Subject: Opposition to Petition to Eliminate Provisional Licensure Requirement (18VAC30-21-60(A)(2)(c))

Dear Dr. McNichol and Members of the Virginia Board of Audiology and Speech-Language Pathology,

I write as a licensed speech-language pathologist and Virginia resident, submitting these comments in my individual capacity and not representing any leadership roles I may hold.

I strongly oppose the petition submitted to eliminate section 18VAC30-21-60(A)(2)(c) of the licensure regulations, which requires six months of supervised practice under a provisional license and a supervisor’s recommendation for full licensure.

My reasons for opposing the petition are that:

• Provisional licensure, implemented by this board in 2016, was a landmark achievement [1]. It ensures that pre-licensed clinicians receive supervised clinical training while being able to practice and bill for services. It is also in alignment with 48 other state licensing boards.
• This petition was prompted by CMS’s June 2025 interpretation that excluded Clinical Fellows from billing Medicare. However, CMS reversed this decision on July 29, 2025, affirming that provisional licensees may bill Medicare if they meet state licensure requirements[2]. Thus, the petition’s rationale is no longer valid.
• The petition fails to justify lowering licensure standards. Licensure protects public safety by ensuring clinicians meet minimum competency standards. The mentored post-graduate clinical experience is essential for transitioning from student to independent practitioner. It strengthens clinical reasoning, refines skills, and ensures readiness to deliver quality care. Eliminating this requirement risks placing underprepared clinicians in unsupervised roles, compromising patient outcomes and public trust[3].
• Provisional licensure supports other pathways, including licensure by endorsement, reactivation of inactive licenses, and reinstatement of lapsed licenses. Removing it would disrupt these processes and increase administrative burdens on the Board without improving consumer protection.
• Any changes to provisional licensure should be considered within broader educational reforms, such as the shift toward competency-based training. Premature regulatory changes would undermine clinician preparedness and care delivery.
• Changes would likely disqualify Virginia from participating in the interstate compact unable to participate in the ASLP-IC.

In conclusion, I urge the Board to reject the petition. Maintaining 18VAC30-21-60(A)(2)(c) is essential for ensuring adequate training, supervision, and public protection.

Respectfully,
Carol C Dudding, PhD CCC-SLP

James Madison University

References

[1] 18VAC30-21-60. Qualifications for initial licensure. - Virginia Law

[2] CMS Reverses Its Interpretation of a Qualified SLP: Clinical Fellows ...

[3] Virginia Regulatory Town Hall View Comments