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I was wondering if you could provide me any information about the use of an oto-tech in an ENT setting. They are considered an otolaryngologist assistant that is able to perform hearing tests and other tests. Do they have to be licensed through the state? Are there any state requirements for an oto-tech to follow or is it just at the doctor’s discretion? We’ve been looking for clarification and haven’t been able to find anything pertaining to oto-techs and was hoping you would have some information for us.
After consulting with a current member of the PA license board, it was determined that this topic was discussed at the last license board meeting. If the tech or assistant is operating under a physician, then that oto-tech does not need to be registered with the license board. However, if the oto-tech is operating under an audiologist, then (s)he must be registered with the license board, just like an SLP assistant has to be.
Could you direct us to PA mandates/regulations regarding hearing screens for school aged children as well as needed audiological visits for deaf and h-o-h school aged children. Also if there are different ones for private vs public schools. Thanks so much.
I was forwarded your questions concerning hearing screenings in PA schools. I am attaching the Guidelines for the School Hearing Screening Program for Pennsylvania's School Age Population that the PA Dept of Education puts out. In PA, school nurses perform the public school screenings and they use a very different protocol from the protocol established by ASHA. I think the guidelines will answer most of your questions (as well as those regarding referrals).
As far as an answer about the public versus private schools, I am not sure if private schools have to abide by these PA Dept of Education guidelines. I looked in the Table of Contents for the Guidelines, but did not see anything addressing private schools. My son is in a private school (Kindergarten) and they do not provide hearing screenings, but I would not be comfortable saying that ALL private schools do the same thing. You may be able to find an answer to that on the PA Dept of Education (PDE) website.
I work in an outpatient hospital clinic and recently it came up that we were treating a child with apraxia that had a Dr. script that said “speech delay”. The patient’s insurance would not pay for the speech delay diagnosis and the SLP then indicated, following assessment, that the diagnosis is apraxia. The hospital billing dept. would not allow the patient’s bill to be changed with the SLP’s diagnosis. They wanted the Dr. to write another script that indicted the diagnosis to be apraxia before they would change the bill.
According to ASHA, a speech pathologist is autonomous and can diagnose and treat patients without physician supervision. According to section 5 of the Pa. draft licensure bill it states that a SLP can not provide medical or surgical services or diagnosis to patients as this is considered unethical.
Do we have the ability and is it ethical for the SLP to “clarify” with a more specific diagnosis, an initial Physician script, without having the physician write a 2nd script in order to bill the insurance company?
Thanks for your question. Speech-Language Pathologists do have the ability to provide a diagnosis code, as long as the code is within our scope of practice, without a pre-written script from the physician with a specific diagnosis code.
As far as the outpatient practice of SLP is concerned, including Video Fluoroscopic Swallow Studies, what practitioners are legally allowed to write a prescription for SLP? We know that MD’s and DO’s are, but can SLP’s work under the prescription of a Nurse Practitioner or Physician’s Assistant? I have checked the practice act and cannot find any language regarding prescriptions for SLP, and I have contacted the State Board but have not heard back. We know that in the hospital and in skilled nursing/rehab/LTC facilities NP’s and PA’s are allowed to prescribe, but has it ever been stated that the same is the case on a strictly outpatient basis? If someone could respond as quickly as possible, I would really appreciate it, as we are having an issue with one of our GI practices. Thank you for your assistance.
Thank you for your question about prescriptions for speech therapy. The answer is not a simple one unfortunately. No prescription is required for speech therapy services unless you are billing it to a third party payer. In this case, I’m certain that is the root of your question. Whether or not you can accept a RX from a nurse practitioner or a physician’s assistant depends on the place you are billing it to. If you are billing it to Medicare, you need to follow Medicare guidelines. Medicaid has different rules and regulations in different states and with different programs. For example, in PA there are Health Choices managed care programs for Medicaid may have different rules for who writes the RX. The same goes for private insurance companies.
I would suggest you look at the rules for the insurers you are using and follow the most stringent of those guidelines. That way, you will be covered in the worst case scenario. Mark Kander at ASHA may be able to help you with specific Medicare guidelines as their website is difficult to navigate. Most private insurers have websites that can provide you with a direction.
Hello.
I came across the link below. Could you please let me know if this is the most up-to-date info/policy on missed therapy sessions in Pennsylvania schools? If it isn’t , where could I find the new regulations. Thanks!
http://www.asha.org/uploadedFiles/advocacy/federal/idea/IDEAIssBrfMissedServices.pdf
There are NO written regulations or policies in Pennsylvania regarding making up missed sessions for an IEP student.
Our answer is based on PSHA board member experiences and knowledge, and as such, does not equate to a particular entity’s policy. It is always advisable to check with your employer regarding their required policies and procedures.
As you know, the IEP is a legal document produced by a team of people, including the parents. The IEP team determines and writes the amount of service time into the document, and this must be provided as stated in the document. All members of the IEP team must agree to the service time, which must be satisfied or the school entity (LEA) is out of compliance.
Some school based agencies have been writing service time in the following way:
30 (30 min) sessions per IEP year, which roughly equates to once per week.
60 (30 min) sessions per IEP year, which roughly equates to twice per week.
Writing service time in this manner allows for flexibility in providing makeup sessions.
The important point in the ASHA document that you referenced is that the IEP team makes the decision about impact of missed sessions on FAPE for each individual student. Therefore, there should NOT be a missed session policy generalized for all.
I would like to know how Pennsylvania defines "caseload". After years of
adhering to the number 65 as the number of students "seen" for Speech and
Language Support, our school district supervisor has chosen to interpret the
Standard as 65 students for which we are "case manager" (speech and
language is the primary disability). Any student we have in therapy who has
a primary disability of Learning Disability, MR, or Autism (speech is
secondary disability); those students do not count as part of our 65
students. If we ever had 65 students we were case manager for, we could have
another 30 students we are secondary. Apparently a call was made to PDE and
they verified that it is interpreted differently. I'm having difficulty
understanding how this could be. Would you please give me your
understanding of the regulations?
Thank you for your question. The Pa. SEAL is correct. The maximum number of students on an itinerant (speech and language support is considered itinerant) caseload in Pennsylvania is 65.
I am providing a summary of the Chapter 14 guidelines that govern special education regulations in Pa. I got this nice summary from an educational law firm, referenced at the top of the attachment. Chapter 14 is the regulation guideline for Pa. that interprets the federal legislation Individuals with Disabilities Education Act (IDEA).
Many moons ago, Pa. guidelines for speech in the schools had a maximum of 90 contacts per week for the SLPs. That may have been a more reasonable way to look at caseload, as you could have 90 time slots on your schedule filled with less than 65 students, because perhaps you scheduled students more than once per week.
Now, you could have up to 65 students on your caseload, and see them multiple times per week, and they still count for only 1 student each.
It is important for you to know that 65 is the maximum number. If a SLP in a Pa. school district carries more than 65 on their caseload, they may be out of compliance with Chapter 14 regulations. Note MAY BE. The school district has the option to request higher or lower numbers from the state as they prepare their special education plan. It might be interesting for you to review the current special education plan of the district that you work for to see if the maximum caseload number of 65 for an itinerant provider is stated.
Could you tell me if PSHA is involved, or has been involved, in trying to get the recommended caseload size reduced for school SLPs in PA? I would be very interested in helping with such efforts so that students get quality speech therapy. I believe that 65 students or more, plus Tier III students, results in fast burn out for SLPs.
When the Pennsylvania Chapter 14 regulations were up for renewal and amendment (1993, 1998, 2000), PSHA followed the proceedings with great interest. We urged our membership to state their opinions to the Pa. Department of Education, and many did. We were not successful in changing the caseload numbers in these regulations.
The Chapter 14 regulations state that Itinerant special educators can have a maximum of 65 students on their caseload. SLPs are considered Itinerant. The regulations do not recognize that multiple contacts of the 65 students could result in a large contact number per week of these 65 students. That is one of the areas of concern for the practicing SLP in our Pa. schools.
PSHA has also followed the national trend to look at workload rather than caseload size. When looking at this model, a student's contact time needs are identified as workload for that student. Thus, paperwork time, teacher and family consultation time, Medical Access billing time, and other aspects of the workload for the student are recognized as part of the accounting of time for each student. It seems to be a more equitable way to determine and track how much time is actually necessary for the development of a quality program for each student.
School districts and Intermediate Units are required to submit a Special Education Plan to the PDE. The local entity can request a different caseload size for SLPs within that Special Education Plan. PSHA believes that it is necessary for a smaller caseload number to be requested by the local school district, based on the workload and time constraints of the work week for their SLP staff.
It is my understanding that not all states have laws saying what the maximum number of students should be for a speech therapist in the public school setting. I am wondering if there is a maximum for the state of Pennsylvania? I found on this website http://www.speechville.com/advocacy-depot/caseloads-state.html that the limit in PA is 65 students on a caseload. I am unsure however if this is a valid source and was wondering if you would have the correct information?
Thank you for your question. The Pa. SEAL is correct. The maximum number of students on an itinerant (speech and language support is considered itinerant) caseload in Pennsylvania is 65.
I am providing a summary of the Chapter 14 guidelines that govern special education regulations in Pa. I got this nice summary from an educational law firm, referenced at the top of the attachment. Chapter 14 is the regulation guideline for Pa. that interprets the federal legislation Individuals with Disabilities Education Act (IDEA).
Many moons ago, Pa. guidelines for speech in the schools had a maximum of 90 contacts per week for the SLPs. That may have been a more reasonable way to look at caseload, as you could have 90 time slots on your schedule filled with less than 65 students, because perhaps you scheduled students more than once per week.
Now, you could have up to 65 students on your caseload, and see them multiple times per week, and they still count for only 1 student each.
It is important for you to know that 65 is the maximum number. If a SLP in a Pa. school district carries more than 65 on their caseload, they may be out of compliance with Chapter 14 regulations. Note MAY BE. The school district has the option to request higher or lower numbers from the state as they prepare their special education plan. It might be interesting for you to review the current special education plan of the district that you work for to see if the maximum caseload number of 65 for an itinerant provider is stated.
Where can I find information regarding school speech-language pathologists being able to treat feeding/swallowing disorders in the school setting?
Click here for Guidelines from ASHA. ASHA has many other documents on their website regarding this topic. Another suggestion is to read IDEA documents that outline responsibilities regarding nutrition and safe eating in order for students to access their curriculum.
We're struggling at my office to find caseload limits for school-based SLP's, primarily for those in 3-5 services. Does a law exist? Do you have any input or any direction to point me in? Our work is a mix of center and community-based.
Unfortunately, there are no laws in the Commonwealth of PA which govern caseload sizes for the 3-5 year old clients, especially in a privately held organization such as yours. If you worked directly for a school district, the school district may set caseload limits but currently, that is up to their discretion.
Certainly you should look to your supervisor for direction for what is a reasonable caseload size for a clinician to handle and still achieve the intended outcome for the child.
I work in a public school system in PA. I am a certified, licensed SLP. One of our SLPs is going on extended leave at the beginning of next school year and my special ed supervisor wants to know if it's ok to have an instructional assistant with an undergraduate degree in developmental communication take over the SLP caseload at that school. I do not believe she even has a teaching certificate in the state. Please direct me to where I can find some information so I can respond to his question!
In Pennsylvania, this could be an option as the Pa. Department of Education allows for emergency certification. Your Human Resources Director could assist your district with this application. The instructional assistant should have a Bachelor’s degree in Communication Disorders to get this emergency certification, and would have to substantiate that with an official transcript. This person could work for more than one year under the emergency certification, and there are some requirements for continuing education units during that time.
I queried the Executive Board of PSHA regarding your question and their responses all indicated that PSHA is not in favor of this option. We believe the scope and practice of school based SLPs require full credentials, and we support universal licensure of all SLPs in our state in order to ensure that. We believe that in school practice in our state, highly qualified SLPs are important for the best service to the children, teachers and families, and to ensure legal compliance regarding IDEA.
What are the requirements for becoming a SLPA in Pennsylvania
Following is a link to Chapter 45 of the Pennsylvania Code on Speech Language Assistants:
http://www.pacode.com/secure/data/049/chapter45/subchapEtoc.html
ONE of the eligibility requirements for an SLPA is the 30 semester hours or the equivalent from an accredited institution of higher education in the area of speech-language and hearing. There is also a training component for eligibility stipulated in 45.304 (relating to minimum education, experience and training requirements)and that is that an already licensed SLP must agree to train you as an assistant, with an emphasis on competency-based skill acquisition, in accordance with a work performance analysis. Training may be provided through formal coursework, workshops or directly supervised observation or practicum and the training must encompass all areas of SLP activities which the assistant will perform. A minimum of 20 hours of practical training is required.
If you can find a licensed SLP who is willing to train you as outlined above, and you have met the coursework requirements, then the following must occur:
(a) You licensed supervisors files with the PA Board of Examiners, on a form provided by the PA Board of Examiners, the following:
(1) The name of the assistant.
(2) The location where the assistant will work.
(3) Certification that the assistant has met the education and training requirements in § 45.304 (relating to minimum education, experience and training requirements).
(4) Attestation by the assistant and the licensee that the assistant has read this chapter.
(b) Completed forms shall be filed with the Board within 30 days of the assistant’s employment or a change in the assistant’s employment or supervision.
What are the requirements for the Clinical Fellowship Year in Pennsylvania? Are there any requirements that are different from the ASHA requirements?
Thank you for your recent question to the PSHA Board regarding Pennsylvania requirements for the ASHA Clinical Fellowship Year. Every state has the right to specify how they want to have their Clinical Fellows supervised, so the requirements for CF supervision in Pennsylvania are slightly different from the ASHA requirements.
These requirements are stated in the rules and regulations of our current state licensure law. Here is the direct link to the Rules and Regulations for YSPE (Year of Supervised Clinical Experience - the same as the Clinical Fellowship Year).
http://www.pacode.com/secure/data/049/chapter45/s45.20.html
However, there is a waiver option that allows you to wait to apply for state license until you obtain the Certificate of Clinical Competence. If you choose this waiver option, you can bypass the information in the regulations and just follow ASHA regulations. After you have obtained the CCC, then you can apply for PA state license.
Our state association, the Pennsylvania Speech-Language and Hearing Association, is actively advocating for passage of a new licensure law in our state legislature. This new law will require universal license in Pennsylvania for all practicing SLPs and Audiologists. It will also allow for a Provisional License period during the Clinical Fellowship Year. That means that the CFY will be eligible to bill for services under federal programs, such as Medicaid and Medicare. The Provisional License holder may also be eligible to bill other medical insurers for services provided.
I am a SLP-CCC that is supervising a CF in a SNF. We currently treat mostly Medicare Part B patients. I am somewhat confused on the supervision required by the state. What type of supervision do they need (direct line of site, etc.)? Also, we are a contract company providing the services in these facilities and we bill under the facility's provider number. Is it appropriate for the CF to bill in this circumstance with the appropriate supervision?
We have had several questions regarding this matter in the past year, therefore I decided to research this issue several months ago. Unfortunately in PA, CFs are not issued an interim or a provisional license. Medicare Law Section 1861 (II) of the Social Security Act states that a ‘qualified’ SLP must be licensed if the state has Licensure. Medicare considers a CF who holds a provisional license as fully qualified. But as above our CFs do not hold this provisional license.
I have had several conversations with Mark Kander at ASHA who is the Director of Health Care Regulatory Analysis. ASHA’s interpretation of the above is that CFs who practice in states without provisional licensure require the same supervision as students. Guidelines regarding student supervision are available on the ASHA website. This essentially means that CFs have the same status as students and cannot bill for services rendered in the state of PA or any other state that does not offer a provisional license.
We do not know if other insurance companies follow this law. Many insurance companies do follow Medicare regulations in other areas so they very well may follow this one as well. You will not find this Medicare Law in the Medicare Manuals, only in the act cited above.
There is a new Licensure Bill proposal which we have been trying to get passed for the past 6 years. A copy of the draft along with an update can be found on the PSHA website at www.psha.org . The new Bill would provide for a Provisional License for CFs; and we are also supporting Universal Licensure for all PA SLPs. Please take a look at the draft. Our current Licensure Act has been in place since 1984! It is badly in need of revision.
Hello, I am looking into hiring a CFY to work with children ages 3-5 within the Early Intervention system in PA. The CFY will be supervised by an SLP-CCC, The CFY lives and went to school in NJ. What does she need in order to be able to provide services in PA under the supervision of a PA licensed SLP-CCC? (She has a school license for NJ already, but in PA she won't be working in schools.)
We were told as long as we follow ASHA guidelines we can use CFY's. ( I looked at the website, but I didn't find an answer)
Please advise. Thanks.
Thank you for your question about hiring a clinical fellow to provide services to 3-5 year old children in Pennsylvania. As long as you are following ASHA’s guidelines for supervision, there is no restriction on hiring a clinical fellow who lives in another state and provides services within Pennsylvania. Once they have completed the requirements for their CFY and passed the ASHA exam, they must apply for a license in PA, even if they live outside of PA. It would be illegal for them to continue to practice in PA after the completion of their CFY without a license.
I am a CFY, do I need to be licensed in the state of Pennsylvania to work in rehab or a hospital?
No, you will work under the license of your CFY Supervisor. Once you complete your CFY successfully, you will apply to ASHA for your CCC. Once you have received your CCC, you can apply for your license in Pennsylvania. It is a good idea to contact the Licensure Board prior to the completion of your CFY to begin gathering the materials/ credentials required by the state. They can be contacted at 717-783-1389.
I am a Master's level SLP and a member of ASHA. I work for a small pediatric practice that employs and contracts for SLPs, OT, and PTs - primarily for school district placements. The current SLPs including myself have state licensure, as well as our CCCs. Many districts that I know have at one time or another hired Bachelor level speech therapists with emergency certification. I contacted ASHA about their position, and I was told that their position is that CCCs are required to practice in any setting, but that they (ASHA) don't have any control over specific states, and that they are aware that some states allow individuals with a Bachelor's degree to practice, under Emergency Certification. They advised me to check directly with my state, to see what PA's rules and regulations are in regard to Emergency Certification and requirements? Are there documents or resources you could direct me to to find out more about emergency certification? How the process works for schools vs. private agencies working within the school?
Well, we have been having quite a few questions like yours recently. Here is the response that the PSHA Executive Board composed:
PSHA is receiving many questions about the provision of school-based speech-language services by other school personnel due to school districts’ decisions based on fiscal/budgetary constraints. In an effort to answer these questions, PSHA provides the following:
Although PDE requirements allow a person holding a Bachelor’s degree in speech/language and a PA teaching certificate to work as a school-based speech therapist, such an individual is not qualified nor licensed as a speech-language pathologist, cannot bill for Medical Assistance services, and does not constitute best practices for students.
Only ASHA-certified or licensed SLPs can bill for Medical Assistance (ACCESS) for speech-language services. There are specific guidelines set forth by the Commonwealth of Pennsylvania regarding Medical Assistance billing, including qualifications for billable professionals and for those “under the direction” of a billable professional. (See School-based ACCESS Program at http://www.leaderservices.com/services/pa/)
Situations such as these (i.e. under-qualified personnel providing speech/language services in the schools of the Commonwealth) underscore the importance of every speech-language pathologist in the Commonwealth of Pennsylvania operating under the same credentials. Currently, no license is required for employment in a school setting. Our new licensure act includes a provision for “universal licensure”. This is a term we have coined to refer to the mandatory licensing of all speech language pathologists in Pennsylvania, regardless of practice setting. You can find up-to-date information about our efforts to obtain universal licensure on the PSHA website homepage, and under the licensure/advocacy tab.
Now, I want to reply from the perspective of the school districts and the Pa. Dept of Ed – PDE:
I have worked in the schools for 33 years, and have been an IU speech supervisor for 11 years. We would occasionally hire non-ASHA and non-licensed SLPs. We would also hire SLPs with CCC who did not have school certification. Then, our HR department would get emergency cert for them. There was a cost, I don’t recall how much. We would allow 1 year for the SLP to obtain the permanent cert. Usually this required taking PRAXIS tests, or other requirements. Sometimes it would go into the 2nd year. All along, we were guided by our HR department, so I don’t know all the particulars. The Pa. Department of Education is not easy to navigate when it comes to certification.
I am thinking that you are contemplating hiring some Bachelor level persons to work in the schools. I would caution you, as the ones with Bachelor’s degrees don’t have any practicums at the undergrad level. They would need major mentoring and support. PSHA stands behind that, and is really interested in updating our licensure process to ensure that these inexperienced speech therapists are not eligible for professional positions. PSHA, along with the national trend from ASHA, feels that the SLPA category is a better one for those with a Bachelor’s degree.
How does an individual go about obtaining their emergency certification for
speech-language pathology?
An emergency permit is issued by the Department of Education upon the request of the employing public school entity when a position has been advertised and no fully qualified and properly certificated applicant is available. The candidate for an emergency permit must have earned a bachelor's degree from a state-approved college or university and must meet all other eligibility requirements related to age, citizenship, mental and physical health and good moral character. The emergency permit may be requested for an individual to serve in a vacant position or as a long-term or day-to-day substitute teacher. The permit is valid from the first day of the month of issuance until the last day of summer school in that school year and may be reissued in subsequent years upon the submission of the appropriate application to the Department from the public school entity and completion of conditions set by the Department. Guidelines for the issuance of emergency permits are found under CSPG #13. Click here for more information.
How many CE hours will be required for license renewal?
During each biennial renewal, you will need to demonstrate completion of 20 CE hours (or 2.0 ASHA CE credits).
Will I be able to use CE hours (or credits) to count toward my PA licensure and PA teachers certificate requirements?
Yes and No. It depends on the content of your CE course. The licensing board of PA will not accept courses that are not directly related to speech/language pathology and audiology. In other words, if you take a "Teaching math ..... " course that does meet the teacher certificate requirement, it will not meet your PA license renewal requirements. In general, courses that will receive ASHA CE hours will be approved for PA Licensure CE hours.
Is ASHA requiring Continuing Education to maintain certification now as well?
Yes, but there is an implementation schedule that will be rolled out that is based upon your initial cerification date. Audiologists will begin begin between the years of 2003 - 2005. Speech-Language Pathologists will begin the process between 2005-2007.
Certificate holders will have 4 ways to to obtain professional continuing education, but overall it require a minimum of 3.0 CEUs (or 30 contact hours) over a 3- year renewal cycle. For additional information, please go to:
http://www.asha.org/certification/maintain-ccc.htm
Where can I find information about professional licensure in Pennsylvania and Act 71?
Check out the licensure board's website at:
http://www.dos.state.pa.us/bpoa/cwp/view.asp?a=1104&q=433205
PSHA's VP for Professional Preparation & Continuing Education can also help with Act 71 questions.
I am seeking a post-teaching certification in the state of PA to work as a SLP in the schools. I currently have an active license to work as a SLP (M.S., CCC-SLP). What courses do I need to take and where can I take them? Is it possible to take a distance learning course?
You should send in your application to the PDE for teacher certification so that they can evaluate your credentials. They can then tell you what if anything you need to take. The application is on the PDE website on the following link under certification and application and forms. http://www.education.state.pa.us/portal/server.pt/community/pa_certification/8635
I would like to verify my course hours that meet ACT 48 requirements, can I do that?
Yes, you will need to go to the secure state site at:
http://www.teaching.state.pa.us/
Where can I find information about teacher certification or Act 48?
Check out the Pennsylvania Department of Education's website at:
www.pde.psu.edu/ PSHA's VP for Professional Preparation & Continuing Education can also help with Act 48 questions.
After reviewing the regulations for SLP practice, I could not find the answer to the following question: Is there a required timeline between when a referral source makes a verbal referral to Speech Therapy and when the therapist must secure the signed referral?
Thank you for your question to PSHA. The answer to your question varies depending on the type of referral you are receiving.
For example, per PDE Special Education regulations in the schools, “when an oral request is made to any school professional or administrator, the school entity must provide the Permission to Evaluate – Evaluation Request Form to the parents” within 10 calendar days.
In private practice, for an outpatient client, an RX is not required unless it is required by the third party payer. Prescriptions are not required for speech therapy services. If this is a home care patient, each home care agency has their own regulations about verbal orders/written orders.
I’m sorry I cannot be more specific. I would also refer you to Mark Kander at ASHA who may be able to help you with more specific information.
I am a licensed Audiologist with BS (bachelor degree in Audiology) working fulltime in Sweden. I'm considering too move to USA (Somewhere in Pennsylvania state) and work as audiologist how do i go about to do so? what chances do i have with my BS? Is it possible for me to get a license and practice audiology plus dispense Hearing Aid with my BS?
In the United States, no one is able to practice audiology with a Bachelor's degree. Audiology is now a doctoral-level entry profession. Therefore, one would need a Doctor of Audiology (AuD) or a Doctor of Philosophy (PhD) degree to be licensed and certified in the US. I would recommend that you look online for the Pennsylvania state licensing information, click here.
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