January 23, 2023

Leslie Knachel, Executive Director

VABASLP

9960 Mayland Drive, Suite 300

Henrico, VA 23233

RE:      Petition to amend 18VAC30-21-60(A)(1)

Dear Ms. Knachel and the VABASLP,

I am writing to oppose a petitioner’s request that the Board amend 18VAC30-21-60(A)(1) to eliminate the requirement that initial licensure applicants hold a Certificate of Clinical Competence (CCC) issued by ASHA, thereby replacing that requirement with holding a master’s degree in speech-language pathology, communication disorders, speech and hearing science, or equivalent.   

Though I understand and appreciate the request, there are many concerns about approaching initial licensure in this manner.  The biggest concern is that a master’s degree in speech-language pathology, communication disorders, speech and hearing science, or equivalent is solely insufficient.  A minimum qualifying standard must remain to be met by all license applicants, which ASHA certification presently provides.  This request eliminates not only the ASHA CCC’s but the requirement for a passing score on the national qualifying examination and completion of the clinical fellowship. We should not be looking to further dilute the qualifications and capabilities, and constituents’ expectations, of the professions.

This is an opportunity for further discussion, but in the present form, this request is not the solution.

Thank you for your consideration.

Respectfully,

Laura Purcell Verdun, M.A., CCC/SLP