Virginia Regulatory Town Hall View Comments

1/31/11 1:40 pm

Commenter: Elizabeth Glover, M.Ed., CCC-SLP, University of Virginia Medical Center

regulation of endoscopy

January 27^th, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Elizabeth B. Glover, M.Ed., CCC-SLP

CommentID: 14968

1/31/11 2:14 pm

Commenter: Elizabeth Asselin, UVA Therapy Services

FEES regulations

January 31, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Elizabeth Asselin

CommentID: 14969

1/31/11 3:12 pm

Commenter: Lara Wilkinson, PT, DPT UVA Medical Center

FEES regulations

January 31^st, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. I work with SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As healthcare professionals we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We, as healthcare professionals, strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. The national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Lara Wilkinson, PT, DPT

.

CommentID: 14970

1/31/11 3:55 pm

Commenter: melissa fox, University of Virginia Health System

FEES, endoscopy regulations for SLP

January 31, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Melissa Fox, PT, DPT

CommentID: 14971

1/31/11 4:13 pm

Commenter: Dale Ding, University of Virginia

FEES regulations

January 27^th, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Dale Ding, MD

University of Virginia Department of Neurosurgery

CommentID: 14972

1/31/11 5:00 pm

Commenter: Dana Cullen, UVA Health System

FEES Regulations

January 27^th, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Dana N. Cullen, RD

CommentID: 14973

2/1/11 7:49 am

Commenter: Lora Baver, UVA Health System

FEES regulation

I believe it is extremely important to the provision of patient care to implement a specific training/certification protocol for use of FEES in clinical practice. This would give our practice defined processes for acquiring the necessary knowledge and skills to safely and effectively assess and treat our patients. Additionaly, these parameters can potentially guide research and program development , creating a standardized and systematic approach to acquring information regarding our patients.

CommentID: 14974

2/1/11 9:03 am

Commenter: Mark Evans, MS, CCC-SLP, UVA-HEALTHSOUTH Rehabilitation Hospital

FEES regulations for SLPs

February 1st, 2011

Dear Members of the Board,

I think that it is advantageous for the state of Virginia to adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy. Fiberscopic Endoscopic Evaluation of Swallowing (FEES) and endoscopic evaluation of vocal function are specialty skills provided by SLPs that require advanced training and skills. Adequate training is needed to ensure quality of patient care and safety.

The American Speech Language and Hearing Association's (ASHA) position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics. It is vital that healthcare providers only provide care in which they are competent to perform.

A FEES examination provides an option for instrumental assessment of swallowing function, that when used properly, has many benefits. It is especially useful for patients who have difficulty with transportation or positioning issues. It provides a direct view of the pharynx and larynx that is not seen in a Modified Barium Swallow study. It also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES.

I believe that regulations for endoscopy would be beneficial for patients in the state of Virginia. Virginia has the opportunity to develop regulations and guide other states to do the same. ASHA has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Including ASHA’s standards in a regulation document would further guide Virginia SLPs in the proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Mark Evans, MS, CCC-SLP

CommentID: 14975

2/1/11 11:09 am

Commenter: Heather Turner, RN UVA Medical Center

In support of regulations for endoscopy procedures

January 27^th, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Heather Turner, RN

CommentID: 14976

2/1/11 11:20 am

Commenter: Holly Hess, MS, CCC-SLP

Regulations for FEES

February 1, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. Our national organization ASHA’s position statement in 2005 states that FEES examinations are within a SLP’s scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform, seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. ASHA has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Holly Hess, MS, CCC-SLP

CommentID: 14977

2/1/11 1:26 pm

Commenter: Julie Pitti, University of Virginia Healthsystem

FEES regulations

February 1, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Julie m. Pitti

CommentID: 14981

2/1/11 3:30 pm

Commenter: Renee Bricker, Speech Pathologist UVa

Regulation for endoscopy

February 1, 2011

Dear Members of the Board,

We believe that the state of Virginia should adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy for establishment of rules for training, supervision, and practice of this service. We are practicing SLPs and health care professionals in the state of Virginia and work in a large health care system where FEES is used routinely. This skill requires advanced education and training and the importance of adequate training is needed to ensure quality of patient care and safety.

FEES is a specialty skill that involves advanced training and skills. ASHA’s position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics no matter where we practice. In health care it is vital that providers only provide care in which they are competent to perform; seeking help from other disciplines as needed. We all adhere to our own “code of ethics” to provide the best care we can for our patients.

FEES examinations are a wonderful assessment tool, that when used properly, have many advantages. They are especially useful for patients who have difficulty with transportation or positioning issues. They also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES. If an SLP could perform the examination within regulation guidelines of their specialty training, patients would benefit from the best care possible.

We strongly believe that regulations for endoscopy would be best for the state of Virginia to pursue. Virginia has the opportunity to develop regulations and guide other states to do the same. Our national organization, ASHA, has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision. Keeping ASHA’s standards in a regulation document would further guide SLPs in proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Renee Bricker MS CCC SLP

CommentID: 14983

2/2/11 12:17 am

Commenter: Carla DeLassus Gress

Proposal to regulate endoscopy by SLPs

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I strongly support and welcome the Board’s efforts to regulate the performance of endoscopic procedures by Speech-Language Pathologists (SLPs) in Virginia.

The Flexible Endoscopic Evaluation of Swallowing (FEES®)procedure[1] represents an advanced practice activity performed by SLPs. Instruction in the technique and interpretation of the FEES® protocolis generally not part of the masters’ level preparation to become an SLP, and competency must be developed through continuing education and ongoing training. There are potential risks to patients who undergo this procedure. It is therefore in the best interest of SLPs and their patients for the Board to regulate these practices to provide for optimum safety.

There are additional instrumental procedures which may be utilized by the SLP to assess functional speech, voice, and swallowing, including laryngeal stroboscopy (also performed with an endoscope), fluoroscopic evaluation of swallowing (aka modified barium swallow studies or MBS), and surface EMG (eg, VitalStim). As technology develops, there will likely be additional instrumental procedures that SLPs will utilize to optimize patient management. As is the case with FEES®, these procedures may carry potential risks to patients. Therefore, it is suggested that regulations which address the FEES® procedure be written in a generalized manner to include all instrumental procedures that a SLP may perform as an advanced practice, rather than developing regulations for each procedure individually in a piecemeal fashion in response to complaints or concerns.

Any regulations that are developed should emphasize the collaborative approach of SLPs and their physician colleagues in patient management. Some of these instruments are used by physicians to detect and diagnose medical conditions and diseases. Use of these instruments by SLPs is restricted to the assessment and treatment of speech, voice, and swallowing disorders for the purpose of SLP therapeutic intervention. SLPs are not qualified or licensed to diagnose medical conditions or diseases, and regulations should make a distinction in the use of these instruments by physicians as opposed to their use by SLPs.

In Virginia, nurse practitioners and physician assistants are “advanced practice” professionals who perform some of the same procedures as physicians, but work collaboratively and under the supervision of physicians. The VA licensure laws regulating these professions may serve as a model for developing regulations for the advanced practice of SLPs, particularly in reference to supervision requirements.

The Tennessee laws which govern the performance of endoscopic procedures (including FEES® and laryngeal stroboscopy) specify training requirements of 1) dedicated instruction (university coursework or continuing education program of 15 hours) and 2) performance of 25 supervised endoscopic procedures. However, there is no evidence that completion of these requirements will ensure competency of the SLP practitioner, and in fact, these numbers are completely arbitrary. There are a number of training models by which an SLP could develop competency in endoscopy. For example, online instruction focused primarily on exam interpretation, coupled with abbreviated hands-on training in the use of the endoscope; or computerized models which simulate manipulation of the scope paired with videotaped examples for interpretation of findings. Our regulations should not identify a particular training model as the preferred model in the absence of data to support its superiority.

The crucial issue is, of course, the competency of the SLP in performing a procedure, which includes skill in the use of the instrument and (equally if not more importantly) the interpretation of the findings. ASHA has developed peer-reviewed knowledge and skill requirements (competencies) for the performance of laryngeal stroboscopy, endoscopic evaluation of swallowing, and modified barium swallow studies, as well as a number of guidance documents regarding the use of instrumental procedures. The knowledge and skills outlined in the ASHA documents form the basis for assessing clinical competency in this specialized area of practice and provide a clear standard for training and practice. Adherence to the ASHA competencies could serve as the criteria by which judgments can be made by the Board regarding the adequacy of training.

SLPs most often collaborate with otolaryngologists in the care of patients with speech, voice and swallowing problems. However, there are other physician specialists who are knowledgeable in the anatomy and physiology of the speech, voice, and swallowing mechanisms, and are skilled in performing endoscopy. These include non-otolaryngologist head & neck surgeons, pulmonologists, radiation oncologists, and gastroenterologists. Further, board-certified otolaryngologists may specialize in various aspects of their profession, such as disorders of the sinus or cochlear implants, and have minimal expertise in the evaluation of speech, voice and swallowing disorders. While in general, a “board-certified” otolaryngologist may be the preferred specialist for supervision of SLPs performing endoscopic procedures, supervisory functions should not be limited to “board-certified otolaryngologists” (as dictated by the Tennessee document) or restricted to “otolaryngologists”. To include regulations to that effect would, in essence, restrict the practice of other qualified physician specialists who may have interest in training and supervising SLPs in endoscopic procedures. The BASLP may need to seek legal guidance regarding its ability to impose restrictions on the practice of non-ENT physicians before adopting the Tennessee document.

There are several provisions in the Tennessee document that should be incorporated into our regulations to facilitate patient care, promote MD-SLP collaboration, and ensure patient safety. These include 1) the requirement for obtaining a physician referral specific to the instrumental procedure, 2) the need to report findings to the referring physician, and 3) the necessity of a protocol for emergency medical back-up.

Many thanks for your efforts to establish a safe environment for our patients by addressing these issues. If I may be of any assistance, please do not hesitate to contact me.

Regards,

Carla DeLassus Gress, ScD, CCC-SLP

University of Virginia

Charlottesville

Home address: 3520 Rocks Mill Lane, Charlottesville, VA 22903

CarlaGress@Virginia.edu

[1]Langmore SE, Schatz K, Olsen N. Fiberoptic endoscopic examination of swallowing safety: a new procedure. Dysphagia 1988;2:216–219

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CommentID: 14984

2/2/11 12:32 pm

Commenter: Megan Ferris, UVA HealthSouth Rehabilitation Hospital

FEES Regulation

February 2nd, 2011

Dear Members of the Board,

I think that it is advantageous for the state of Virginia to adopt practice regulations for Speech Language Pathologists (SLPs) who perform endoscopy. Fiberscopic Endoscopic Evaluation of Swallowing (FEES) and endoscopic evaluation of vocal function are specialty skills provided by SLPs that require advanced training and skills. Adequate training is needed to ensure quality of patient care and safety.

The American Speech Language and Hearing Association's (ASHA) position statement in 2005 states that FEES examinations are within a SLPs scope of practice who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Furthermore, the ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As a profession we strongly adhere to our code of ethics. It is vital that healthcare providers only provide care in which they are competent to perform.

A FEES examination provides an option for instrumental assessment of swallowing function, that when used properly, has many benefits. It is especially useful for patients who have difficulty with transportation or positioning issues. It provides a direct view of the pharynx and larynx that is not seen in a Modified Barium Swallow study. It also allow for a nurse and/or doctor to be in a close vicinity of the examination and observe if possible. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there were no serious complications from SLPs performing FEES.

I believe that regulations for endoscopy would be beneficial for patients in the state of Virginia. Virginia has the opportunity to develop regulations and guide other states to do the same. ASHA has already put in place many documents that guide our profession to ensure patient safety and proper training in specialty services. Regulations would allow a Speech Language Pathologist to practice in his/her own setting and provide the best services possible while ensuring that he/she had proper training and supervision.

Including ASHA’s standards in a regulation document would further guide Virginia SLPs in the proper use of endoscopy procedures.

Thank you for your time and consideration.

Respectfully,

Megan Ferris M.A. CCC-SLP

CommentID: 14991

2/2/11 4:14 pm

Commenter: Wendy Bunting MS, CCC-SLP, Riverside Health System

Comments on FEES Regulatory Action

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Wendy Bunting MS, CCC-SLP

Director, Therapy Services

Riverside Rehabilitation Institute

Newport News, VA 23607

wendy.bunting@rivhs.com

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15000

2/2/11 4:16 pm

Commenter: Julie Scott MS, CCC-SLP, Riverside Health System

FEES Regulatory Action

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Julie Scott MS, CCC-SLP

Outpatient Coordinator

Riverside Rehabilitation Institute

CommentID: 15001

2/2/11 4:17 pm

Commenter: Ann Cyptar CCC-SLP

FEES Regulatory Action-Comments

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Ann Cyptar CCC-SLP

Riverside Health System

CommentID: 15002

2/2/11 4:19 pm

Commenter: Amanda McCall MS, CCC-SLP, Riverside Health System

Regulatory Action for FEES

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Amanda McCall MS, CCC-SLP

Riverside Health System

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15003

2/2/11 4:21 pm

Commenter: Amy Larocca MS, CCC-SLP; Riverside Health System

FEES propsosed regulatory action

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Amy Larocca MS, CCC-SLP

Riverside Health System

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15004

2/2/11 4:23 pm

Commenter: Doug Culbert, Riverside Health System

FEES comments

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as the SLP professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through the state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Doug Culbert DPT

Director, Rehab Services

Riverside Health System

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15006

2/2/11 4:26 pm

Commenter: Lisa Adams, MA, CCC-SLP, Riverside Health System

proposed regulatory action on FEES

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Lisa Adams MA, CCC-SLP

Riverside Rehabilitation Institute

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15007

2/2/11 4:29 pm

Commenter: Stacy Salvatori MS, CCC-SLP

proposed FEES regulations

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Stacy Salvatori MS, CCC-SLP

Riverside Health System

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15008

2/2/11 4:30 pm

Commenter: Alisa Hinton MA, CCC-SLP, Riverside Health System

FEES comments

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Alisa Hinton MA, CCC-SLP

Riverside Health System

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15009

2/2/11 5:27 pm

Commenter: Margot Powell MS, CCC-SLP, Riverside Health System

FEES propsosed regulatory action

Dear Ms. Knachel and Members of the Board:

The purpose of this letter is to submit comments on the Board’s planned action to establish rules for the training, supervision and practice of SLPs in the performance of fiberoptic endoscopic evaluation of swallowing (FEES). Notice was given on January 3, 2011 that the Board of Audiology and Speech-Language Pathology intended to consider amending Chapters 18 vac 30 – 20 of the Regulations of the Board of Audiology and Speech-Language Pathology. At that time, speech-language pathologists (SLPs) within Riverside Health System (RHS) began to confer and we would like to convey our views on the direction we hope that the Board will take in these matters.

Riverside Health System has had a successful FEES program in place since 2003. Policies for our program that address training, supervision and the practice of SLPs performing FEES were developed by utilizing Policy Documents from the American Speech-Language Hearing Association (ASHA). Currently, FEES are performed in 3 of our facilities: our main acute care hospital, the acute rehabilitation hospital, the long-term acute care hospital, as well as in the outpatient clinics located on those hospital campuses. Our health system FEES training is rigorous and adheres to the recommendations of ASHA. We have ten speech-language pathologists that are currently privileged to perform FEES within our health system and we have assisted in the training of many more. In the eight years that Riverside Health System has had a FEES program, an estimated 1000 procedures have been performed with no reported adverse medical events. A robust emergency-management process is in place at each facility, however, and this will be followed in the event of a medical emergency during a FEES. Our SLPs work collaboratively with physicians. They communicate the results of the procedures to allow the most appropriate patient care to take place in a timely manner, including referrals to another medical specialty when needed.

We feel our profession has the ability to self-regulate and determine best practices in this area, through the American Speech-Language and Hearing Association (ASHA). ASHA has published several documents (referenced below) that address training, supervision and safety, as well as our scope of practice. ASHA will, as our professional governing body, update those policy documents in reaction to evidence-based practice research, federal regulatory changes and patient safety concerns. We do, however, support the board in adopting regulation for FEES that references ASHA's already existing published documents. Regulation through our state licensing board will further ensure that proper criteria in performing these specialized evaluations is followed, ethical practices are maintained, and that proper care and safety is given to those that receive these services.

Thank you for your consideration related to this matter.

Sincerely,

Margot Powell MS, CCC-SLP

Riverside Health System

Applicable ASHA Policy Documents

Knowledge and Skills

American Speech-Language-Hearing Association. (2002). Knowledge and Skills

for Speech-Language Pathologists Performing Endoscopic Assessment of Swallowing Functions

[Knowledge and Skills]. Available from www.asha.org/policy.

Role of the SLP in Performance and Interpretation of Endoscopic Evaluation of Swallowing

American Speech-Language-Hearing Association. (2005). The Role of the Speech-

Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Position Statement [Position Statement]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2005). The Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Technical Report [Technical Report]. Available from www.asha.org/policy.

American Speech-Language-Hearing Association. (2004). Role of the Speech-Language Pathologist in the Performance and Interpretation of Endoscopic Evaluation of Swallowing: Guidelines [Guidelines]. Available from www.asha.org/policy.

Use of Endoscopy by SLPS

American Speech-Language-Hearing Association. (2008). Use of Endoscopy by Speech-Language Pathologists: Position Statement [Position Statement]. Available from www.asha.org/policy.

CommentID: 15011

2/2/11 11:27 pm

Commenter: Catherine Reynolds M. A. CCC-ACE-SLP, UVA Medical Center,

Requirements for practice of fiberoptic endoscopic evaluation by speech-language pathologists

February 2, 2011

Ms Knachel, Ms Yeatts and members of the Board of Audiology and Speech Language Pathology of the Commonwealth of Virginia (BASLP).

As a practicing speech language pathologist (SLP), in a large health care system, where Flexible Endoscopic Evaluation of Swallowing (FEES) is part of routine care, I agree that the licensing board for audiology and speech pathology should adopt practice regulations in order to establish guidelines for SLP training, supervision, and practice of this procedure. This skill does require advanced education and training, which are necessary to ensure quality patient care and safety. I recognize that state regulated guidelines, referencing national standards for training and education, knowledge and skills, and the ethics of providing competent care, can be an invaluable resource, for practicing clinicians, referring physicians, and also regulatory board members, in providing information to the public and patient advocates.

ASHA’s position statement of 2005 states that performance of FEES procedures is within the scope of practice for SLPs who have expertise in dysphagia and specialized training in flexible endoscopy. ASHA states that SLPs are “…qualified to use this procedure independently for the purpose of assessing swallow function and related functions of structures within the upper aerodigestive tract,” and that FEES is “…not intended to replace the fiberoptic examination of swallowing [by an MD] and/or assess the integrity of the laryngeal and pharyngeal structures in order to render a medical diagnosis.” Several states have adopted regulations and guidelines in accordance with this national standard, e.g. http://www.op.nysed.gov/prof/slpa/speechguidefiberoptic.htm

In the past two years Flexible Endoscopic Evaluation of Swallowing has become an integral part of my practice, determining safety for patients during medical recovery, providing documentation of risk for patients, families and physicians, and contributing to decision-making by the team for aggressive or, alternatively, palliative care. As I described at the BASLP meeting in August 2010, before performing FEES independently we at UVA Health System Medical Center have received 12 hours of classroom instruction, one-on-one hands-on demonstration and then supervision by a trained, competent dysphagia endoscopist for a minimum of 25 procedures initially, and continued monitoring over the first twelve months, with a further annual review of practice standards, research updates and analysis of case study imaging. This is a comprehensive program of instruction, designed by leaders in the field, and describing one avenue for developing skill and competence with performing the FEES procedure.

In our acute medical care setting FEES provides the opportunity for nurses, physicians, respiratory therapists and the code team to be in close vicinity to the SLP independently performing examination of swallowing, thus facilitating patient monitoring, and observation if indicated, often in the same areas where bronchoscopies, tracheostomies and gastrostomies are performed. SLPs across the country perform FEES in rehabilitation, nursing facilities and outpatient clinics with physicians available and emergency plans in place. Complication rates of FEES examinations in the literature are very low. Langmore and Aviv (2000, 2000) have each conducted studies with thousands of FEES examinations performed, showing there have been no serious complications during FEES performed by SLPs.

Our ASHA Code of Ethics states that all SLPs “…shall provide all services competently.” As practicing health care providers we are bound by our code of ethics to pursue education and training and to only provide services we are each individually competent to perform. Regulation and guidelines, developed by BASLP in collaboration with SLPs practicing FEES and knowledgeable with regard to current research in the field, would facilitate adherence to the code and provide for reporting and sanctioning as necessary.

I urge the Board of Audiology and Speech Language Pathology of the Commonwealth of Virginia to consider the work done nationally and in other states regarding SLP FEES practice and regulation, and to enlist the services of trained SLPs practicing FEES, in the various settings in which clients and patients are treated, in the development of regulation and guidelines for the Commonwealth of Virginia. I look forward to participating in discussions with SHAV and VSO members to this end.

Thank you for your considerate attention to this important matter.

Respectfully submitted,

Catherine M. Reynolds, M.A. CCC-ACE-SLP

Clin 3 Acute Medcial Care SLP,

Therapy Services,

University of Virginia MedicalCenter

Cr6j@Virginia.edu

CommentID: 15013

Action	Requirements for practice of fiberoptic endoscopic evaluation by speech-language pathologists
Stage	NOIRA
Comment Period	Ended on 2/2/2011