, and the term and definition of “extended absence” are repealed altogether. 

Changes to the Licensing Process

In §111.30, Speech-Language Pathology License, the proposed rules remove the requirement to submit a copy of the transcript from the applicant’s master’s degree. The proposed rules also clarify that a person may apply for a speech-language pathology license “only if the degree is from a college or university which has a program accredited by a national accrediting organization that is approved by the department and recognized by the United States Secretary of Education.” An additional option will also be available for applicants who have completed ASHA-approved clinical fellowship requirements. The proposed rules clarify the documents these applicants must provide for licensure. 

The proposed rules amend §111.70 and repeal and replace §111.75, which deals with the licensing process and requirements for audiology licenses. These changes align with the modifications made to the speech-language pathology licensing process. 

Changes for Speech-Language Pathology and Audiology Interns

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The proposed rules amend §§111.40, 111.41, 111.42, 111.45, and 111.47 concerning applications and eligibility requirements for speech-language pathology interns, as well as §§111.80, 111.81, 111.82, 111.85, and 111.87 for audiology interns. The proposed rules update and clarify internship and supervision requirements for interns in both professions. The specific intern supervision forms have been replaced with a general “Intern Supervision Plan.” 

Speech-language pathology interns must also accumulate internship hours under the supervision of licensed professionals in Texas. These supervisors are required to report internship hours promptly using a specific format. 

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Audiology interns would no longer be required to complete 1,600 hours of supervised clinical work under the proposed rules. Still, they would need to complete “supervised professional experience under the direction of a professionally recognized accredited doctoral program as approved by TDLR.” Furthermore, an audiology intern license would be valid for two years rather than one year and would be renewed biennially. 

Changes for Speech-Language Pathology and Audiology Assistants

The proposed rules repeal and replace §111.50, Assistant in Speech-Language Pathology License – Licensing Requirements – Educational and Clinical Observation and Experience, to supplement the current requirements and procedures for education, clinical observation, and experience. A new licensing requirement for assistants is proposed, along with degree, coursework, clinical observation, and experience requirements for that license. This section also outlines alternative paths to becoming an assistant that do not require the specified number of clinical observation and experience hours. 

Amendments to §111.51, Supervision Requirements establish an assistant supervision plan and its requirements. The proposed rules modify §111.52, Practice and Duties of Assistants, to include acting as a translator as a duty that a supervisor may give to an assistant. The rules clarify that an assistant must work only under supervision and that the supervisor must verify that the assistant is working within their scope of license. Finally, the proposed rules also amend §111.55, Application and Eligibility Requirements, to reduce form requirements and provide requirements for applicants whose transcripts are in a language other than English or whose degrees are from foreign universities. A university program director or designee must verify 25 hours of clinical observation and 25 hours of clinical assisting experience of an assistant. Any missed hours must be made up under the direct supervision of a TDLR-approved supervisor who does not currently have any license sanctions. 

The proposed rules make similar changes to the sections governing audiology assistants, including requirements for TDLR-approved supervisors. Additionally, the proposed rules reduce the minimum amount of supervision for audiology assistants from 10 hours per week to four hours per week or from 40 hours per month to 16 hours per month. At least one hour per week or four hours per month of total supervision must be under direct supervision by a TDLR-approved supervisor.

Changes to Licensee Contact Information

Licensees are no longer required to provide employment information to TDLR, but they must provide a contact telephone number and a valid email address.

What are the Internship Requirements for Interns Seeking a Speech-Language Pathology License?

Under 16 TAC §111.41, a speech-language pathology license internship requires the following: 

  • Thirty-six (36) weeks of full-time supervised professional experience (thirty-five (35) hours per week) totaling a minimum of 1,260 hours, or its part-time equivalent, of supervised professional experience in which clinical work has been accomplished in speech-language pathology;
  • Professional experience involving primarily clinical activities such as assessment, diagnosis, evaluation, screening, treatment, report writing, family/client consultation, and/or counseling related to the management process of individuals who exhibit communication disabilities;
  • Professional experience divided into three (3) segments with no fewer than thirty-six (36) clock hours of supervisory activities to include:
    • Six (6) hours of direct supervision per segment by the supervisor(s) of the intern’s client contact in which the intern provides screening, evaluation, assessment, habilitation, and rehabilitation; and
    • Six (6) hours of indirect supervision per segment with the supervisor(s), which may include correspondence, review of videos, evaluation of written reports, phone conferences with the intern, evaluations by professional colleagues; or
    • An alternative plan as approved by the department.

What are the Internship Requirements for an Audiology Intern?

Under §111.81, internships for audiology interns require the following: 

  • 1,600 hours of supervised clinical work that involve primarily clinical activities such as assessment, diagnosis, evaluation, screening, treatment, report writing, family/client consultation, and/or counseling related to the management process of individuals.

Under Texas law, what is the Distinction Between Direct Supervision and Indirect Supervision of Interns and Assistants?

16 TAC 111.2(14) defines “direct supervision” as real-time observation and guidance by the supervisor while an assistant or intern engages in client contact, clinical activity, or service. Direct supervision may be in person or via tele-supervision as authorized.

16 TAC 111.2(24) defines “indirect supervision” as occurring when a supervisor performs monitoring activities or provides guidance to the assistant or intern, excluding instances during the intern’s or assistant’s actual client contact, clinical activity, or provision of clinical services. Tele-supervision may be used for indirect supervision as authorized.

Contact Your Texas Speech-Pathologist License Defense Lawyers Today

Our experienced speech-pathologist license defense attorneys at Bertolino LLP know how to handle disciplinary proceedings before TDLR. We will advocate for you to be in the best position to maintain and safeguard your license, as well as secure your professional future. Call us at (512) 980-3751 or contact us online.

Call or text (512) 476-5757 or complete a Case Evaluation form