34 comments
As the chair of the MS Speech-Language Pathology program at Old Dominion University and as a licensed speech-language pathologist, I support the proposed amendment to bring full licensure to our graduates. There is needless complication for new graduates to have two different pathways upon attempting to gain their license. They have completed all academic and professional training once the Masters degree is conferred. This has enormous implications for payors who decline to pay for services provided by a professional who is issued a provisional license.
Thank you for your attention
Anastasia Raymer, CCC-SLP
New graduates should be able to pursue full licensure after graduation from an accredited program and passing the praxis. No additional supervision/probationary period should be required.
As a concerned stakeholder in the field of speech-language pathology, I oppose the proposed removal of Clinical Fellowship (CF) licensure requirements for SLPs in Virginia. While recent Medicare changes have prompted discussion, dismantling CF licensure would have far-reaching and potentially harmful consequences for our profession, our clients, and our state.
1. Threat to Virginia’s Participation in the ASLP-IC (Interstate Compact):
Virginia is a member of the Audiology and Speech-Language Pathology Interstate Compact (ASLP-IC). Removing CF licensure might jeopardize our compliance with compact requirements. This change could isolate Virginia SLPs from national opportunities and reduce access to services for clients in underserved areas. Therefore, more information is needed to determine what, if any impact, there might be on VA's participation in the ASLP-IC.
2. Medicare Changes Affect a Small Subset of SLPs:
The recent Medicare policy shift impacts only a limited number of SLPs. It is disproportionate and shortsighted to overhaul licensure requirements for all SLPs based on a federal billing issue that affects a minority.
3. Ongoing Advocacy and Adaptation Are Already Underway:
Organizations like ASHA, private practices, and healthcare systems are actively working to address the Medicare changes through supervision models and policy advocacy. These efforts demonstrate that we can adapt without dismantling the CF licensure structure that ensures professional accountability and public protection.
4. Long-Term Risks to Workforce Development and Education:
Eliminating CF licensure introduces significant uncertainty into the professional pipeline. It could disrupt graduate program curricula, deter students from enrolling in Virginia programs, and create confusion in the job market. Most importantly, it risks undermining the quality and readiness of new SLPs entering the field, which could ultimately harm the clients we serve.
In conclusion, while we must respond thoughtfully to federal policy changes, removing CF licensure is not the solution. I urge policymakers to preserve this critical step in professional development and maintain Virginia’s commitment to high standards, workforce stability, and interstate collaboration.
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.
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:
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.
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.
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.
The biggest risk we face besides patient care is the risk to the speech therapy profession itself.?Applicants for graduate school will likely decrease after the latest Medicare announcement because potential applicants don’t want to have to deal with the fact that after spending thousands of dollars on a graduate education, their employability is limited by a byzantine set of rules and regulations. We are already facing intense pressure to meet demand.?We need to nurture this profession and avoid anything that might give someone pause as they consider this career.
Bottom line, when a new physical or occupational therapist graduate comes to work for us, they have no limitations on their work and who they can treat.?That does not mean we don't mentor, coach, and support their career path.?However, we can mentor them as any company in any industry does with new hires and graduates and avoid the regulatory hurdles which pop up when a practicing therapist does not have a full license.?
In closing, as listed above, it is clear that the present licensure process for SLPs is no longer practical and needs to be changed. The ultimate beneficiaries for this change would not just be new speech graduates but the ever-growing population of children and adults who need speech therapy services but whose interventions/therapy are delayed by a lack of staff who are credentialed to see them.
I can't emphasize how important it is to solve this issue now, both for our SLPs and the patients we serve. The petition involved is a common sense solution to an important issue and I encourage the board to accept it.
Sincerely,
Philip R. Helman
CEO
Adler Therapy Group
757-647-5517
I am writing to strongly advocate for a change in the current licensure process for Speech-Language Pathologists in our state. Specifically, I urge the board to consider granting full, unrestricted licensure to SLPs immediately upon graduation and successful completion of the Praxis examination—consistent with the licensing practices for other allied health professionals such as physical therapists and occupational therapists.
The current requirement for Clinical Fellowship (CF) licensure, while well-intentioned, no longer accurately reflects the training, competence, or readiness of today’s SLP graduates. By the time a clinician enters the CF year, they have completed extensive supervised clinical hours, passed a nationally standardized exam, and demonstrated their ability to provide independent, evidence-based care.
Yet, outdated regulations continue to classify CFs as needing supervision to perform tasks they are already qualified to do. This creates confusion, billing complications, and barriers to employment—especially in underserved settings where access to fully licensed SLPs is already limited.
Granting full licensure upon graduation would:
Ensure parity with PTs and OTs, who receive unrestricted licenses immediately upon passing their exams.
Streamline billing and credentialing processes for employers and payers.
Reflect the high level of clinical competence and readiness our graduate programs instill.
Support new clinicians without stigmatizing them as “in training” professionals.
Mentorship and professional support can and should continue during the first year of practice, but these supports should not be tied to an unnecessarily restricted license.
Thank you for your time and consideration. I respectfully urge the board to modernize our licensure system and align it with the realities of contemporary SLP education and practice.
Sincerely,
Gianna Cardone, M.S., CF-SLP
To whom it may concern,
As a current speech language pathologist graduate student, my course of study not only include a variety of classes that involve all types of age groups and disorders to be educated about for the profession; but also am required to complete 400 hours of clinical practicum. This means that I am the clinician, under a supervisor, that treats these patients for a number of disorders. I have seen a wide range of children, adults, groups, and much more that I am prepared for in my field of work. Due to this, I am in support for receiving my Certification of Clinical Competence (CCC) after graduation and eliminating the extra year of work under supervision.
Thank you for your time and consideration.
As a bilingual speech-language pathologist, Latina immigrant, and private practice owner in Virginia, I strongly support eliminating the requirement in 18VAC30-21-60(A)(2)(c) that ties licensure to holding the ASHA Certificate of Clinical Competence (CCC). While the CCC is one valuable pathway, it should not be the only one.
Many highly skilled and qualified clinicians—especially those from underrepresented, immigrant, bilingual, and internationally trained backgrounds—face systemic barriers to obtaining the CCC. These barriers are often financial, institutional, or related to accreditation access, not reflective of clinical competence or commitment to ethical, high-quality care.
The additional licensure pathway established by the Board earlier this year opens the door for these professionals to serve communities that are often overlooked, including families who need services in languages other than English or who seek therapists who reflect their cultural values and communication styles. Removing this requirement would increase access to care, support the growing demand for speech therapy across Virginia, and foster a more inclusive, culturally responsive workforce.
As someone who works directly with families who struggle to find providers who understand both language development and cultural nuance, I believe this policy change is essential. It upholds high standards while expanding access, without compromising the quality of services provided.
I urge the Board to consider the broader implications of workforce equity, client access, and community representation, and to allow this more flexible licensure pathway to remain in place.
As a clinician, private practice owner, and advocate for positive change in our field, I strongly support the petition to eliminate the requirement in 18VAC30-21-60(A)(2)(c) that ties licensure to holding the ASHA Certificate of Clinical Competence (CCC). While the CCC is a respected credential, it should not be the sole path to licensure in our state.
This requirement creates unnecessary barriers for highly qualified clinicians who may face challenges accessing the CCC due to financial, institutional, or systemic limitations. The additional pathway established by the Board earlier this year is an equitable step toward meeting Virginia’s growing demand for speech-language services. It broadens access for professionals who are uniquely positioned to serve our communities, and especially reduces bureaucratic barriers contributing to a "funnel effect" for new, but perfectly competent, clinicians entering the field.
This change does not lower standards; it modernizes them. It recognizes that competence, ethical practice, and professional excellence are not limited to those holding one specific credential.
I respectfully urge the Board to retain this licensure flexibility and eliminate the requirement in 18VAC30-21-60(A)(2)(c), allowing our profession to move forward in a more inclusive, responsive, and accessible direction.
Sincerely,
Louise Chamberlin
As a CF Mentor and Lead Therapist, I fully support the resolution to eliminate the provisional license for Clinical Fellows in Virginia. In my role mentoring new graduates, I’ve consistently seen how this extra step—though well-intended—creates more confusion than clarity. Families are often uncertain about what a provisional license means and whether their child is being treated by a “real” speech therapist. I’ve had to explain the CF process multiple times to reassure parents that their child is receiving the same level of care. This confusion can erode trust and create unnecessary barriers between families and therapists.
On the administrative side, the provisional license creates complications with insurance billing, credentialing, and approvals. Each insurance company treats CFs differently, and keeping track of what is and isn’t allowed for each payer adds to the workload of our administrative team. It also leads to delays in getting services started, which ultimately impacts patients.
Our Clinical Fellows are competent and well-prepared. Once they’ve graduated and passed the Praxis, they are fully capable of delivering high-quality care. Aligning our licensure process with other allied health professions would reduce barriers, streamline access to services, and relieve unnecessary burdens from both clinicians and families. Thank you for considering this important step forward for our profession.
Sincerely,
Courtney Judson, M.A., CCC-SLP
As a lead early intervention provider, I supervise and support a variety of clinician, including clinical fellows. In early intervention, our CFs are unable to treat patients with certain insurance types (like Tricare) due to the nature of the provisional license and the nature of travel therapy in early intervention. As clinical fellows have passed all necessary examinations and have a Master's degree, there is no reason that they should not be able to treat any patients who are in need of services. This makes it more difficult for those therapist's to build up their caseloads, especially in certain regions (like Virginia Beach and Norfolk) that have a high population of patients with Tricare insurance. And, ultimately, it give patients less availability of providers in their area. I am in 100% support of new clinicians being able to apply for full licensure upon their graduation.
As a speech-language pathologist serving children and families in Virginia, I strongly support the proposal to eliminate the six-month wait period for obtaining a full, unrestricted license after graduation and passing the Praxis. This unnecessary delay creates significant barriers that negatively impact patient care. Families already face long waitlists for speech therapy, and requiring an additional six-month restriction prolongs access during critical developmental windows, especially for infants and toddlers who need early intervention.
The impact is even greater in rural and underserved areas, such as the Northern Neck, where SLP shortages are already a challenge. This rule discourages new graduates from accepting positions in these communities, further limiting access to essential services. Additionally, the policy places speech-language pathologists at a disadvantage compared to other rehabilitation professionals, such as occupational and physical therapists, who do not face a similar barrier. It also creates a financial burden for families and providers when insurance cannot be billed for CF-SLP services, leaving families to pay out of pocket or forgo therapy altogether.
Removing the six-month waiting period ensures that patients across Virginia receive timely, uninterrupted care from qualified professionals. I urge the Virginia Board to approve this proposal in the best interest of the patients and families we serve.
Sincerely,
Madeline Appleyard, M.S., CCC-SLP
I am writing to strongly advocate for a change in the current licensure process for Speech-Language Pathologists in our state. Specifically, I urge the board to consider granting full, unrestricted licensure to SLPs immediately upon graduation and successful completion of the Praxis examination—consistent with the licensing practices for other allied health professionals such as physical therapists and occupational therapists.
The current requirement for Clinical Fellowship (CF) licensure, while well-intentioned, no longer accurately reflects the training, competence, or readiness of today’s SLP graduates. By the time a clinician enters the CF year, they have completed extensive supervised clinical hours, passed a nationally standardized exam, and demonstrated their ability to provide independent, evidence-based care.
Yet, outdated regulations continue to classify CFs as needing supervision to perform tasks they are already qualified to do. This creates confusion, billing complications, and barriers to employment—especially in underserved settings where access to fully licensed SLPs is already limited.
Granting full licensure upon graduation would:
Ensure parity with PTs and OTs, who receive unrestricted licenses immediately upon passing their exams.
Streamline billing and credentialing processes for employers and payers.
Reflect the high level of clinical competence and readiness our graduate programs instill.
Support new clinicians without stigmatizing them as “in training” professionals.
Mentorship and professional support can and should continue during the first year of practice, but these supports should not be tied to an unnecessarily restricted license.
Thank you for your time and consideration. I respectfully urge the board to modernize our licensure system and align it with the realities of contemporary SLP education and practice.
Sincerely,
Lindasy Hadel, M.S., CCC-SLP
As a pediatric speech-language pathologist in Virginia I strongly support the proposal to eliminate the six-month wait period for obtaining a full, unrestricted license after graduation and passing the Praxis.
This policy imposes unnecessary delays for professionals who are already highly qualified to begin providing care. By the time we graduate from accredited programs, we have completed over 400 supervised clinical hours across a variety of settings and populations. In addition, we have passed two rigorous national exams — the Praxis in Speech-Language Pathology and the comprehensive assessments required by our graduate programs. These experiences thoroughly prepare us to deliver evidence-based services to clients from day one.
The current six-month restriction limits our ability to practice independently, bill insurance, or be fully credentialed, even though we have already met the standards of competency. This delay directly impacts access to care, particularly for families with young children during critical periods of development. Early intervention is time-sensitive, and unnecessary barriers such as this can affect long-term outcomes.
I respectfully urge the Board to approve this change in the best interest of the patients and families we serve.
Sincerely,
Olivia Hampton MS, CCC-SLP
I am in support of eliminating 18VAC30-21-60(A)(2)(c) and allow an applicant to qualify for licensure without holding a Certificate of Clinical Competence from the American Speech-Language-Hearing Assocation (ASHA).
I strongly support the amendment to create an additional pathway for speech-language pathology licensure that does not require completion of the Clinical Fellowship (CF). This important change will expand access to the profession, help address persistent workforce shortages, and make it more feasible for highly qualified professionals to serve in Virginia—especially in rural and underserved communities where access to care is limited.
By removing the CF requirement while still maintaining rigorous academic and clinical training standards through accredited graduate programs, the Board is recognizing the evolving nature of professional preparation in our field. Many states have already modernized their licensure requirements to reflect these trends without compromising public safety or professional quailty.
I commend the Board for taking this thoughtful and forward-looking step and urge continued support for licensure pathways that expand opportunity while maintaining the integrity of the profession
I am an SLP licensed in Virginia and have supervised SLP graduate students, recent graduates, and those seeking advanced certifications over the last 25 years. I fully support the proposed changes to licensure. Our graduates finish 6 years of advanced education meeting a complicated list of competencies, both academic and clinical, as well as completing 400 supervised clinical hours. They have also passed the Praxis exam. These professionals have proven their ability to safely practice. State license is about public protection. The extra hurdle of additional supervision is not necessary and not needed to accomplish the mission of the Board.
I believe it is necessary to reflect on some of the comments that are opposed to these proposed changes. Yes, this issue only affects only a small number of professionals. I wholeheartedly disagree with the notion that if it only effects a few, then we do not need to consider changes as every one of our fully licensed professionals was once on a provisional license. I may not have had the issues with reimbursement since I was licensed well before the 2015 changes to Medicaid; however, we cannot ignore that the supervision period is an antiquated system without data from the Board as to the impact on public protection. Cited data on various message boards are provided by our professional association - ASHA. I understand and appreciate that ASHA is "working on it" in reference to billing and the enforcement of guidelines approved 10 years ago, but we can work on it also by eliminating the unnecessary delay in licensure.
Additionally, I do not believe that considering the impact on the ASLP-IC is warranted at this time. We cannot delay our own interests in Virginia, as our commitment is to our licensed professionals, when there is nothing that is stated in the ASLP-IC that our membership would be impacted by eliminating this requirement. Finally, thank you for your time and consideration to this important matter.
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.
As a licensed speech-language pathologist, I support the proposed amendment to bring full licensure to those who have graduated with a Masters degree and passed the praxis. They have completed all academic and professional training once the Masters degree is conferred, and should have full licensure as occupational therapists and physical therapists do. The current restricted license prevents Virginia patients from accessing a larger pool of qualified SLPs due to certain insurance companies’ credentialing requirements, and should be changed
I want to address some of the concerns brought up around this resolution:
This leads to long waitlists for service members and their families, who are already more likely to slip through the cracks due to needing to navigate through new health systems to find care each time they relocate. This issue impacts both pediatric and adult populations, and with Medicare having put the idea out that provisional licenses/CFs are bad, other insurances may follow suit. If commercial carriers adopt similar language and don’t allow CFs/SLPs with provisional licenses to see patients, CFs/SLPs with provisional licenses will essentially become unemployable.
Simply put, the state of Virginia has the opportunity to set an example for all states that can simplify the licensure process for new speech language pathologists. As 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 proposed petition would make the speech-language pathologist career a better one while providing a licensing process that is in line with that of physical and occupational therapists. Most importantly, it would ensure that patients who need care, can get it consistently.
Josh Adler, OTR/L
Owner, Chief Clinical Officer
Adler Therapy Group
August 7, 2025
Kelli Moss, Executive Director
Board of Audiology and Speech-Language Pathology
9960 Mayland Drive
Suite 300
Henrico, VA 23233
RE: Petition for Rulemaking to Remove Supervised Professional Experience
Dear Ms. Moss:
On behalf of the American Speech-Language-Hearing Association (ASHA), I write to oppose the petition to remove the supervised professional experience required by the Board of Audiology and Speech-Language Pathology to qualify for a speech-language pathologist (SLP) license.
ASHA is the national professional, scientific, and credentialing association for 241,000 members, certificate holders, and affiliates who are audiologists; SLPs; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. SLPs identify, assess, and treat speech, language, swallowing, and cognitive disorders. Over 5,170 ASHA members reside in Virginia.[i]
Recently, the Centers for Medicare & Medicaid Services (CMS) updated Chapter 15 of the Medicare Benefit Policy Manual to revise the definition of a qualified SLP for Part B (outpatient) services. This update recognized only fully licensed SLPs and excluded those with provisional license from enrolling and billing Medicare for outpatient services, which could have threatened access to care for Medicare patients. However, last week CMS notified ASHA it is reversing its previous interpretation[ii]:
“After further review of our prior statement about ‘provisional’ licenses for clinical fellows as well as the CY 2015 Home Health final rule (79 FR 66107), for Part B outpatient services furnished by speech-language pathologists, we now believe that deferring to the state licensure requirements for SLPs in each state would allow them to determine the SLPs that are most appropriate to provide speech-language pathology services to individuals/patients, including Medicare beneficiaries. In other words, to the extent that an SLP complies with the applicable state process for licensure, certification, or registration (if the state has one) necessary to practice as an SLP, which may include provisional or temporary licensure as such individual completes required supervised experience, such individual complies with the applicable licensure requirements found at 1861(ll)(a)(4)(A) of the Social Security Act and 42 CFR 410.62(a), 42 CFR 484.115(n) and Section 230.3 of Ch. 15 of the Medicare Claims Processing Manual.”
The reversal of CMS’ previous interpretation eliminates the need to move forward with this petition for rulemaking.
Additionally, removal of the requirement for a supervised professional experience would put the Commonwealth out of compliance with HB 2033 (2023), which adopted the Audiology & Speech-Language Pathology Interstate Compact (ASLP-IC). Section 54.1-2608 requires that participation in the compact include a “supervised postgraduate professional experience as required by the Commission.” If Virginia were to remove the supervised professional experience, the Commonwealth would likely be found out of compliance and unable to participate in the ASLP-IC.
Thank you for your consideration of ASHA’s position. If you or your staff have any questions, please contact Susan Adams, ASHA’s director of state legislative and regulatory affairs, at sadams@asha.org.
Sincerely,
A. B. Mayfield-Clarke, PhD, CCC-SLP
2025 ASHA President?
[i] American Speech-Language-Hearing Association. (2024). Virginia [Quick Facts]. https://www.asha.org/siteassets/advocacy/state-flyers/virginia-state-flyer.pdf
[ii] American Speech-Language-Hearing Association. (2025, Jul 29). CMS Reverses Its Interpretation of a Qualified SLP: Clinical Fellows Cleared to Bill Medicare. https://www.asha.org/news/2025/cms-reverses-its-interpretation-of-a-qualified-slp-clinical-fellows-cleared-to-bill-medicare/
August 8, 2025
Melissa A. McNichol, Au.D., CCC-A, Chair
And the Virginia Board of Audiology & Speech-Language Pathology
c/o Kelli Moss, Executive Director
RE: Opposition to Petition to Eliminate 18VAC30-21-60(A)(2)(c)
Dear Dr. McNichol and Members of the VABASLP,
I write to you as a licensee and resident of the Commonwealth of Virginia, and as a member of the Speech & Hearing Association of Virginia (SHAV). I am submitting these comments in my individual capacity, not as a representative of any volunteer leadership roles I may currently hold.
Provisional licensure in the Commonwealth was implemented in 2016. This was a landmark accomplishment during my second term serving on the VABASLP. The provisional license was designed to ensure that pre-licensed clinicians could gain additional clinical training while being able to practice and bill under supervision.
I am writing in strong opposition to the petition submitted by the SHAV and Ms. Dorn to eliminate 18VAC30-21-60(A)(2)(c) from the Regulations Governing the Practice of Audiology and Speech-Language Pathology, which currently states:
18VAC30-21-60. Qualifications for initial licensure.
A. The board may grant an initial license to an applicant for licensure in audiology or speech-language pathology who:
1. Holds a current and unrestricted Certificate of Clinical Competence issued by ASHA; or
2. Submits evidence of the following:
a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body recognized by the board;
b. Passage of the qualifying examination from an accrediting body recognized by the board; and
c. Evidence of six months of practice pursuant to a provisional license as described in 18VAC30-21-70 and submission of recommendation for licensure from the applicant's supervisor during practice as a provisional licensee.
This petition by SHAV is short-sighted, unjustified, and detrimental to public protection. The petition was prompted in response to CMS (Centers for Medicare & Medicaid Services) clarification of language disseminated in June 2025, indicating that individuals with provisional licensure, such as Clinical Fellows, would no longer be able to engage with Medicare enrollees, bill for services or be reimbursed. This was disappointing and frustrating. However, CMS since reversed course on July 29, 2025. https://www.asha.org/news/2025/cms-reverses-its-interpretation-of-a-qualified-slp-clinical-fellows-cleared-to-bill-medicare/?srsltid=AfmBOopwFXgIaboznqfSvV_BNXSrWoWxsn-8DP8fasY_4Lf7Ov6f72P0
“In direct correspondence with ASHA, CMS clarified that its updated interpretation aligns with state licensing requirements and allows individuals holding provisional or temporary licenses, such as CFs, to provide services to Medicare beneficiaries—provided they meet their respective state’s licensure requirements.”
With this reversal, the original impetus for the petition is no longer valid.
More concerning, however, is that the petition offers no compelling rationale for lowering the threshold for full licensure. Licensure exists to protect the constituents of the Commonwealth, providing for public safety and consumer protection. It provides the minimal standards for practice in the state and sets legal recourse for individuals who have been harmed by those who have misrepresented their credentials or who have not provided services that meet the standards imposed by licensing bodies. It is a public-safety measure. Weakening these standards undermines public trust in licensed healthcare professionals. Licensing is mandatory.
The fundamental education and training for licensed and certified Speech-Language Pathologists requires completion of the mentored post-graduate clinical experience following graduation from a CAA accredited program. This is a critical, structured, mentored professional experience to transition between being a student enrolled in a communication sciences and disorders (CSD) program and being an independent provider of speech-language pathology clinical services. The purpose of this experience is to integrate and apply the knowledge from academic education and clinical training, evaluate strengths and identify limitations, develop and refine clinical skills consistent with the Scope of Practice in Speech-Language Pathology, strengthen clinical reasoning and decision making, and advance the clinician from needing constant supervision to being an independent practitioner. The petition disregards the significance of this supervised transition and effectively proposes its elimination—without addressing the impact on quality of care, patient outcomes, or professional readiness.
Moreover, the petition fails to consider other categories of professionals who benefit from provisional licensure, including those:
The mentored post-graduate clinical experience is an integral part of preparing entry-level clinicians for full licensure, certification and a successful career of competence. The clinical experience of the graduate training programs is insufficient currently for an individual to graduate and expect to be practicing without additional guidance. Eliminating this step would risk placing inadequately prepared clinicians into unsupervised roles, weakening the foundation of consumer protections imbedded in Virginia licensure laws.
Furthermore, any proposal to eliminate provisional licensure must be evaluated in the broader context of educational reform. Graduate training programs would need guidance and time to adjust. Efforts are currently underway at the national level to transition to emphasis on competency-based training v. hour-based requirements, but that will take time, collaboration and systemic adjustment. Premature regulatory changes would jeopardize the readiness of new clinicians and compromise care delivery.
Eliminating provisional licensure would also increase the administrative burden on the Virginia Board of Audiology and Speech-Language Pathology (VABASLP), as staff would need to verify all credentialing elements for every applicant—likely requiring additional budget and staffing with no added benefit to patients or consumers. Also, would want to consider impacts to participation with Medicaid, of which I am less knowledgeable.
In conclusion, the removal of 18VAC30-21-60(A)(2)(c) is ill-advised, unjustified, and risky. The current standard ensures adequate preparation, supervision, and public protection. I respectfully urge the Board to reject this petition.
Most sincerely,
Laura Purcell Verdun, M.A., CCC/SLP, ASHA Fellow
VABASLP 2010-2014, 2014-2018
VABHP 2014-2015, 2015-2019
As a licensee and member of SHAV and ASHA who has been in practice for over fifteen years as both an SLP and a Nursing Home Administrator I am writing in strong support of the petition to remove the Clinical Fellowship Year requirement for licensure for Speech-Language Pathologists in Virginia and in so doing provide them with the same full and unrestricted licensure status which is immediately accorded to new graduate colleagues in the fields of Occupational and Physical Therapy. The current requirement for the clinical fellowship year unnecessarily restricts new graduates who have successfully completed their graduate level studies, earned at minimum the required 400 clinical clock hours to obtain their competencies, and have successfully passed the PRAXIS examination. The CFY requirement further reduces their earning potential as well as their ability to secure employment if a supervisor is not available.
Additionally, I have had the pleasure of being a graduate clinician externship supervisor and a CFY supervisor and have been consistently impressed at the degree of knowledge, critical thinking skills, experience and integrity which the students have acquired during their program of study. I believe that there remains an opportunity for seasoned SLPs to mentor newly licensed SLPs, but the Clinical Fellowship requirement itself has been shown to be unnecessarily limiting and should be removed. For those reasons I fully support this petition.
Respectfully,
Janet C. Bunnell, MS CCC/SLP, LNHA
Kelli Moss, Executive Director
Board of Audiology and Speech-Language Pathology
9960 Mayland Drive
Suite 300
Henrico, VA 23233
RE: Removal of Supervised Professional Experience
Dear Ms. Moss:
I am reaching out on behalf of the Audiology and Speech-Language Pathology Interstate Compact (ASLP-IC) Commission. It has come to our attention that Virginia is engaging in rulemaking in consideration of removing the requirement for the supervised professional experience as required by Section 3 (F)(3) of the Model Legislation, as adopted in Virginia through HB 2033 (2023). As compacts are contracts between states, all compact member states must agree to and adopt the same material terms for compact participation.
The removal of the requirement for supervised professional experience would render Virginia non-compliant with the requirements of member state participation in the ASLP-IC. In turn, practitioners who have not undergone post-graduate supervised professional experience would not have a license that rendered them eligible to participate in the Compact.
If you or your staff have any questions, please contact me at nkalfas@compactlegalcounsel.org.
Sincerely,
Nahale Kalfas, Esq.
General Counsel
Audiology and Speech-Language Pathology Interstate Compact Commission
Subject: Opposition to Petition to Eliminate Provisional Licensure Requirement (18VAC30-21-60(A)(2)(c))
Dear Dr. McNichol and Members of the Virginia Board of Audiology and Speech-Language Pathology,
I write as a licensed speech-language pathologist and Virginia resident, submitting these comments in my individual capacity and not representing any leadership roles I may hold.
I strongly oppose the petition submitted to eliminate section 18VAC30-21-60(A)(2)(c) of the licensure regulations, which requires six months of supervised practice under a provisional license and a supervisor’s recommendation for full licensure.
My reasons for opposing the petition are that:
In conclusion, I urge the Board to reject the petition. Maintaining 18VAC30-21-60(A)(2)(c) is essential for ensuring adequate training, supervision, and public protection.
Respectfully,
Carol C Dudding, PhD CCC-SLP
James Madison University
References
[1] 18VAC30-21-60. Qualifications for initial licensure. - Virginia Law
[2] CMS Reverses Its Interpretation of a Qualified SLP: Clinical Fellows ...
[3] Virginia Regulatory Town Hall View Comments
I am in support of eliminating 18VAC30-21-60(A)(2)(c) and allow an applicant to qualify for licensure without holding a Certificate of Clinical Competence from the American Speech-Language-Hearing Assocation (ASHA). SLPs deserve a full, unrestricted license following graduation from graduate school and passing the praxis. The clinical fellowship only restricts employment opportunities and hinders children from receiving speech therapy services.
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 a passing score on the Praxis. This is the standard for new physical therapy and occupational therapy graduates. Standards for speech-language pathologists should not be any different. The provisional license given to SLP graduates puts our profession at a disadvantage and causes issues for healthcare businesses in the Commonwealth. It is costly to provide CF supervision, CFs are now limited in what insurances they can treat and bill, and there is already a shortage of SLPs in the state and nation.
Please do away with the provisional license for SLP graduates and allow full licensure!
I am a licensed SLP in VA with 20 years experience working in pediatrics. I am in full support of the petition to eliminate 18VAC30-21-60(A)(2)(c). This requirement creates barriers that are unnecessary and negatively impact not only new graduates, but the children and families we serve. Something that no one has mentioned it that often times, recent graduates are given a lower wage during this supervisory period. It's hard enough to make ends meet with prices for every day essentials on the rise. This also negatively impacts insurance reimbursement, which then limits job opportunities. With fewer therapists available who can bill insurance, wait-lists are created that can be long. Additionally, this proposal does not impact the Interstate Compact.
To the Virginia Board of Audiology and Speech-Language Pathology:
My name is Jeanette Benigas, PhD, SLP, founder and CEO of Fix SLP, a national grassroots advocacy organization advancing evidence-based reforms that improve access to care, build sustainable career pathways, and expand professional autonomy for speech-language pathologists. My advocacy and leadership have helped modernize licensure and credentialing policies in multiple states, balancing public protection while empowering clinicians to make informed choices about licensure and third-party certifications. I am a former full professor with two decades of experience as a clinician, academic, national public speaker, author, continuing education provider, and business owner. That cross-sector experience lets me see how licensure rules land on patients, payers, employers, and early-career clinicians, and it informs the practical, Compact-compliant amendments I’m urging the Board to adopt.
I support the petition, only with targeted amendments that preserve patient protection, prevent payer denials, and keep Virginia compliant with the Audiology & Speech-Language Pathology Interstate Compact (ASLP-IC). Approval of the petition with these amendments grants full licensure at graduation, replaces supervision with structured first-year mentored CE, and keeps Virginia ASLP-IC compliant.
While CMS has reversed its June 2025 interpretation, systemic payer barriers remain. TRICARE has a longstanding practice of not credentialing or reimbursing conditionally licensed SLPs, and employers report that Palmetto GBA, Virginia’s Medicare Administrative Contractor (MAC), has inconsistently refused to credential conditionally licensed providers over the last several years. These gaps create denials and delays despite state licensure. Without explicit state action, full licensure at graduation paired with a Board-defined, Compact-compliant first-year mentored CE requirement, payers will continue to treat early-career clinicians as “conditional.” Absent clarity, similar tactics may spread to commercial plans (e.g., Blue Cross Blue Shield plans, UnitedHealth Group) to avoid reimbursement.
Note on PT/OT comparisons: While some commenters cite physical therapy and occupational therapy models, those professions follow clinical-doctorate pathways with substantially longer training timelines and supervised hours. Virginia does not need to import those frameworks to protect the public. An SLP-specific solution, full licensure at graduation paired with a Board-defined, Compact-compliant first-year mentored CE requirement (MPDH), better fits our current education model, workforce needs, and ASLP-IC obligations.
I propose the following targeted amendments as a starting point for the Board to refine and adopt:
ASLP-IC Compliance
To maintain participation in the ASLP-IC:
Implementation Considerations
In closing, this amended approach maintains the elimination of 18VAC30-21-60(A)(2)(c), as proposed, protects patients, improves early-career support, avoids payer confusion, may increase early-career compensation, and preserves interstate mobility. I respectfully urge the Board to approve the petition with these or similar amendments and adopt Mentored Professional Development Hours (MPDH) as Virginia’s first-year, structured, competency-based CE requirement.
If you or the Board have any questions, I can be reached at team@fixslp.com.
Respectfully submitted,
Jeanette Benigas, PhD, SLP
Founder & CEO, Fix SLP
As a licensed speech-language pathologist, I am in support of the proposed amendment to bring full licensure to recent SLP graduates in Virginia. SLPs complete at least 375 hours of supervised, direct patient care during graduate school, hold a Master's degree, and pass a Praxis exam. Occupational therapists require a Mater's degree and do not require a provisional license to treat upon graduation and the standards for SLPs should not be different. A provisional license limits what insurances that SLP can bill and reduces the options that families have regarding their care.
Dear Dr. McNichol and Members of the Virginia Board of Audiology and Speech-Language Pathology,
I write as a licensed speech-language pathologist and Virginia resident, submitting these comments in my individual capacity and not representing any leadership roles I may hold.
I strongly oppose the petition submitted to eliminate section 18VAC30-21-60(A)(2)(c) of the licensure regulations, requiring six months of supervised practice under a provisional license and a supervisor’s recommendation for full licensure.
My reasons for opposing the petition are that:
In conclusion, please reject the petition. Maintaining 18VAC30-21-60(A)(2)(c) is essential for ensuring adequate training, supervision, and public protection.
Respectfully,
Jane C. Hilton, Ph.D., CCC-SLP
CMS’s recent reversal of its interpretation of Clinical Fellows (CFs) should have no effect on the pending resolution for the following reasons:
Here is the issue in a nutshell:
In its own words, ASHA has said this about CFs: “The scope of practice (evaluation, diagnosis, treatment) for CFs and SLPs is the same whether an individual holds a provisional or a full license……Therefore, the varied licensure title is largely a distinction without difference….”
Thus, we have to ask the question if a CF (Provisional License) and someone with their CCCs (Full License) in the State of Virginia all can do the same things as practitioners, why don’t they have the same license??? The answer is that they should.
Pro CF provisional license advocates claim that SLP graduates need more clinical hours to augment their training. However, the current CF process as outlined by ASHA only requires one hour a week (a total of 36 hours over nine months) of supervision, with only 30 minutes per week (a total of 18 hours over 9 months) requiring actual observation of therapy. Up to 6 hours can be completed in one day, with some CFs going months without seeing or hearing from their CF supervisor. Simply put, 36 hours over nine months is not worth the administrative burden involved and has minimal impact on the new graduate’s development.
We can all speculate about the reasons why ASHA and other legacy advocates are holding onto this outdated model, but the bottom line is that the ones who suffer are the patients who can’t receive timely care.
Here are the facts:
Here is a note from ASHA itself: “Please note. Some private payers and state Medicaid programs do not recognize provisional licensure as meeting their personnel standards for billing purposes. ASHA members should always verify billing and supervision requirements with each payer individually.” I can’t think of any other national medical organization with such a disclaimer about a class of professionals.
For Virginia, and our large military population, TRICARE does not allow CFs to see active military members or their beneficiaries, thus these patients can only be seen by those with their CCCs. This has a huge impact on our day-to-day operation with the Norfolk Naval Base being the largest in our country along with numerous other military institutions in our area and state.
Virginia Medicaid considers CFs to be “assistants”, and the supervision requirements are much stricter than the state code. This means that if a CF has 50 Medicaid patients on their caseload, I have to pay a CF SUPERVISOR to jointly see each patient with the CF once a month. Thus, I am paying two therapists to do one job……our margins are small, and reimbursements are decreasing. This makes no sense, but we have to comply with Medicaid’s rules.
Here are some other myths that I have read from opposition to the resolution:
The ironic thing about ASHA’s opposition to this resolution is that they are resisting a solution to a problem they created….creating a class of professionals (CFs) whose ability to practice is interpreted and defined differently amongst every national regulatory agency (e.g., Medicare vs. TRICARE), state insurances such as Medicaid, private insurance companies, state boards, private practice, etc. Simply put, this process no longer makes sense, and the Virginia Board of Audiology and Speech-Language Pathology can provide a solution for our state and others to follow.
The board identified licensure issues when it implemented the new six-month window to apply for full licensure earlier this year. I urge it to now go all the way and implement this common sense resolution to eliminate 18VAC30-21-60(A)(2)(c) so that the patients in Virginia in need of care can get it in a timely manner.
Philip Helman
CEO
Adler Therapy Group
I am a licensed SLP and resident in Virginia, and I am writing in support of the removal of 18VAC30-21-60(A)(2)(c). Moving forward with conveying full SLP licensure in Virginia to those who earn a Master’s degree in speech-language pathology/communication disorders and pass the Praxis is the next step in aligning the profession with current needs.
SLPs who have surpassed these two hurdles (which include acquiring a multitude of clinical care hours with a diverse patient base) are well-prepared for the next step of entering the workforce to provide quality care to patients in need. Requiring an on-paper mentorship, the way it is set up now, is not conducive to improving quality of care, nor growth of the clinician’s skills. Removing mandated mentorship will allow for a better balance between providing quality patient care, and encouraging the seeking out of new information for the purpose of providing quality care.
To ensure this, I support extending the current continuing education requirements that exist for all license renewals after the initial renewal, to also include SLPs within their first year of licensure/first renewal. This is a win-win solution to increase quality and availability of care for patients overall.
Virginia must not be afraid to do something different, and instead must be willing to turn the tide when the time is right.
Thank you,
Kathleen Wido, MS Ed., CCC-SLP
I am a speech-language pathologist providing speech therapy services in an outpatient clinic in the state of Virginia, and am in favor of revoking Virginia 18VAC30-21-60(A)(2)(c), adopted by the Virginia State Board in earlier this year.
I believe that graduates of Speech-Language Pathology/Communication Science Disorders programs who have passed the PRAXIS examination in Virginia have attained an appropriate level of study and clinical experience to competently provide therapy services across a wide range of communication disorders.
Requiring CFs to wait six months before they can receive full licensure hinders their ability to provide speech therapy services to patients waiting for treatment. While timely diagnosis and treatment correlates with more favorable patient outcomes, those forced to remain on waitlists due to the shortage of SLPs are surely at a disadvantage.
Therefore, I fully support the pending resolution being considered by the Virginia Board of Audiology and Speech-Language Pathology to eliminate the six-month waiting period for Clinical Fellows to obtain full, unrestricted licensure in the state of Virginia.