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.

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.

ASHA is a private organization and state (governmental) licensure to practice should NEVER been tethered to a private organization. SLPs in the schools and in the private sector are doing the same job, and school SLPs are NOT currently required to hold a CCC in order to practice in the schools, whereas those outside of the public school sector are required to choose one of two pathways, one of which indeed IS the CCC. Many professionals continue to maintain the CCC even when it provides no tangible benefit to their practice or the communities they serve. This creates a recurring financial burden, with annual fees of $250 or greater, which can disproportionately impact private practitioners, school-based SLPs, or those no longer engaged in clinical practice in the field. For many, the decision to keep the certification is driven more by habit or perceived necessity rather than actual professional value, perpetuating a system that benefits the certifying organization FAR more than the individual practitioner. 

All SLPs share a commitment to ethical practice, evidence-based care, and excellence in service—values that extend far beyond any specific credential. By eliminating the CCC requirement, Virginia can align with other states, reduce unnecessary financial and professional barriers, and create a more inclusive and accessible profession while preserving the high standards that define our field.

I urge the regulatory body to accept the proposed changes related to removal of the requirement for speech-language pathologists to hold a certification of clinical competence from ASHA and repealing the prohibiting conduct section. I strongly support the removal of a distinction between school-based and other speech-language pathologists regarding licensure requirements and fees. These changes will foster a more inclusive, effective, and equitable profession for all speech-language pathologists in Virginia. Thank you for your time and consideration. 

Sincerely,

Christine Brandel, M.S., SLP, Virginia licensed speech-language pathologist