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