Who qualifies as a student extern? A student extern must be a graduate student currently enrolled in an accredited Doctor of Audiology (Au.D.) program. To qualify as an extern, the student must be in their final 12 months of schooling, gaining supervised, real-world clinical experience.
Do student externs require a license to practice? State licensure requirements vary across the country, with some states providing a provisional, temporary, or preliminary license to practice. If no specific licensure exists in a given state, they are simply classified as students. It is important to check the requirements for your specific state.
Can a fourth-year audiology extern perform diagnostic audiology testing for Medicare patients? If a student extern holds a temporary or preliminary license to practice in their state, they are considered a qualified provider under Medicare and do not require additional supervision beyond what is required under applicable state licensure. If they do not have a license, they are considered students as defined by Medicare policy and must follow the Medicare supervision requirements, which vary by practice setting.
- In an outpatient setting – students require 100% “personal supervision,” meaning the supervising audiologist or otolaryngologist must be in the room directing the service and not engaged with any other activities or patients.
- In an in-patient setting – students require “direct supervision,” which allows the supervising audiologist to be elsewhere (in person or virtually) so long as they are available to intervene immediately if needed.
What about for commercially insured patients? Commercial health plans (including Medicare Advantage and Medicaid Managed Care) are not required to follow the same policies set forth by Medicare, though some policies do mirror Medicare policy language. For this reason, it is critical to check with the specific payers to determine their supervision requirements.
If a student extern is allowed to provide services, what documentation should be present in the chart regarding supervision? In cases where a student does not have any type of license, including temporary or provisional, they would not have an NPI number of their own. In these cases, the documentation would need to clearly include the following:
- Student Extern’s Name and Services Provided
- Supervising Audiologist’s Name and Services Provided
- Level of Supervision and Circumstance:
- Where is the supervising audiologist in relation to the student extern and patient?
- Is the supervising audiologist working with any other patients or externs?
- The clinical note must be signed by the supervising audiologist.
Key Takeaways if you are considering bringing in a student extern:
- Understand their classification in your state. Is there a student licensing option?
- Check with all payers to understand their specific policies and supervision requirements.
- Schedule smart: Ensure you are assigning the extern to an audiologist with a schedule that allows for appropriate supervision. Similarly, avoid scheduling externs with patients whose payers may prohibit externs’ involvement.
- Ensure you understand the services the extern can provide vs what needs to be completed by the supervising audiologist. Some payers may limit student externs to work similar to a technician, meaning they could provide the technical component of a diagnostic test. To learn more about the technical vs professional component of services, review our position statement on technicians.
Published August 2026
