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