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.
