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

I strongly support continuing the requirement for the Certificate of Clinical Competence (CCC). The CCC is a nationally recognized professional credential that represents a level of excellence in the field of Audiology (CCC-A) or Speech-Language Pathology (CCC-SLP). Those who have achieved the CCC have voluntarily met rigorous academic and professional standards, typically exceeding the minimum state licensure requirements. They have the knowledge, skills, and expertise to provide high-quality clinical services, and they actively engage in ongoing professional development to keep their certification current.

Maintaining our CCCs as a license requirement is essential to ensuring that all practicing SLPs uphold the standard of knowledge and competency in our field. This national standard is continually updated to meet the evolving needs of our profession and those we serve, and removing this requirement would place this burden on the state licensure board. Further, the CCC requires all practitioners to maintain our ethical standards. 

Our profession is constantly evolving and the only way to keep practitioners current in evidence-based research and practice standards is by requiring annual, high-quality, professional education. Maintaining ASHA-approved continuing education is vital for consistency as well as credibility across the field of speech pathology. 

Further, I strongly oppose the distinction between school-based and other speech-language pathologists. Differentiation of fees between employment settings creates barriers across our profession. Many SLPs work in multiple practice settings, and if this proposition passes many SLPs would need two licenses within one state. As an SLP from the greater Washington, DC area, I am already required to hold licenses from multiple states to meet the needs of the clients I serve. There is no need for this additional burden, as our national practice standards are the same regardless of our clinical setting.

The section on prohibited conduct that restricts school-based SLPs from practicing outside the public school setting should also be repealed, as it would create an additional and unnecessary administrative burden that also has the potential to further reduce the availability of SLPs to serve our school population. Flexibility in practice settings allows for greater access to services for all constituents. 

As SLPs, we serve Virginians with communication disorders - a vulnerable community who may not be able to advocate for themselves. Therefore, we must uphold the highest standards to ensure that high-quality services remain available for these residents.

Thank you for considering the points above and listening to SLPs in Virginia while reviewing these standards. I appreciate your time and service.