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Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Audiology and Speech-Language Pathology
 
chapter
Regulations Governing the Practice of Audiology and Speech-Language Pathology [18 VAC 30 ‑ 21]
Action Regulatory Reduction 2024
Stage Fast-Track
Comment Period Ended on 1/29/2025
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1/27/25  4:42 pm
Commenter: Madison Brumbaugh

Support removal of CCC requirement
 

While the American Speech-Language-Hearing Association (ASHA) has been a fantastic resource and collaborator for speech-language pathologists in Virginia, including their clear and active partnership on interstate compact legislation during Virginia's 2024 legislative session, the current CCC requirement is creating an unnecessary barrier to speech-language pathology licensing in Virginia.

We are currently facing a provider shortage, with school-based caseloads often exceeding the Virginia cap of 68(!) and productivity rates in healthcare settings often exceeding 80%, ultimately impacting the quality of speech-language pathology services that our clients receive. Licensing requirements for prospective speech-language pathologists in the Commonwealth should be revised to ensure that applicants have adequate educational and clinical practicum experiences (i.e., discerned through their educational record and Praxis examination scores); however, the CCC should not be mandatory. Doing so not only hinders the licensing of competent practitioners who could enhance the quality of healthcare services in Virginia, but it also requires their payment of certification maintenance fees to ASHA. State regulations should not require affiliation with a national organization that is not otherwise mandated by state or federal legislation. 

Thus, I support the removal of the CCC requirement.

CommentID: 230142