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]
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7/17/25  11:28 pm
Commenter: Courtney Judson

Support of Removing the Provisional License Requirement
 

As a CF Mentor and Lead Therapist, I fully support the resolution to eliminate the provisional license for Clinical Fellows in Virginia. In my role mentoring new graduates, I’ve consistently seen how this extra step—though well-intended—creates more confusion than clarity. Families are often uncertain about what a provisional license means and whether their child is being treated by a “real” speech therapist. I’ve had to explain the CF process multiple times to reassure parents that their child is receiving the same level of care. This confusion can erode trust and create unnecessary barriers between families and therapists.

On the administrative side, the provisional license creates complications with insurance billing, credentialing, and approvals. Each insurance company treats CFs differently, and keeping track of what is and isn’t allowed for each payer adds to the workload of our administrative team. It also leads to delays in getting services started, which ultimately impacts patients.

Our Clinical Fellows are competent and well-prepared. Once they’ve graduated and passed the Praxis, they are fully capable of delivering high-quality care. Aligning our licensure process with other allied health professions would reduce barriers, streamline access to services, and relieve unnecessary burdens from both clinicians and families. Thank you for considering this important step forward for our profession.

Sincerely,
Courtney Judson, M.A., CCC-SLP

CommentID: 236976