While I commend the board for proposed changes to the CCC requirement, I feel strongly that the proposed changes do not go far enough. There is no reason why a speech-language pathologist should not be able to gain a full, unconditional license from the State of Virginia upon graduation from an accredited school and having passed the Praxis. This is the standard for new physical and occupational therapy graduates and standards for speech therapists should not be any different. 

Limiting the provisional licensure period and eliminating the CCCs will not assist in the two main challenges related to provisional licenses:

1. The standards for credentialling with most commercial and federal payers is directly related to licensure (i.e., speech-language pathologists can't see some patient populations unrestricted because both commercial and federal insurances won't credential them specifically due to the provisional license). This causes excessive administrative and financial burdens on both the provisional licensees and the companies which employ them.
2. Provisional licensees can do anything a fully licensed speech-language pathologist can do as long as certain supervision steps are in place. Unfortunately, this creates a burden on the supervisor involved.  Again, more administrative and financial burdens are created for no reason.

Bottom line, when a new physical therapist graduate comes to work for us, they have no practice limitations. That does not mean we don't mentor, coach, and support their career path. However, we can do so and avoid the regulatory hurdles which pop up when a practicing therapist does not have a full license. 

While I am sure there is a long history of how we got to this convoluted process for gaining full licensure for speech therapists, I do not think this process is practical today. The ultimate beneficiary for this change would not just be new speech grads, it would be an ever-growing population of kids who need speech therapy services but whose interventions/therapy are delayed by a lack of staff who are credentialed to see them.

In closing, I encourage you to go "all the way" and eliminate the provisional license/supervision requirement for full licensure. A simple online search will show elimination of the requirement of supervision and CCC trending occurring in multiple states across the country. As an employer in private practice with close to 35 full time pediatric speech-language pathologists, I can't emphasize how important it is to solve this issue, both for our speech-language pathologists and the patients we serve.

Thanks.

Phil Helman

CEO

Adler Therapy Group

www.adlertherapygroup.com