Student Services Certificate Update
Withdrawal of Certification Requirements for Initial Student Services Certificate
On November 30, 2016, MSHA and ASHA submitted comments to DESE in regards to the proposed change in the SLP Student Services Certificate. Both of those statements are posted on the MSHA website.
Sharon Sowder, MSHA President, Beth McKerlie, MSHA President-Elect, and Diane Golden, MO-CASE, attended the MACCE meeting in Jefferson City on December 5, 2016. Information was provided to the attendees about the history of the certificate, the rationale for proposed phasing out of the certificate through elimination of the initial certificate and alternatives for reestablishing an SLP DESE certificate that is supplemental to the license. There was a robust discussion among all the meeting attendees which included the MACCE committee members and representatives from DESE, NEA and MSTA.
A motion was made and carried that a recommendation be made to the State Board of Education to consider extending the proposed implementation date for ending issuance of the initial certificate until August 1, 2018, to provide districts with plenty of lead time to address any issues at a local level. The recommendation will be presented at the State Board of Education meeting in January, 2017, as well as a summary of statements that were submitted during the open comment period in November. The final decision will be made by the State Board of Education.
During the comment period, some SLPs recommended that a DESE SLP certificate should be reestablished with its own set of coursework and practicum requirements that would be independent of the SLP license. MSHA will be reaching out to critical stakeholders, especially higher education faculty who would be responsible for delivering such required coursework and practicum, to further gauge the level of interest in this concept.
ASHA has issued a comment letter to DESE. The full letter may be read by clicking here.
The MSHA Executive Board has issued a comment letter to DESE that states the following:
MSHA recommends further discussion among stakeholders and postponement of the proposed implementation date.
MSHA recommends exploration of the development of an optional credential for graduate students or school based working practitioners interested in advancement.
The full letter may be read by clicking here.
Watch the Student Services Certificate Webinar presented by Sharon Sowder, Beth McKerlie and Diane Cordry-Golden.
MSHA will present a complimentary webinar to address the many questions regarding the Student Services Certificate.
The webinar will be held on Monday, November 28, 2016, at 7:00 PM CST.
Please submit questions and issues you would like to be addressed in the webinar to the MSHA Office at firstname.lastname@example.org by the end of business November 21, 2016.
The subject line should read Question for SLP Certificate Webinar. Please include your name, phone number and email address with your question, should we need to contact you for clarification. Your identity will remain anonymous for purposes of the webinar.
Attendance is limited to the first 100 participants. The webinar will be recorded and available for playback on November 29, 2016. (Visit MSHA website after November 28 to receive details on how to watch recorded webinar.)
- Sharon Sowder, MSHA President
- Beth McKerlie, MSHA President-Elect
- Diane Cordry-Golden, Policy Coordinator, Missouri Council of Administrators of Special Education
This webinar is not eligible for CEUs.
We have continued to learn more information this week as it relates to the recent proposed rule impacting the Initial Student Services Certificate. The message below is lengthy, but it contains many details specifically related to current certifications and retirement questions.
Proposed Rule Change to Eliminate SLP Student Services Certificate
The November 1 Missouri Register includes a proposed rule change that would eliminate the SLP Initial Student Services Certificate. This proposed rule change will delete the following text from the current rules effective August 1, 2017:
[(F) The Initial Student Services Certificate for Speech-Language Pathologist (Birth - Grade 12), valid for a period of four (4) years from the effective date of the certificate, will be issued to those persons meeting the following requirements:
7. Professional Requirements-A. Possession of a master's or higher degree in Speech-Language Pathology from an accredited college or university; and B. Possession of a valid, unencumbered, undisciplined Missouri license in Speech-Language Pathology from the Missouri Board of Registration for the Healing Arts.]
If this amendment is adopted as final rule, Speech-Language Pathologists (SLPs) will no longer need to apply for nor be able to obtain an initial Student Services Certificate as they begin work in the schools. New SLPs will work under their state license issued by the Board of Healing Arts just as other professionals do such as nurses, clinical psychologists, social workers, OTs, PTs, etc. Those SLPs who already hold a DESE SLP credential (the Student Services Certificate or previous SLP certificates such as the Speech-Language Specialist certificate) will continue to hold/renew that credential. While the proposed rule does not have an effective data identified, the action approved by the State Board has a proposed effective date of August 1, 2017 which will be included in the final rule.
This proposed change is the end result of a long evolution of the DESE SLP credential. There was a DESE SLP teaching certificate before there was a state SLP license and for decades the two credentials were separate and distinct. However, about 15 years ago a decision was made to issue the DESE credential based only on holding a valid Missouri SLP license issued by the Board of Healing Arts. Over time, holding a valid state SLP license became the only way to obtain the DESE SLP credential and the DESE SLP certificate became a credential with no substance. DESE currently has little to no ability to discipline or manage the SLP credential as it has no real content of its own. It is simply issued as a "tag along" to a valid license.
Newly hired SLPs working under their state license will be part of the PEERS retirement system rather than PSRS. Since many SLPs work in employment settings outside of public schools at some time in their career, the PEERS retirement system (as a social security supplemental system) may be a better fit for them. School staff and administrators responsible for personnel in districts who employ SLPs should proactively consider how to ensure appropriate and equitable salary schedules are available for SLPs in their district when some will have a DESE credential and others will not. It is important to remember that currently districts likely have SLPs with a variety of different credentials, DESE, Board of Healing Arts and ASHA.
Stakeholders are encouraged to submit comments that include clear recommendations to address concerns (e.g., if the desire is to keep a DESE credential then how should a credential be established that is actually issued by and controlled by DESE?) Districts might also want to make comments on the proposed effective date of August 1, 2017. Will that provide sufficient lead time to ensure all personnel policy adjustments can be understood and implemented effectively? Comments are due by November 30, 2016, and can be submitted by email to email@example.com.
Here's a short Q & A responding to questions already asked about the proposed change.
1. It appears the language of the proposed amendment will only affect Initial Student Services Certificates for SLPs. If so, does that mean SLPs who already have an Initial Student Services Certificate will still be able to upgrade to a Career Continuous Certificate?
Answer: Correct, this change only ends issuance of the Initial SLP Student Services certificate. Existing certificates will be eligible to move to the Career Continuous and other prior existing certificates (old Speech-Language Specialists and even Speech Correction) will still be valid.
2. If SLPs have already been contributing to PSRS and have earned years in PSRS toward retirement, will they be allowed to stay within the PSRS system as full members (no social security) instead of switching mid-career to PEERS?
Answer: Yes, clarification has been issued by PSRS working with the Missouri Social Security Administrator that affirms SLPs with a DESE credential who are working one of the two common core data codes for SLPs (usually 195500) will continue to be eligible to remain in PSRS as a full member (no social security). See below for full text of PSRS clarification.
3. Will SLPs who have and maintain Student Services Certificates remain eligible for tenure?
Answer: Nothing will change for those SLPs who hold the DESE credential and yes, they will continue to be covered by tenure provisions. New SLP hires without the DESE credential will not be eligible for teacher tenure.
4. If SLPs wish to serve districts in other capacities (e.g., Special Education Process Coordinator), will they still be considered appropriately certificated? As of now, the requirement to be a Special Education Process Coordinator is to hold "Any Special Ed certificate with Graduate Degree."
Answer: The requirements for a Process Coordinator are established by the Office of Special Education via State Plan. Discussions are underway to revise that requirement so that SLPs and perhaps even OT's or other related services providers who do not hold a DESE credential can serve in the position of "process coordinator". Unfortunately, the SLP Student Services Certificate was never accepted as a "teaching certificate" to satisfy the requirements of many administrative certificates (including sped administrator). Currently an SLP who wants an administrative certificate has to get some other teaching certificate to be eligible for an administrative credential and that will continue to be the case for new SLPs also.
5. Can all SLPs stay on a teacher salary schedule, even those without the DESE credential?
Answer: Salary schedule decisions are made at a district level. Some districts have SLPs on a teacher salary schedule now and others do not. Some districts have separate "therapist" salary schedules, others do not. These are all decisions made at a local level and thus all options are available to use at district discretion. The critical issue would seem to be to ensure that any salary schedule applied to SLPs are equitable based on credible differences in position responsibilities and not simply holding the DESE SLP credential or not, especially since the DESE SLP credential has had no substance of its own for many years.
Full text from PSRS clarification as referred to in Question #2 above:
From PSRS -DESE is proposing that it discontinue issuing new SLP certificates as of August 1, 2017. According to DESE, if a member already has a SLP certificate, he or she may continue to renew the SLP certificate. The member would continue to be certificated and would remain in PSRS as long as the member continues to hold and renew the SLP certificate.
If the member continues to renew his or her SLP certificate and remains in his or her current position (according to the DESE position code; e.g., DESE position code 195500), the proposed rule change should have no effect on the member. The member will remain in PSRS as long as the member renews his or her SLP certificate. Also, according to DESE, the proposed rule as written should not have an effect on the member's current position or DESE position code. So, according to the State Social Security Administrator, the proposed rule change should not require any current PSRS member to be considered a 2/3 PSRS member and participate in Social Security.
There may be members with SLP certificates who are currently in PSRS 2/3 positions and who participate in Social Security. This proposed rule change should have no effect on those members. They would remain as 2/3 PSRS members and continue to participate in Social Security as long as they continue to renew their SLP certificates.
Of course, a member could change from a full PSRS position to a PSRS 2/3 position (or vice versa), but that change would be due to moving to a different position and not due to the proposed rule change.
Finally, if the proposed rule is enacted as written, it may be possible for new district employees to be hired into a position that previously required an SLP certificate (e.g., DESE position code 195500). If that person does not have any DESE certificate, he or she would be a member of PEERS due to lack of a DESE issued certificate regardless of the position in which the person is employed.
Again, this is a proposed DESE rule change that could be further amended or withdrawn. The proposed rule change is in the comment period for the remainder of November.
You can find the proposed rule at 5 CSR 20-400.640: page 1540 at this link:
You do have through November 30 to submit comments to Mr. Paul Katnick at firstname.lastname@example.org.
If you have additional questions, you may continue to contact Sharon Sowder, President, Beth McKerlie, President-Elect or Pat Jones, Vice President for School Services.
Sharon, Beth and Pat
MSHA Response to Questions Regarding the Student Services Certificate
Beth McKerlie, President-Elect, Pat Jones, Vice President of School Services, and I are working diligently to communicate the proposed change in the Student Services Certificate. We have reviewed the information provided by DESE, and with the help of Diane Golden (MO-CASE), we will be providing as much information that we can to the MSHA members regarding this proposed change. This information will be disseminated to the MSHA membership via listserv, the MSHA website and the MSHA Facebook page. You may continue to contact Beth, Pat, or me with any questions or concerns that you have. MSHA, as an organization, will not be submitting an opinion to Paul Katnik at DESE, however, we are encouraging our members to let your voice be heard and contact Mr. Katnik by email at email@example.com.
Questions that we feel we are not qualified or equipped to answer regarding your individual retirement choices and options will need to be answered by your specific human resources departments as well as PSRS/PEERS. Multiple conversations have been occurring between DESE and PSRS and hopefully there will be clarification issued shortly to address the conflicting information that has been circulating. However, we have no control over when this will be provided.
MSHA was not involved in the process of this proposed change. This is a proposed rule change that was approved by the State Board of Education based on the recommendation of the Missouri Advisory Council of Certification of Educators (MACCE) which is the advisory body for all DESE issued credentials. MACCE made the recommendation because the Speech-Language Pathology Student Services Certificate over time became nothing but a “tag along” credential, e.g. the speech-language pathology license is the controlling credential. DESE currently has little to no ability to discipline or manage the SLP credential as it has no real content of its own and is simply issued so long as there is a valid license. The options to resolve this situation are either to stop issuing the Initial SLP Student Services Certificate and move to universal licensure over time as proposed, or return to a stand-alone DESE SLP credential with its own specific education requirements that is distinct and separate from licensure. The latter option would be a significant change for university SLP preparation programs and students.
You do have until November 30 to submit comments to the above mentioned email. After the comment period has closed, DESE will review all of the comments and make a recommendation to the State Board of Education about how to proceed. Nothing will be final as of November 30. DESE could propose changes to the current proposed rules and/or could ask for additional comments. This is not a legislative issue (the legislature is not in session now), nor is it an issue to employ a lobbyist. It is a proposed rule change made by the State Board of Education to solicit comments and we encourage you to take advantage of that opportunity.
While there are clearly issues that need official, written clarification, nothing in this proposed change was intended to change anything about retirement for those SLPs already holding any of the many different DESE SLP certificates. They will continue to be reported the same in core data course code and will continue to be in PSRS without paying into social security (SS). The SLP Student Services Certificate will continue to exist and be renewed for years to come. What has been unclear so far is how the new SLPs, working under only their license, will be reported in core data. No matter how they are reported, these new SLPs will be in PEERS, not a pro-rated PSRS with SS, because they do not hold a DESE credential. Hopefully something written will be provided soon from an "official" source that will clarify all of the retirement system issues.
There is some false information that appears to have come from a post on Facebook and perhaps even from some HR offices saying that SLPs with a DESE credential will be forced out of “full” PSRS (no SS) into the prorated PSRS with SS. Based on multiple conversations with PSRS and DESE that is not an accurate or an official interpretation, and those agencies are working to provide clarification in writing. We encourage our members to not jump to conclusions without clarification from official sources. Please watch the MSHA website, listserv and the MSHA Facebook page for updated information. The MSHA Executive Board is doing everything we can in regards to notifying our members and university personnel about this proposed change and provide accurate updates.
You can find the proposed rule at 5 CSR 20-400.640: page 1540 at this link:
Sharon Sowder, MA, CCC-SLP, President
Missouri Speech Language Hearing Association
Page last updated
February 1, 2017