I am writing to provide feedback on the proposed changes to the speech-language pathology licensing regulations in Virginia. 

Frist, I would like to see a continued requirement for the Certificate of Clinical Competence (CCC). This is the national certification that ensures SLPs across the country are practicing with the same ethical code, education and training requirements, and are upholding the same level of professionalism in terms of continuing education, assessment, and intervention. As stated by another commentor "The CCC's certification demonstrates each SLP's dedication to providing evidence based therapy, upholding their clinical skills and remaining up to date with our ever changing field. The certificate of clinical competence also serves at the only mechanism for reported ethics violations in Virginia. We need to uphold this ethical standard for all practitioners." 

Second, I agree and support the need for ongoing professional education. Our field is consistently changing with new evidence based practices, evaluation measures, legislation, and other research. In order to serve our clients, we need to be knowledgeable and up to date on the above items.

Third, I strongly oppose the distinction between school-based and other speech-language pathologists. School based speech language pathologists have the same expectations when it comes to education and often CCC requirements, the main distinction is the educational or academic impact governing the inclusion of services. We provide the same services as outpatient or private practices, we use the same evaluation measures, and we write very similar goals. Additionally, many SLP's work in two settings and if this proposition passes many SLP's would need two licenses within one state in order to simply maintain their current positions. We need to hold all SLP's to the same standards regardless of setting. The section on prohibited conduct that restricts school-based SLPs from practicing outside the public school setting should be repealed. Our scope of practice is wide and varied, those who choose to work in both a medical and school setting are responsible for maintaining their professional skills and knowledge. This legislation implies that we cannot be knowledgeable in both, when we in fact can and are.