Legislative Analysis
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SPEECH-LANGUAGE PATHOLOGY TEMPORARY http://www.house.mi.gov/hfa
EDUCATIONAL LIMITED TEMPORARY LICENSE
Analysis available at
House Bill 4101 (H-2) as passed by the House http://www.legislature.mi.gov
Sponsor: Rep. Curt S. VanderWall
Committee: Health Policy
Complete to 2-23-24
(Enacted as Public Act 57 of 2024)
SUMMARY:
House Bill 4101 would amend the Public Health Code to extend, from 12 months to 24
months, the maximum period for which a temporary license for completing a supervised
postgraduate clinical experience in speech-language pathology may be issued. In addition,
the temporary license of a qualified applicant could be renewed for one additional 12-
month term. The bill would take effect 180 days after it is enacted.
Speech-language pathologists provide an array of services for individuals with
communication and swallowing difficulties, from infants in a hospital neonatal intensive
care to the elderly. To obtain a license as a speech-language pathologist, a graduate of a
master’s or doctoral program must complete 1,260 hours of supervised postgraduate
clinical experience.
The act provides for a temporary license (known as a speech-language pathology
educational limited temporary license) for the purpose of completing a supervised
postgraduate clinical experience. An individual seeking a temporary license must obtain it
before beginning that clinical experience.
To be eligible for the temporary license, the applicant must meet both of the following:
• The applicant must have a master’s or doctor of science or doctor of philosophy
degree in speech-language pathology that is acceptable to the Michigan Board of
Speech-Language Pathology and must have their academic institution transmit their
academic transcripts directly to the Department of Licensing and Regulatory
Affairs (LARA).
• The applicant must submit a plan for supervised postgraduate clinical experience
on a form approved by the board and signed by a licensed professional who will
provide supervision.
An individual who holds a speech-language pathology educational limited temporary
license cannot work without supervision. At the conclusion of the individual’s clinical
experience, their supervisor must sign and submit to LARA a report documenting the
individual’s successful completion of the clinical experience.
As noted above, the period of the temporary license is currently 12 months, which the bill
would extend to 24 months. In addition, the temporary license is currently nonrenewable.
House Fiscal Agency Page 1 of 3
The bill would allow it to be renewed for an additional 12-month term (for a total of three
years) as long as the applicant continues to be eligible as described above.
MCL 333.17609
BRIEF DISCUSSION:
Currently, the Public Health Code and R 338.613 of the Michigan Administrative Code
authorize LARA to issue a nonrenewable 12-month temporary license to an individual for
the purpose of completing the supervised postgraduate clinical experience.
However, until 2021, the administrative rule had allowed LARA to issue a two-year
educational limited license that could be renewed up to two times, providing up to six years
for individuals to complete the required postgraduate clinical experience. The educational
limited license is no longer offered, and only educational limited licenses issued before the
effective date of the rule change may be renewed for the additional two-year periods.
According to representatives of the Michigan Speech-Language-Hearing Association, the
shortened period in which to complete the 1,260 hours of supervised postgraduate clinical
experience is proving untenable for many recent graduates. Clinical experience can be
interrupted by factors outside an individual’s control, and part-time employees working
less than 24 hours a week simply cannot complete the hours in time. These constraints
could result in recent graduates being unable to obtain full licensure or incentivize
graduates to move to states with more favorable licensing requirements.
Beginning about six months after the bill is enacted, the time period an initial temporary
license is valid would be extended from 12 months to 24 months. In addition, the license
could be renewed for an additional 12 months, for a total of up to three years (instead of
one) in which to complete the supervised clinical experience. While this total is three years
less than the previous educational limited license provided, it is hoped that it would be
sufficient to accommodate circumstances requiring more than the time currently allowed
to complete the necessary hours of supervised clinical experience.
FISCAL IMPACT:
House Bill 4101 would have an indeterminate fiscal impact on the Department of Licensing
and Regulatory Affairs, as the impact would largely depend on the choices of individual
licensees. Under the provisions of the bill, some licensees would likely choose to renew
their educational limited temporary license, which currently has a lower associated fee than
the standard license. Under current law, the temporary license is valid for 12 months, but
the bill would increase this period to 24 months. The bill would also allow for a temporary
license to be renewed for a single 12-month term. It is unclear whether the department
would increase the fee to reflect this longer period. The current fee associated with a
speech-language pathologist educational limited temporary license is $102.70 for 12
months, while the total fee for a speech-language pathologist license is $183.80 for two
years. For reference, as of September 2023, there were 313 active temporary licenses.
House Fiscal Agency HB 4060 (H-2) as passed by the House Page 2 of 3
POSITIONS:
A representative of the Michigan Speech-Language-Hearing Association testified in
support of the bill. (9-28-23)
The following entities indicated support for the bill (9-28-23):
• Department of Licensing and Regulatory Affairs
• Michigan Health and Hospital Association
Legislative Analyst: Rick Yuille
Fiscal Analyst: Marcus Coffin
■ This analysis was prepared by nonpartisan House Fiscal Agency staff for use by House members in their
deliberations and does not constitute an official statement of legislative intent.
House Fiscal Agency HB 4060 (H-2) as passed by the House Page 3 of 3
Statutes affected: Substitute (H-1): 333.17609
Substitute (H-2): 333.17609
House Introduced Bill: 333.17609
As Passed by the House: 333.17609
As Passed by the Senate: 333.17609
House Concurred Bill: 333.17609
Public Act: 333.17609
House Enrolled Bill: 333.17609