As a licensed and ASHA certified SLP in Virginia for 25 years, I am writing in strong support of the proposed changes to the Virginia Board of Audiology and Speech-Language Pathology regulations 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.  Our state licensure should not rely on our national professional organization.  Other professions in Virginia such as OT and PT are not tied to their national professional organization to maintain their state licensure in the same way that the SLPs are currently.

The CCC should be voluntary and ASHA states it is voluntary, but it is not if you practice in Virginia. The cost to maintain my CCC over the past 25 years, when I have only ever practiced in Virginia, is well over $5000.  That cost is in addition to the costs I pay to maintain my state license. Maintaining my CCC has done nothing to assist with public protection, the goal of the BASLP, as I have always completed my 10 hours of CE per year per state licensing guidelines.  By eliminating the CCC requirement, Virginia can align with other states and reduce unnecessary financial barriers.

I ask that the Board of Audiology and Speech-Language Pathology accept the proposed changes related to removal of the requirement for speech-language pathologists to hold the CCC from ASHA. Also, I strongly support the removal of a distinction between school-based and other speech-language pathologists regarding licensure requirements and fees.