The School That Hired an Unlicensed "Speech Therapist"

1. Unlicensed practice by the school's "therapist." Under RA 11249, the Philippine Speech-Language Pathology Act, practice requires a PRC-issued licence. Delivering and billing for "speech therapy" without one is unlicensed practice, regardless of the diploma held. I cannot make that conduct lawful by association.

2. Diagnosis outside scope. "Mild autism" is a medical/developmental diagnosis made by a physician as part of a multidisciplinary assessment. An SLP contributes a communication assessment; she does not issue an autism diagnosis, and neither does a diploma holder in special education. Screening is also not diagnosis - a screening result may only generate a referral.

3. Co-signing reports for HMO claims - cannot do this. A signature on a clinical report attests that I performed the assessment and formed the opinion. Signing another person's work for payment is false certification and potentially fraud against the HMO, and it exposes my licence to revocation. There is no fee that makes this acceptable.

4. Supervision of unlicensed aides by messaging app - cannot do this. Delegation is only defensible where the law and its implementing rules clearly permit support personnel, and then only within defined, documented supervision with the licensed professional retaining clinical responsibility. Fourteen additional sessions of direct therapy delivered by unlicensed staff, supervised by chat messages, is unlicensed practice with my name attached. I must check the current IRR wording before saying anything specific about permissible assistant roles, but the described arrangement is not it either way.

5. Coercion and conflict of interest. The evaluation threat is irrelevant to the ethical analysis; the HMO offer is a financial conflict that must be declined and documented.

To the parent - the parent is the client in front of me, and the priority is that she is not misled twice.

• Review the document she brought and explain what it does and does not show: it is a screening level opinion; nobody has yet done a standardised language assessment; the autism label was not made by a qualified professional.
• Offer her a proper assessment and a written plan. Do not attack the other provider personally, and do not tell her what to do about the fees - give her the facts and let her decide.
• If she asks about a complaint, tell her truthfully that she may raise it with the PRC through the Board of Speech-Language Pathology, and that I will give her copies of my own findings.

To the school - put it in writing, once, factually:

• Billing parents for services delivered by an unlicensed person creates legal exposure for the school, and the reports will not withstand scrutiny if a parent contests them.
• Decline the co-signing arrangement explicitly and in writing, stating the reason: a signature certifies personal performance of the assessment.
• Offer an alternative that solves their real problem: a contracted, scheduled screening day delivered by me, with parental consent, clear screening-only language, and referral pathways.

To the director - do not argue ethics in the corridor; make it a business-risk conversation and put it in writing.

• The proposed caseload is unlicensed practice; my licence is the asset that lets the centre bill at all, and it can be suspended or revoked.
• Propose a counter-plan: a waitlist with priority triage, parent-delivered home programs with scheduled reviews, and recruitment of a second licensed SLP.
• Request the instruction in writing. If it is repeated, escalate to the PRC Board and the accredited professional organisation, and consult an employment lawyer before resigning - resignation does not erase the record of having complied.

Documentation - contemporaneous and factual.

• A dated record of the request to co-sign, the fee offered, and my refusal, with the reason stated clinically rather than morally.
• A dated record of the instruction to run 14 sessions through unlicensed aides, including the wording used and the evaluation threat.
• The parent's visit: what document she presented, what I explained, what I did and did not agree to do, and her stated wishes.
• My assessment findings, written to stand alone, so that any later reader does not need the earlier report.
• Nothing about the other provider's competence beyond observable facts (credential held, service billed). Opinion about a named individual invites a defamation problem and weakens the real complaint.

Escalation order, and why.

1. Internal, written, with an alternative offered. This is the step that most often resolves the issue and the step that protects me if it does not.
2. PRC Board of Speech-Language Pathology. The Board is the regulator with jurisdiction over licensure and practice; unlicensed practice and pressure on a licensee belong there.
3. The accredited professional organisation, for guidance and peer support, and because pattern complaints carry more weight than isolated ones.
4. Employer-side remedies - HR, then a labour lawyer - if the pressure continues, since the risk to me is employment as well as licence.
5. The HMO or the school's accrediting body only if billing fraud actually proceeds, and then with documents, not suspicions.

Judgement point. Do not escalate first and document later. In regulatory cases the contemporaneous written record, not the strength of my indignation, is what determines the outcome.