I am writing to provide feedback on the proposed changes to the speech-language pathology (SLP) licensing regulations in Virginia. As a professional committed to upholding the highest standards of care, I support the following positions and respectfully offer these considerations: 

Continuing the Requirement for the Certificate of Clinical Competence (CCC):
Maintaining the CCC as a licensure requirement is essential to ensuring that practitioners meet rigorous standards of knowledge and competency. This certification reflects a commitment to evidence-based practice, advanced clinical skills, and ongoing professional development, which are critical when working with vulnerable populations. Additionally, the CCC serves as the only mechanism for reporting ethics violations, as, to my knowledge, no such channel currently exists within Virginia’s licensing regulations. This oversight role mitigates, to some extent, the risk of predatory "treatments" such as "Spelling to Communicate" and "Rapid Prompting Method" being implemented with individuals in need of ethically informed and evidence-based therapy. The CCC thus not only ensures clinical excellence but also upholds the ethical standards necessary to protect our constituents.

Revising Continuing Education Requirements:
While I strongly support the need for ongoing professional education, I agree with removing the mandate that CEUs must be ASHA-approved. Broadening the scope of acceptable CEU providers would reduce financial and logistical burdens on practitioners while maintaining high-quality professional development. Recognizing diverse sources of continuing education, provided they align with evidence-based and ethical practices, will foster greater accessibility and innovation in professional learning as well as fostering interprofessional practice.

Upholding Strong Regulatory Standards:
SLPs serve some of the most vulnerable individuals in our communities, and it is essential to maintain a licensing framework that reflects the highest levels of professional accountability and clinical excellence. Strict licensure requirements ensure public trust, uphold the integrity of the field, and guarantee that practitioners possess the necessary qualifications to deliver safe and effective services.

Opposing the Distinction Between School-Based and Other Speech-Language Pathologists:
The distinction made between school-based SLPs and other SLPs, particularly regarding application and renewal fees and licensing requirements is bothersome. Speech-language pathology is a highly specialized field requiring advanced training and expertise, regardless of the professional setting. The reality is that many school-based SLPs do (and often NEED to) also work in other settings and thus would need to hold two distinct licenses to practice in VA. Differentiating fee structures and requirements based on the setting of employment creates unnecessary barriers and disparities among practitioners. All licensed SLPs should be held to the same standards and subject to consistent licensing procedures, regardless of whether they practice in schools, clinics, hospitals, or other environments. Equity in licensing is essential to uphold the integrity of our profession and ensure that all practitioners are treated fairly. 

Repealing Restrictions on School-Based Speech-Language Pathologists Practicing Outside Public Schools:
The section on prohibited conduct that restricts school-based SLPs from practicing outside the public-school setting should be repealed. Limiting the professional scope of school-based SLPs in this way is unjustified and does not align with the realities of our profession. If all licensed SLPs are held to the same licensing and renewal standards, there should be no restrictions on their ability to practice outside of the public-school environment. Such limitations are arbitrary and fail to reflect the breadth of training and expertise that SLPs possess. Removing this prohibition would not only promote flexibility and opportunity for school-based SLPs but also enhance access to critical services in other settings where their skills are urgently needed.

By addressing these concerns, the Board has an opportunity to strengthen the licensing framework and support the advancement of the profession in Virginia. I appreciate your dedication to revisiting these standards and respectfully urge consideration of these points.