I am writing in strong support of the proposed changes to speech-language pathology licensure in Virginia.

Although graduates of speech-language pathology programs complete rigorous academic and clinical training comparable to other allied health professionals (e.g.,  physical therapists and occupational therapists) current licensure requirements impose additional burdens that are not aligned with these peer professions. The unnecessary barriers may delay the attainment of full licensure and, more importantly, limit access to care for individuals who need speech and language services. Given that the primary purpose of licensure is to protect the public, policies that inadvertently reduce access to qualified clinicians run counter to that mission.

Some comments have suggested that recent CMS changes will have a minimal impact. However, these assertions are speculative. To date, no formal assessment has been conducted within Virginia to evaluate how these changes affect consumers or the workforce. Without state-level data, we cannot accurately determine the scope of the impact. National data from the American Speech-Language-Hearing Association (ASHA) indicate that approximately 44% of speech-language pathologists work in medical settings, suggesting nearly half of recent graduates may be directly affected by the CMS changes.

While I acknowledge and appreciate ASHA's national advocacy efforts, it is imperative that Virginia independently evaluate and address the needs of its own residents. Consumer protection and workforce sustainability in our state should not be contingent upon national organizations.

Additionally, I urge the Board to defer consideration of the Audiology & Speech-Language Pathology Interstate Compact (ASLP-IC) until its policies regarding postgraduate supervision are clearly defined. An inquiry to the ASLP-IC Committee confirmed that these regulations are still under development. When finalized, the needs of both consumers and clinicians must take precedence over political or financial motivations.

Thank you for your attention to this important issue. I respectfully encourage the Board to move forward with the proposed licensure changes in support of improved access to care and workforce development in Virginia.