To the Virginia Board of Audiology and Speech-Language Pathology:

My name is Jeanette Benigas, PhD, SLP, founder and CEO of Fix SLP, a national grassroots advocacy organization advancing evidence-based reforms that improve access to care, build sustainable career pathways, and expand professional autonomy for speech-language pathologists. My advocacy and leadership have helped modernize licensure and credentialing policies in multiple states, balancing public protection while empowering clinicians to make informed choices about licensure and third-party certifications. I am a former full professor with two decades of experience as a clinician, academic, national public speaker, author, continuing education provider, and business owner. That cross-sector experience lets me see how licensure rules land on patients, payers, employers, and early-career clinicians, and it informs the practical, Compact-compliant amendments I’m urging the Board to adopt.

I support the petition, only with targeted amendments that preserve patient protection, prevent payer denials, and keep Virginia compliant with the Audiology & Speech-Language Pathology Interstate Compact (ASLP-IC). Approval of the petition with these amendments grants full licensure at graduation, replaces supervision with structured first-year mentored CE, and keeps Virginia ASLP-IC compliant.

While CMS has reversed its June 2025 interpretation, systemic payer barriers remain. TRICARE has a longstanding practice of not credentialing or reimbursing conditionally licensed SLPs, and employers report that Palmetto GBA, Virginia’s Medicare Administrative Contractor (MAC), has inconsistently refused to credential conditionally licensed providers over the last several years. These gaps create denials and delays despite state licensure. Without explicit state action, full licensure at graduation paired with a Board-defined, Compact-compliant first-year mentored CE requirement, payers will continue to treat early-career clinicians as “conditional.” Absent clarity, similar tactics may spread to commercial plans (e.g., Blue Cross Blue Shield plans, UnitedHealth Group) to avoid reimbursement.

Note on PT/OT comparisons: While some commenters cite physical therapy and occupational therapy models, those professions follow clinical-doctorate pathways with substantially longer training timelines and supervised hours. Virginia does not need to import those frameworks to protect the public. An SLP-specific solution, full licensure at graduation paired with a Board-defined, Compact-compliant first-year mentored CE requirement (MPDH), better fits our current education model, workforce needs, and ASLP-IC obligations.

I propose the following targeted amendments as a starting point for the Board to refine and adopt:

1. Eliminate 18VAC30-21-60(A)(2)(c)
   Eliminate 18VAC30-21-60(A)(2)(c), as proposed, to enable the Board to issue a full, unrestricted license upon graduation/exam, so that employers and payers do not misclassify new clinicians as “conditional,” a practice that can depress wages, trigger billing/credentialing denials, and delay access to care.
   
2. Restructure the required post-graduate support period to a mentored CE model
   a. Timeline and substitution for first-year CE: Extend the current six-month format to allow as few as nine months (to accommodate school SLPs), but up to twelve months to complete a Board-defined mentored continuing education/professional development program, required instead of the first-year 10 hours of CE per year. Name the hours Mentored Professional Development Hours (MPDH) (alternates: Applied Clinical Education Hours, Skill Advancement Education Hours, Structured Continuing Education Hours).
   
   b. CE credit and documentation: Award Board-approved CE to mentees for documented mentored contact hours and completed activities, and to mentors for providing structured mentorship; both report using a Board template (learning plan, session logs, artifacts) retained for audit, or require all first years to report via the method in place for the current six-month model. For mentors, allow up to five hours per mentee (aligned with some OT models).
   
   c. Mentor structure: The mentee can designate one mentor for primary accountability, but encourage multiple mentors of record with complementary skills; this reduces dependency, risk of abuse of power, and broadens clinical judgment. 
   
   d. Interaction standards: Define interaction standards (face-to-face/synchronous) to prevent employers from substituting telephone or web-only check-ins as a cost-saving measure.
   i. Months 1-3: At least two mentored meetings per month; at least three face-to-face meetings across Q1 and at least three direct observations (live or synchronous video).
   ii. Months 4+: Six monthly mentored meetings (in-person; allow a limited number of virtual meetings), with at least three additional direct observations across the year.
   iii. Encounters may include live observation, case conference, documentation review, payer policy coaching, ethics consults, and interprofessional coordination.
   
   e. Qualifications and safeguards: Mentor need not be the employer and may not condition sign-off on employment terms. The Board may reassign a mentor if concerns arise without penalizing the mentee’s progress. Define clear progress criteria and a remediation plan when the mentee does not meet competencies.
   
   f. Competency-based completion: Core domains include clinical decision making, documentation and compliance, payer requirements, ethics, safety/quality, culturally responsive care, and specialty-specific skills. Completion requires concurrence from at least two mentors (where available) to mitigate a single-person veto/approval.
   
3. Provide administrative clarity to prevent lower wages and payer denials.
   a. The license is full and unrestricted from day one. The mentored CE is post-licensure and does not create a conditional status.
   
   b. Issue written guidance to payers and employers clarifying that first-year mentored CE is post-licensure and does not create a conditional status.

ASLP-IC Compliance
To maintain participation in the ASLP-IC:

1. Codify the mentored CE year as Virginia’s post-graduate supervised professional experience (SPE) equivalent, delivered in a structured, Board-regulated mentorship format (Mentored Professional Development Hours).
2. Make explicit in regulation that successful completion of this mentored CE satisfies the Compact’s post-graduate supervision requirement for Virginia licensees.
3. With these amendments, approval of the petition maintains Virginia’s ASLP-IC compliance while modernizing oversight and strengthening support.

Implementation Considerations

1. Transition: Individuals currently in Virginia’s six-month pathway may roll those months into the new mentored CE requirement.
2. Access and Equity: Permit tele-mentoring statewide, provided minimum in-person thresholds are met; create an optional mentor registry to expand availability in rural/underserved areas.
3. Audit and Quality: The Board may audit artifacts and logs and establish a non-punitive feedback loop to improve the program continually.

In closing, this amended approach maintains the elimination of 18VAC30-21-60(A)(2)(c), as proposed, protects patients, improves early-career support, avoids payer confusion, may increase early-career compensation, and preserves interstate mobility. I respectfully urge the Board to approve the petition with these or similar amendments and adopt Mentored Professional Development Hours (MPDH) as Virginia’s first-year, structured, competency-based CE requirement.

If you or the Board have any questions, I can be reached at team@fixslp.com.

Respectfully submitted,
Jeanette Benigas, PhD, SLP
Founder & CEO, Fix SLP