As Chief Executive Officer and Owner of Adler Therapy Group, a private therapy company located in the Hampton Roads (Virginia) area which employs over 60 speech-language pathologists (SLPs) and provides speech services to close to 1,000 pediatric patients a week, I am writing in support of the petition to eliminate 18VAC30-21-60(A)(2)(c).?  

 Simply put, there is no reason why an SLP in the state of Virginia 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-language pathologists should not be any different.? 

 As the American Speech-Language-Hearing Association (ASHA) itself says: 

 “The scope of practice (evaluation, diagnosis, treatment) for CFs and SLPs is the same whether an individual holds a provisional or a full license.?The primary difference is the title of the license (e.g., provisional).?In addition, for those who are pursuing clinical fellowship, they need to comply with the supervision standards required to obtain the CCC and state licensure.?Therefore, the varied licensure title is largely a distinction without difference and fails to acknowledge that provisional licensees have earned a master’s or doctoral degree and completed supervised clock hours of clinical practicum as required by Medicare and under most state laws.”  

 The Virginia code follows ASHA’s supervision requirements, which boils down to only requiring a half hour of direct and a half hour of indirect supervision per week, resulting in a minimum of thirty-six hours of supervision during the entire nine-month ASHA fellowship process.  While ATG has robust mentorship in place for CFs, the reality is many CFs barely interact with their supervisors and often are not even working in the same building.  The simple fact is that the CF experience is never uniform and varies widely based on the structure of each work environment, and on the discretion of the supervisor involved.  While some CF experiences are great, many are just going through the motion for nine months. 

 This issue is critical for our industry for the following reasons: 

1. The standards for credentialling with most commercial and federal payers are directly related to licensure.?I.e., CFs cannot see some patient populations unrestricted because both commercial and federal insurances, such as MEDICARE and TRICARE, won't credential them with a 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 SLP 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. 

3. PATIENT CARE.?The demand for speech therapy services throughout Virginia is strong. Virginia is currently ranked 42nd in the country in the ratio of SLPs to 100,000 residents (https://www.asha.org/siteassets/surveys/audiologist-and-slp-to-population-ratios-report.pdf). In fact, there are hundreds of children waiting for services across Hampton Roads alone, with some clinics on a six-month to one-year wait list.?We should be doing everything possible to get these children the care they need,and eliminate?obstacles such as provisional licenses and the related red tape of credentialling and supervision that cause many clinics and healthcare systems to refrain from hiring those with provisional licenses.   

Simply put, if insurance carriers won’t credential CFs, they can’t be employed and patients won’t be able to get the services they need.