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,
Tiffany Rhodes
Speech-Language Pathologist and Advocate