I am writing in strong support of the proposed changes to the Virginia Board of Audiology and Speech-Language Pathology regulations, particularly regarding the development of an alternative pathway to licensure that does not require the Certificate of Clinical Competence (CCC) and the removal of the requirement for ASHA-approved CEUs for professional development. These changes are critical for enhancing accessibility to the field of speech-language pathology (SLP) and reducing unnecessary barriers for professionals and those they serve.

The CCC is a third-party, nonprofit certification product that generates substantial revenue for the American Speech-Language-Hearing Association (ASHA). Furthermore, it does not guarantee any initial or ongoing competency across the scope of SLP beyond what is already assured by Virginia’s licensing standards. 

Considering professional development/CEU requirements,  ASHA approved CEUs provide barriers for SLPs due to increased costs and less availability. CEUs are more accessible and affordable from other sources. Broadening access to peer reviewed CEUs beyond third party companies and agencies will increase options for clinicians looking to obtain alternative continuing education opportunities including interdisciplinary education from experts in other fields. 

The reduction of redundant requirements will enhance accessibility to the field of speech-language pathology (SLP) and reducing unnecessary barriers for professionals and those they serve. This directly supports the increasing need for recruitment and retainment of SLPs in Virginia schools. The need for school based SLPs is at a critical level. When schools are not fully staffed, students do not recieve services. 

In summary, I strongly support this regulatory action. The reduction of "redundant and unnecessary" in any situation is a postitive step forward. 

Sincerely,

Janine Thompson, SLP