I am an SLP licensed in Virginia and have supervised SLP graduate students, recent graduates, and those seeking advanced certifications over the last 25 years. I fully support the proposed changes to licensure. Our graduates finish 6 years of advanced education meeting a complicated list of competencies, both academic and clinical, as well as completing 400 supervised clinical hours. They have also passed the Praxis exam. These professionals have proven their ability to safely practice. State license is about public protection. The extra hurdle of additional supervision is not necessary and not needed to accomplish the mission of the Board. 

I believe it is necessary to reflect on some of the comments that are opposed to these proposed changes. Yes, this issue only affects only a small number of professionals. I wholeheartedly disagree with the notion that if it only effects a few, then we do not need to consider changes as every one of our fully licensed professionals was once on a provisional license. I may not have had the issues with reimbursement since I was licensed well before the 2015 changes to Medicaid; however, we cannot ignore that the supervision period is an antiquated system without data from the Board as to the impact on public protection. Cited data on various message boards are provided by our professional association - ASHA. I understand and appreciate that ASHA is "working on it" in reference to billing and the enforcement of guidelines approved 10 years ago, but we can work on it also by eliminating the unnecessary delay in licensure.

Additionally, I do not believe that considering the impact on the ASLP-IC is warranted at this time. We cannot delay our own interests in Virginia, as our commitment is to our licensed professionals, when there is nothing that is stated in the ASLP-IC that our membership would be impacted by eliminating this requirement.  Finally, thank you for your time and consideration to this important matter.