While I can appreciate the concerns related to CMS billing for provisional licensees, I am uncomfortable with removing the requirement of six months of practice and a recommendation from a supervisor under a provisional license as a path to initial licensure (18VAC30-21-60 - section c). Would it be possible to move the requirement of six months of practice and a recommendation from a supervisor to being a requirement for the initial renewal of a license? Subsequent renewals of the BASLP license would only require that SLPs meet the criteria for continuing education. This would "remove" the provisional license, but keep the requirement for supervision within at least the first year of practice.