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.

Alternative Pathway to Licensure

Establishing an alternative pathway to licensure without the CCC is a progressive and necessary step that aligns more effectively with the needs of the profession and the individuals we 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. While the CCC may hold value for some professionals, it should not be the sole pathway to licensure when Virginia’s licensing requirements and continuing education standards already ensure competence and accountability. Its exclusivity creates unnecessary barriers, restricting access to the profession and preventing qualified individuals from entering or remaining in the field—particularly in underserved areas. Implementing alternative pathways will promote greater flexibility and inclusivity while maintaining high professional standards to ensure quality care.

Continuing Education

The proposal to remove the requirement for ASHA-approved CEUs and those of other sanctioned organizations is a commendable and forward-thinking change. 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 Board should consider expanding this proposal section to allow greater flexibility and inclusivity in professional development. Virginia could adopt a model similar to that of Ohio, as outlined in Chapter 4753-4 of the Ohio Administrative Code. Ohio’s approach empowers professionals to engage in self-directed, meaningful continuing education directly relevant to their practice. This model respects the autonomy of licensed professionals to identify the learning opportunities most beneficial for their growth while reducing the board’s administrative burden of pre-approving CEUs.

To ensure accountability, the Board can implement randomized audits to verify compliance with professional development requirements. This system balances the need for professional autonomy with regulatory oversight, fostering a more efficient and impactful approach to continuing education.

Suggestions for Clarity and Implementation

To strengthen these changes, I suggest the following:

1. Expand Acceptable CEU Opportunities: Broaden the scope of eligible continuing education activities to include workshops, independent study, in-service training, research, and interdisciplinary learning. This flexibility allows professionals to pursue diverse, relevant educational experiences without the constraints of restrictive approval processes.

2. Incorporate Supervision as an Eligible Activity: Permit SLPs to count a limited number of hours (e.g., 5 hours) spent supervising students and new graduates toward their CEU requirements. States like Michigan have successfully implemented this practice, incentivizing SLPs with demanding productivity or caseloads to consider supervision. This approach benefits graduate programs by increasing the availability of placement opportunities and gives new clinicians a broader range of mentors to choose from during their initial year of practice. Additionally, it is cost-neutral for the licensing board and fosters collaboration between emerging professionals and experienced clinicians.

3. Streamline Documentation: Simplify the reporting process for CEUs by allowing professionals to sign an attestation form stating that they have met the state's continuing education requirements. They can also independently maintain a log of completed activities and retain certificates of completion to submit only in the event of a randomized audit. This process reduces unnecessary administrative burdens while ensuring compliance.

4. Provide Clear Guidance: Publish a comprehensive list of acceptable CEU activities to prevent misunderstandings about what qualifies. This guidance could include detailed examples and templates modeled after Ohio’s approach, helping professionals confidently plan and document their continuing education efforts.

This proposed framework balances flexibility, accessibility, and accountability, ultimately supporting professional growth while reducing unnecessary administrative hurdles.

Conclusion

In conclusion, the proposed changes represent a pivotal opportunity to modernize licensure and professional development regulations for SLPs in Virginia. By establishing an alternative pathway to licensure without the CCC and expanding the scope of approved continuing education opportunities, the Board can remove unnecessary barriers that hinder accessibility and choice in the profession. These reforms will empower clinicians to pursue meaningful growth, attract more professionals to underserved areas, and reduce administrative burdens for both the Board and practitioners while maintaining the high standards of care that patients deserve.

I strongly urge the Board to adopt these changes and consider the additional recommendations provided to ensure clarity, flexibility, and equitable access to the field. These steps will benefit the current workforce and create a more sustainable and progressive future for the profession.

Thank you for your commitment to advancing the field of SLP in Virginia and for considering these thoughtful revisions to support clinicians and the individuals they serve.

Sincerely,
Amy
Speech-Language Pathologist and Advocate