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Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Audiology and Speech-Language Pathology
 
chapter
Regulations Governing the Practice of Audiology and Speech-Language Pathology [18 VAC 30 ‑ 21]
Action Regulatory Reduction 2024
Stage Fast-Track
Comment Period Ended on 1/29/2025
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1/19/25  5:32 pm
Commenter: Alyssa Bleimeyer, MS, CCC-SLP

Support for proposed text - Regulations Governing the Practice of Audiology and SLP
 
     As a licensed speech-language pathologist in the state of Virginia, I am writing to express my support for the proposed changes in regulatory reduction, specifically the removal of the requirement for speech-language pathologists to hold a certification of clinical competence from the American Speech-Language-Hearing Association (ASHA). I believe this change will create a more equitable and accessible path to licensure for professionals in our field, without compromising the quality of services provided to the individuals we serve.
     However, I respectfully disagree with the distinction made between school-based speech-language pathologists and other speech-language pathologists, particularly regarding application and renewal fees and licensing requirements. Speech-language pathology is a specialized field that requires a high level of training and expertise, regardless of the setting in which the professional practices. The different fee structures and requirements based on the setting of employment appear to create unnecessary barriers and disparities among practitioners. All licensed speech-language pathologists should be held to the same standards and should be subject to consistent licensing procedures, regardless of whether they work in schools or other settings.
     Furthermore, I believe the section on prohibited conduct restricting school-based speech-language pathologists from practicing outside the public-school setting should be repealed. Limiting the professional scope of school-based speech language pathologists in this way is unjustified and does not align with the realities of our profession. If all licensed speech-language pathologists are held to the same licensing and renewal standards, then there should be no restriction on their ability to practice outside of the public-school environment. It is essential that all professionals in our field are equally empowered to serve individuals in various settings based on their qualifications, rather than being limited by arbitrary distinctions that do not reflect the scope of our expertise or training. Removing this prohibition would promote greater flexibility and opportunity for speech-language pathologists to contribute their skills where they are most needed.
     I urge the regulatory body to accept the proposed changes related to removal of the requirement for speech-language pathologists to hold a certification of clinical competence from ASHA and repealing the prohibiting conduct section. I strongly support the removal of a distinction between school-based and other speech-language pathologists regarding licensure requirements and fees. These changes will foster a more inclusive, effective, and equitable profession for all speech-language pathologists in Virginia. Thank you for your time and consideration.
 
Sincerely,
Alyssa Bleimeyer, MS, CCC-SLP, CBIS
CommentID: 229403