I want to address some of the concerns brought up around this resolution:

1. Threat to the Interstate Compact (ASLP-IC).  The proposed resolution would have absolutely no impact on the Interstate Compact.  In fact, it would provide more opportunities for speech language pathologists as presently CFs/SLPs with provisional licenses are limited in what they can do under the ASLP-IC.  Hopefully, more states will follow suit.

2. TRICARE, which services military members and their families, does not allow SLPs with provisional licenses to treat their beneficiaries.  With a large military population in Northern Virginia and Hampton Roads (Southeastern Virginia), this has a huge impact for our state. 

This leads to long waitlists for service members and their families, who are already more likely to slip through the cracks due to needing to navigate through new health systems to find care each time they relocate.  This issue impacts both pediatric and adult populations, and with Medicare having put the idea out that provisional licenses/CFs are bad, other insurances may follow suit.  If commercial carriers adopt similar language and don’t allow CFs/SLPs with provisional licenses to see patients, CFs/SLPs with provisional licenses will essentially become unemployable. 

3. The fact that ASHA continues to perpetuate a CF process model which causes confusion and additional administrative burdens shows how out of touch they are with the profession.  Most CFs are just getting the bare minimum experience during their CCC process without true mentorship and guidance.  A combination of ASHA’s processes and lack of success advocating for our profession create the reasons why stakeholders are now having to navigate these threats on the state level.  Virginia was on the right track when updating state regulations back in February to allow SLPs with provisional licenses to get their full license after 6 months (with recommendation from their supervisor). However, this is not enough. We need to remove the supervision requirements altogether, giving the SLP a full license at graduation to ensure patients have access to what they need, qualified and quality care, no matter the insurance that is paying for the services. 

Simply put, the state of Virginia has the opportunity to set an example for all states that can simplify the licensure process for new speech language pathologists.  As ASHA itself says:

“The scope of practice (evaluation, diagnosis, treatment) for CFs and SLPs is the same whether an individual holds a provisional or a full license. The primary difference is the title of the license (e.g., provisional). In addition, for those who are pursuing clinical fellowship, they need to comply with the supervision standards required to obtain the CCC and state licensure. Therefore, the varied licensure title is largely a distinction without difference and fails to acknowledge that provisional licensees have earned a master’s or doctoral degree and completed supervised clock hours of clinical practicum as required by Medicare and under most state laws.”

4. Some make the argument that the reason that PT and OT graduates receive a full, unrestricted license is that they are required to perform more clinical hours than speech pathology students.  While this may or may not be true depending upon the graduate program in question, the truth is that the design of the ASHA CF process (and the more recent 6-month Virginia update) hardly addresses this.  SLPs with provisional licenses in Virginia are only required to have 24 hours of supervision over 6 months.  In reality, most receive a lot less.  In any case, an additional 24 hours over six months won’t bridge any clinical gap between PT/OT and speech language pathologists.  Justifying supervision requirements of newly graduated SLPs to make up for supposedly less clinical hours does not make sense.

The proposed petition would make the speech-language pathologist career a better one while providing a licensing process that is in line with that of physical and occupational therapists.  Most importantly, it would ensure that patients who need care, can get it consistently.

Josh Adler, OTR/L

Owner, Chief Clinical Officer

Adler Therapy Group