Opinion No. (2006)

BILL LOCKYER Attorney General DANIEL G. STONE Deputy Attorney General THE DEPARTMENT OF HEALTH SERVICES has requested an opinion on the following question: Does a state services credential with specialization in clinical or rehabilitative services issued by the California Commission on Teacher Credentialing qualify the holder as a "speech pathologist" under federal standards governing Medicaid reimbursement? CONCLUSION A state services credential with specialization in clinical or rehabilitative services issued by the California Commission on Teacher Credentialing does not qualify the holder as a "speech pathologist" under federal standards governing Medicaid reimbursement. ANALYSIS We are asked to determine whether certain eligibility requirements for federal Medicaid reimbursement pertaining to professional qualifications of speech and language therapists ( 42 C.F.R. § 440.110 (c)(2) (2006); hereafter "Regulation 440.110") may be deemed satisfied if a person performing clinical or rehabilitative services in the state's school system has complied with the requirements imposed by the state for a state services credential with specialization in clinical or rehabilitative…