August 8, 2025
Melissa A. McNichol, Au.D., CCC-A, Chair
And the Virginia Board of Audiology & Speech-Language Pathology
c/o Kelli Moss, Executive Director
RE: Opposition to Petition to Eliminate 18VAC30-21-60(A)(2)(c)
Dear Dr. McNichol and Members of the VABASLP,
I write to you as a licensee and resident of the Commonwealth of Virginia, and as a member of the Speech & Hearing Association of Virginia (SHAV). I am submitting these comments in my individual capacity, not as a representative of any volunteer leadership roles I may currently hold.
Provisional licensure in the Commonwealth was implemented in 2016. This was a landmark accomplishment during my second term serving on the VABASLP. The provisional license was designed to ensure that pre-licensed clinicians could gain additional clinical training while being able to practice and bill under supervision.
I am writing in strong opposition to the petition submitted by the SHAV and Ms. Dorn to eliminate 18VAC30-21-60(A)(2)(c) from the Regulations Governing the Practice of Audiology and Speech-Language Pathology, which currently states:
18VAC30-21-60. Qualifications for initial licensure.
A. The board may grant an initial license to an applicant for licensure in audiology or speech-language pathology who:
1. Holds a current and unrestricted Certificate of Clinical Competence issued by ASHA; or
2. Submits evidence of the following:
a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body recognized by the board;
b. Passage of the qualifying examination from an accrediting body recognized by the board; and
c. Evidence of six months of practice pursuant to a provisional license as described in 18VAC30-21-70 and submission of recommendation for licensure from the applicant's supervisor during practice as a provisional licensee.
This petition by SHAV is short-sighted, unjustified, and detrimental to public protection. The petition was prompted in response to CMS (Centers for Medicare & Medicaid Services) clarification of language disseminated in June 2025, indicating that individuals with provisional licensure, such as Clinical Fellows, would no longer be able to engage with Medicare enrollees, bill for services or be reimbursed. This was disappointing and frustrating. However, CMS since reversed course on July 29, 2025. https://www.asha.org/news/2025/cms-reverses-its-interpretation-of-a-qualified-slp-clinical-fellows-cleared-to-bill-medicare/?srsltid=AfmBOopwFXgIaboznqfSvV_BNXSrWoWxsn-8DP8fasY_4Lf7Ov6f72P0
“In direct correspondence with ASHA, CMS clarified that its updated interpretation aligns with state licensing requirements and allows individuals holding provisional or temporary licenses, such as CFs, to provide services to Medicare beneficiaries—provided they meet their respective state’s licensure requirements.”
With this reversal, the original impetus for the petition is no longer valid.
More concerning, however, is that the petition offers no compelling rationale for lowering the threshold for full licensure. Licensure exists to protect the constituents of the Commonwealth, providing for public safety and consumer protection. It provides the minimal standards for practice in the state and sets legal recourse for individuals who have been harmed by those who have misrepresented their credentials or who have not provided services that meet the standards imposed by licensing bodies. It is a public-safety measure. Weakening these standards undermines public trust in licensed healthcare professionals. Licensing is mandatory.
The fundamental education and training for licensed and certified Speech-Language Pathologists requires completion of the mentored post-graduate clinical experience following graduation from a CAA accredited program. This is a critical, structured, mentored professional experience to transition between being a student enrolled in a communication sciences and disorders (CSD) program and being an independent provider of speech-language pathology clinical services. The purpose of this experience is to integrate and apply the knowledge from academic education and clinical training, evaluate strengths and identify limitations, develop and refine clinical skills consistent with the Scope of Practice in Speech-Language Pathology, strengthen clinical reasoning and decision making, and advance the clinician from needing constant supervision to being an independent practitioner. The petition disregards the significance of this supervised transition and effectively proposes its elimination—without addressing the impact on quality of care, patient outcomes, or professional readiness.
Moreover, the petition fails to consider other categories of professionals who benefit from provisional licensure, including those:
The mentored post-graduate clinical experience is an integral part of preparing entry-level clinicians for full licensure, certification and a successful career of competence. The clinical experience of the graduate training programs is insufficient currently for an individual to graduate and expect to be practicing without additional guidance. Eliminating this step would risk placing inadequately prepared clinicians into unsupervised roles, weakening the foundation of consumer protections imbedded in Virginia licensure laws.
Furthermore, any proposal to eliminate provisional licensure must be evaluated in the broader context of educational reform. Graduate training programs would need guidance and time to adjust. Efforts are currently underway at the national level to transition to emphasis on competency-based training v. hour-based requirements, but that will take time, collaboration and systemic adjustment. Premature regulatory changes would jeopardize the readiness of new clinicians and compromise care delivery.
Eliminating provisional licensure would also increase the administrative burden on the Virginia Board of Audiology and Speech-Language Pathology (VABASLP), as staff would need to verify all credentialing elements for every applicant—likely requiring additional budget and staffing with no added benefit to patients or consumers. Also, would want to consider impacts to participation with Medicaid, of which I am less knowledgeable.
In conclusion, the removal of 18VAC30-21-60(A)(2)(c) is ill-advised, unjustified, and risky. The current standard ensures adequate preparation, supervision, and public protection. I respectfully urge the Board to reject this petition.
Most sincerely,
Laura Purcell Verdun, M.A., CCC/SLP, ASHA Fellow
VABASLP 2010-2014, 2014-2018
VABHP 2014-2015, 2015-2019