It is essential to remove the CCC (Certificate of Clinical Competence) requirement from the speech-language pathology licensing process in Virginia. States such as California, New York, Florida, Texas, and Pennsylvania have shown that the CCC is not necessary to ensure professional competence or public safety. These states rely on robust licensing standards, including accredited education, supervised clinical hours, and passing the Praxis exam, proving that professionals can meet high-quality standards without mandatory certification from a professional organization.

Many professionals continue to maintain the CCC even when it provides no tangible benefit to their practice or the communities they serve. This creates a recurring financial burden, with annual fees of $250, which can disproportionately impact private practitioners, school-based SLPs, or those no longer active in the field. For many, the decision to keep the certification is driven more by habit or perceived necessity rather than actual professional value, perpetuating a system that benefits the certifying organization more than the individual practitioner.

All SLPs share a commitment to ethical practice, evidence-based care, and excellence in service—values that extend far beyond any specific credential. By eliminating the CCC requirement, Virginia can align with other states, reduce unnecessary financial and professional barriers, and create a more inclusive and accessible profession while preserving the high standards that define our field.

I am writing in strong support of the proposed changes to remove the Certificate of Clinical Competency (CCC) requirement for initial licensure in Virginia.

The state license is sufficient to ensure that SLPs meet the educational and clinical requirements necessary to provide high-quality services. In fact, the state licensing process already includes robust standards that align with the qualifications evaluated by the CCC. By maintaining a focus on state licensure alone, we can remove unnecessary barriers that currently hold back our profession and limit access to care for our clients.

The CCC is a redundant and costly product that adds no additional value to an already comprehensive licensure process. Requiring the CCC for initial licensure creates an artificial bottleneck in our field, preventing many capable and qualified professionals from entering the workforce. This restriction is particularly concerning given the ongoing shortage of SLPs, especially in underserved and rural areas.

Access to care is a fundamental right for individuals with communication and swallowing needs, and these changes will open the door for many more licensed SLPs to serve our communities. Removing the CCC requirement will allow highly trained professionals to begin their careers sooner, increase the availability of services, and reduce wait times for patients who need our support.

I urge the Board to move forward with these changes and eliminate this unnecessary hurdle. By doing so, we can improve access to care for Virginians and ensure that the focus remains on the skills and qualifications that truly matter for our profession.

I am writing to provide feedback on the proposed changes to the speech-language pathology (SLP) licensing regulations in Virginia. As a professional committed to upholding the highest standards of care, I support the following positions and respectfully offer these considerations: 

Continuing the Requirement for the Certificate of Clinical Competence (CCC):
Maintaining the CCC as a licensure requirement is essential to ensuring that practitioners meet rigorous standards of knowledge and competency. This certification reflects a commitment to evidence-based practice, advanced clinical skills, and ongoing professional development, which are critical when working with vulnerable populations. Additionally, the CCC serves as the only mechanism for reporting ethics violations, as, to my knowledge, no such channel currently exists within Virginia’s licensing regulations. This oversight role mitigates, to some extent, the risk of predatory "treatments" such as "Spelling to Communicate" and "Rapid Prompting Method" being implemented with individuals in need of ethically informed and evidence-based therapy. The CCC thus not only ensures clinical excellence but also upholds the ethical standards necessary to protect our constituents.

Revising Continuing Education Requirements:
While I strongly support the need for ongoing professional education, I agree with removing the mandate that CEUs must be ASHA-approved. Broadening the scope of acceptable CEU providers would reduce financial and logistical burdens on practitioners while maintaining high-quality professional development. Recognizing diverse sources of continuing education, provided they align with evidence-based and ethical practices, will foster greater accessibility and innovation in professional learning as well as fostering interprofessional practice.

Upholding Strong Regulatory Standards:
SLPs serve some of the most vulnerable individuals in our communities, and it is essential to maintain a licensing framework that reflects the highest levels of professional accountability and clinical excellence. Strict licensure requirements ensure public trust, uphold the integrity of the field, and guarantee that practitioners possess the necessary qualifications to deliver safe and effective services.

Opposing the Distinction Between School-Based and Other Speech-Language Pathologists:
The distinction made between school-based SLPs and other SLPs, particularly regarding application and renewal fees and licensing requirements is bothersome. Speech-language pathology is a highly specialized field requiring advanced training and expertise, regardless of the professional setting. The reality is that many school-based SLPs do (and often NEED to) also work in other settings and thus would need to hold two distinct licenses to practice in VA. Differentiating fee structures and requirements based on the setting of employment creates unnecessary barriers and disparities among practitioners. All licensed SLPs should be held to the same standards and subject to consistent licensing procedures, regardless of whether they practice in schools, clinics, hospitals, or other environments. Equity in licensing is essential to uphold the integrity of our profession and ensure that all practitioners are treated fairly. 

Repealing Restrictions on School-Based Speech-Language Pathologists Practicing Outside Public Schools:
The section on prohibited conduct that restricts school-based SLPs from practicing outside the public-school setting should be repealed. Limiting the professional scope of school-based SLPs in this way is unjustified and does not align with the realities of our profession. If all licensed SLPs are held to the same licensing and renewal standards, there should be no restrictions on their ability to practice outside of the public-school environment. Such limitations are arbitrary and fail to reflect the breadth of training and expertise that SLPs possess. Removing this prohibition would not only promote flexibility and opportunity for school-based SLPs but also enhance access to critical services in other settings where their skills are urgently needed.

By addressing these concerns, the Board has an opportunity to strengthen the licensing framework and support the advancement of the profession in Virginia. I appreciate your dedication to revisiting these standards and respectfully urge consideration of these points.

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,
Jeanette Benigas, Ph.D./SLP
Fix SLP, Owener and Operations Director

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.

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.

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.

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.

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,
Nicole Terado
Speech-Language Pathologist

I am an SLP practicing in Virginia, and am writing to you 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.

Thank you, 

Katie Hundertmark, MS SLP

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.

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.

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. 

Considering professional development/CEU requirements,  ASHA approved CEUs provide barriers for SLPs due to increased costs and less availability. CEUs are more accessible and affordable from other sources. 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 reduction of redundant requirements will enhance accessibility to the field of speech-language pathology (SLP) and reducing unnecessary barriers for professionals and those they serve. This directly supports the increasing need for recruitment and retainment of SLPs in Virginia schools. The need for school based SLPs is at a critical level. When schools are not fully staffed, students do not recieve services. 

In summary, I strongly support this regulatory action. The reduction of "redundant and unnecessary" in any situation is a postitive step forward. 

Sincerely,

Janine Thompson, SLP

I am writing to provide feedback on the proposed changes to the speech-language pathology licensing regulations in Virginia. 

Frist, I would like to see a continued requirement for the Certificate of Clinical Competence (CCC). Maintaining our CCC's as a license requirement is essential to ensuring that all practicing SLP's uphold their standard of knowledge and competency in our field. The CCC's certification demonstrates each SLP's dedication to providing evidence based therapy, upholding their clinical skills and remaining up to date with our ever changing field. The certificate of clinical competence also serves at the only mechanism for reported ethics violations in Virginia. We need to uphold this ethical standard for all practitioners. 

Second, I agree and support the need for ongoing professional education. I believe that maintaining ASHA- approved continuing education is vital for consistency as well as credibility across the field of speech pathology. I also believe that we need to uphold this standard as it demonstrates our competence in this field. 

Third, I strongly oppose the distinction between school-based and other speech-language pathologists. Differentiation of fee's between settings of employment creates barriers across our profession. Many SLP's work in two settings and if this proposition passes many SLP's would need two licenses within one state. We need to hold all SLP's to the same standards. The section on prohibited conduct that restricts school-based SLPs from practicing outside the public school setting should be repealed. 

Thank you for your dedication to reviewing these standard. I urge consideration to the above points. Thank you. 

I am in full support to drop the Virginia state requirement to obtain and maintain ASHA's Certificate of Clinical Competence (CCC) for licensure. The CCC does not standardize or guarantee mentorship within evidence-based practice, which is harmful for clinical fellows. The CCC is expensive to maintain and requires continuing education units which are not required to be vetted or align with up-to-date evidence-based practices. 

As was the aim of my petition submitted on November 29, 2022 (See BASLP records) (which was not voted upon due to, at the time, recent legislation enacting the Commonwealth's participation in ASLP Compact and its subsequent unknown requirements), I continue to support complete dissociation of the Board's licensure requirement from the American Speech-Language Hearing Association (ASHA), including the requirement that initial (and renewing) licensees hold a Certificate of Clinical Competence (CCC), as well as any requirement from the Board demanding that ASHA CEUs be used for continuing education (for licensure renewal, etc.).  While an alternate pathway to the CCC is acceptable to me, removing the CCC altogether is preferred, given that (1) ASHA is a private organization and state (governmental) licensure to practice should NEVER been tethered to a private organization, and (2) SLPs in the schools and in the private sector are doing the same job, and school SLPs are NOT currently required to hold a CCC in order to practice in the schools, whereas those outside of the public school sector are required to choose one of two pathways, one of which indeed IS the CCC.  Untether, altogether.           The contents of the letter I received dated March 14, 2023 with the board's decision regarding my petition are as follows:

"The Board of Audiology & Speech-Language Pathology considered your petition for rulemaking at its March 14, 2023, meeting. The Board decided to take no action on the petition due to the recent passage of legislation entering Virginia into the ASLP Compact. The requirements of the Compact are unknown, and the Board declined to begin a regulatory process related to licensure requirements prior to the Compact determining and communicating requirements for licensure in member states.  Thank you for your interest in the Board and the regulatory process in Virginia."

I hope the board will take into consideration that having ASHA certification as a requirement for Virginia licensure is redundant and unnecessarily costly. Licensure already requires that we complete 10 hours of continuing education per year along with the prerequisite to initial licensure which includes, among other things, qualifying level of education and guarantee to follow ethical standards of practice. Thank you for your consideration. 

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,
Kyleigh Martin
Speech-Language Pathologist and Advocate

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.

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.

ASHA is a private organization and state (governmental) licensure to practice should NEVER been tethered to a private organization. SLPs in the schools and in the private sector are doing the same job, and school SLPs are NOT currently required to hold a CCC in order to practice in the schools, whereas those outside of the public school sector are required to choose one of two pathways, one of which indeed IS the CCC. Many professionals continue to maintain the CCC even when it provides no tangible benefit to their practice or the communities they serve. This creates a recurring financial burden, with annual fees of $250 or greater, which can disproportionately impact private practitioners, school-based SLPs, or those no longer engaged in clinical practice in the field. For many, the decision to keep the certification is driven more by habit or perceived necessity rather than actual professional value, perpetuating a system that benefits the certifying organization FAR more than the individual practitioner. 

All SLPs share a commitment to ethical practice, evidence-based care, and excellence in service—values that extend far beyond any specific credential. By eliminating the CCC requirement, Virginia can align with other states, reduce unnecessary financial and professional barriers, and create a more inclusive and accessible profession while preserving the high standards that define our field.

I urge the regulatory body to accept the proposed changes related to removal of the requirement for speech-language pathologists to hold a certification of clinical competence from ASHA and repealing the prohibiting conduct section. I strongly support the removal of a distinction between school-based and other speech-language pathologists regarding licensure requirements and fees. These changes will foster a more inclusive, effective, and equitable profession for all speech-language pathologists in Virginia. Thank you for your time and consideration. 

Sincerely,

Christine Brandel, M.S., SLP, Virginia licensed speech-language pathologist

As a licensed and ASHA certified SLP in Virginia for 25 years, I am writing in strong support of the proposed changes to the Virginia Board of Audiology and Speech-Language Pathology regulations 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.  Our state licensure should not rely on our national professional organization.  Other professions in Virginia such as OT and PT are not tied to their national professional organization to maintain their state licensure in the same way that the SLPs are currently.

The CCC should be voluntary and ASHA states it is voluntary, but it is not if you practice in Virginia. The cost to maintain my CCC over the past 25 years, when I have only ever practiced in Virginia, is well over $5000.  That cost is in addition to the costs I pay to maintain my state license. Maintaining my CCC has done nothing to assist with public protection, the goal of the BASLP, as I have always completed my 10 hours of CE per year per state licensing guidelines.  By eliminating the CCC requirement, Virginia can align with other states and reduce unnecessary financial barriers.

I ask that the Board of Audiology and Speech-Language Pathology accept the proposed changes related to removal of the requirement for speech-language pathologists to hold the CCC from ASHA. Also, I strongly support the removal of a distinction between school-based and other speech-language pathologists regarding licensure requirements and fees. 

I support the removal of the CCC requirement for initial licensure in Virginia. 

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).

Establishing an alternative pathway to licensure without the CCC is a 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.

The proposed change represents a pivotal opportunity to modernize licensure for SLPs in Virginia. By establishing an alternative pathway to licensure without the CCC, 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 this change and remove the ASHA CCC requirement for state licensure. Thank you for your commitment to advancing the field of SLP in Virginia.

Sincerely,
Anonymous
Speech-Language Pathologist and Advocate

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,

Kendra Clerkin-Males

Spech-Language Pathologist 

I am an ASHA certified SLP who fully suports the continued regulation of recognition of ASHA Certification in initial licensure for Virginia's Speech Language Pathologists. ASHA Certification ensures that speech language pathologists are adhering to the highest standards both ethically, and academically and have participated in a rigorous clinical fellowship year. These requirements ensure that SLPs in Virginia continue to meet high standards of care.

Regardless of the setting that a speech language pathologist works in requirements for licensure and the SLP licence should be the exact same. Many SLPs work in both the schools and in private practice / health care. There should only be one type of SLP license in the Commonwealth of Virginia.

Thank you for the opportunity to provide comments on this important matter.

Support removing ASHA CCC requirement for Virginia State licensure.

I am writing in strong support of the proposed changes to the Virginia Board of Audiology and Speech-Language Pathology (SLP) 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 (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. As an Ohio SLP license holder, I have first hand experience with this procedure.  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.  Personally, mentoring new students guides my curiosity for seeking new continuing education opportunities. 

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,
Sara Kull
Speech-Language Pathologist and Advocate

I am writing to provide feedback on the proposed changes to the speech-language pathology licensing regulations in Virginia. 

Frist, I would like to see a continued requirement for the Certificate of Clinical Competence (CCC). This is the national certification that ensures SLPs across the country are practicing with the same ethical code, education and training requirements, and are upholding the same level of professionalism in terms of continuing education, assessment, and intervention. As stated by another commentor "The CCC's certification demonstrates each SLP's dedication to providing evidence based therapy, upholding their clinical skills and remaining up to date with our ever changing field. The certificate of clinical competence also serves at the only mechanism for reported ethics violations in Virginia. We need to uphold this ethical standard for all practitioners." 

Second, I agree and support the need for ongoing professional education. Our field is consistently changing with new evidence based practices, evaluation measures, legislation, and other research. In order to serve our clients, we need to be knowledgeable and up to date on the above items.

Third, I strongly oppose the distinction between school-based and other speech-language pathologists. School based speech language pathologists have the same expectations when it comes to education and often CCC requirements, the main distinction is the educational or academic impact governing the inclusion of services. We provide the same services as outpatient or private practices, we use the same evaluation measures, and we write very similar goals. Additionally, many SLP's work in two settings and if this proposition passes many SLP's would need two licenses within one state in order to simply maintain their current positions. We need to hold all SLP's to the same standards regardless of setting. The section on prohibited conduct that restricts school-based SLPs from practicing outside the public school setting should be repealed. Our scope of practice is wide and varied, those who choose to work in both a medical and school setting are responsible for maintaining their professional skills and knowledge. This legislation implies that we cannot be knowledgeable in both, when we in fact can and are. 

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,
Genevieve Denue
Speech-Language Pathologist and Advocate

Good afternoon,

I am submitting a formal comment to remove the CCC requirement to provide speech therapy services in Virginia. As many of my colleagues have stated in their other comments, the CCC is a financial burden for many of us and is not necessary to prove our competence in the field. We must pass an extensive test, pass our clinical placements, and commit and pass a fellowship year until we can be fully licensed to practice. I believe those accomplishments are enough to demonstrate our skill set. We also must participate in continuing education courses throughout our career to stay current on evidence based practices. 
Please consider the alternative and let us drop our CCCs.

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.

I am writing to provide feedback on the proposed changes to the speech-language pathology licensing regulations in Virginia. 

I strongly support continuing the requirement for the Certificate of Clinical Competence (CCC). The CCC is a nationally recognized professional credential that represents a level of excellence in the field of Audiology (CCC-A) or Speech-Language Pathology (CCC-SLP). Those who have achieved the CCC have voluntarily met rigorous academic and professional standards, typically exceeding the minimum state licensure requirements. They have the knowledge, skills, and expertise to provide high-quality clinical services, and they actively engage in ongoing professional development to keep their certification current.

Maintaining our CCCs as a license requirement is essential to ensuring that all practicing SLPs uphold the standard of knowledge and competency in our field. This national standard is continually updated to meet the evolving needs of our profession and those we serve, and removing this requirement would place this burden on the state licensure board. Further, the CCC requires all practitioners to maintain our ethical standards. 

Our profession is constantly evolving and the only way to keep practitioners current in evidence-based research and practice standards is by requiring annual, high-quality, professional education. Maintaining ASHA-approved continuing education is vital for consistency as well as credibility across the field of speech pathology. 

Further, I strongly oppose the distinction between school-based and other speech-language pathologists. Differentiation of fees between employment settings creates barriers across our profession. Many SLPs work in multiple practice settings, and if this proposition passes many SLPs would need two licenses within one state. As an SLP from the greater Washington, DC area, I am already required to hold licenses from multiple states to meet the needs of the clients I serve. There is no need for this additional burden, as our national practice standards are the same regardless of our clinical setting.

The section on prohibited conduct that restricts school-based SLPs from practicing outside the public school setting should also be repealed, as it would create an additional and unnecessary administrative burden that also has the potential to further reduce the availability of SLPs to serve our school population. Flexibility in practice settings allows for greater access to services for all constituents. 

As SLPs, we serve Virginians with communication disorders - a vulnerable community who may not be able to advocate for themselves. Therefore, we must uphold the highest standards to ensure that high-quality services remain available for these residents.

Thank you for considering the points above and listening to SLPs in Virginia while reviewing these standards. I appreciate your time and service.

I strongly propose a continued requirement for the Certificate of Clinical Competence (CCC) in order to uphold the standards, qualifications and validation of our license.

January 27, 2025

VA Professional and Occupational Licensing Board of Audiology and Speech-Language Pathology

9960 Mayland Drive

Suite 300

Henrico, VA 23233

Submitted Via Online Townhall & Emailed to Executive Director Kelli Moss (kelli.moss@dhp.virginia.gov)

Re: Requesting Amendments to Proposed Rule Changes to 18 VAC 30-21

Dear Members of the Board,

The American Academy of Audiology (the Academy) appreciates the opportunity to submit comments on proposed rule changes to 18 VAC 30-21.  The Academy is the largest organization of, by, and for audiologists. We are dedicated to the provision of quality hearing and balance care services through professional development, education, research, and increased public awareness of hearing and balance disorders.

We commend the board's efforts to streamline licensure processes and improve accessibility for audiologists. However, we respectfully suggest amendments to further clarify and strengthen the proposed regulations. Our recommendations address our concerns on the removal of the ABA certification, the ambiguity of ACAE accreditation, and providing additional guidance on CEUs. These adjustments would improve the rules, ensuring they better serve audiologists in Virginia.

ABA Certification Language Removal

The removal of ABA certification language from 18VAC30-21-50, “Qualifications for Initial Licensure,” creates inconsistency in the regulations and potential confusion for applicants. While we understand that ABA certification remains a viable option, its exclusion unfairly disadvantages ABA-certified audiologists compared to ASHA’s CCC, which is retained in the regulations. Furthermore, 18VAC30-21-110, “Inactive Licensure,” explicitly includes ABA certification, highlighting a discrepancy that undermines regulatory consistency. To ensure fairness and clarity throughout the licensure process, we strongly urge the inclusion of ABA certification in the initial licensure qualifications. If the board decides not to incorporate ABA certification language, we respectfully request the removal of ASHA certification language to maintain equitable treatment of professional certifications.

ACAE Accreditation

The Academy advocates for the explicit inclusion of ACAE accreditation in the regulations to provide greater clarity and certainty for applicants from ACAE-accredited programs. Although the board’s existing guidance document acknowledges ACAE as board-approved, embedding this recognition directly in the regulations would eliminate any potential ambiguity. This change aligns with the proposed rule’s intent to streamline licensure processes and reduce barriers for qualified professionals. By increasing transparency, this amendment would not only encourage more qualified applicants but also help expand Virginia’s audiology workforce more efficiently.

CEU Guidance Document

We recognize the intent behind removing CEU program language to reduce redundancy; however, this change could create confusion about acceptable continuing education programs. To address this, we respectfully request the Board draft a guidance document that outlines approved CEU programs and publish it to the website’s guidance section. Such a resource would be a proactive step to support professionals in meeting continuing education requirements confidently.

Amendment Language Recommendations

The Academy respectfully submits the following recommended language, which is in red, for your consideration:

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, a current unrestricted certification issued by the ABA; or

2. Holds a current and unrestricted certification issued by the ABA or any other accrediting body recognized by the board and provides documentation of having passed the qualifying examination from an accrediting body recognized by the board; or 3. Provides documentation of (i) graduation from an audiology program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body as recognized by the board; and (ii) having passed the qualifying examination from an accrediting body recognized by the board. Submits evidence of the following:

a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA, Accreditation Commission for Audiology Education (ACAE),or an equivalent accrediting body recognized by the board;

Or another alternative language recommendation:

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. 1. Holds a current and unrestricted certification issued by the ABA or any other accrediting body recognized by the board and provides documentation of having passed the qualifying examination from an accrediting body recognized by the board; or 3. Provides documentation of (i) graduation from an audiology program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body as recognized by the board; and (ii) having passed the qualifying examination from an accrediting body recognized by the board. Submits evidence of the following:

a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA, Accreditation Commission for Audiology Education (ACAE), or an equivalent accrediting body recognized by the board;

Conclusion

The American Academy of Audiology commend the board’s efforts to improve licensure processes and accessibility for audiologists. By addressing our concerns regarding ABA certification, ACAE accreditation, and CEU guidance, we are confident that these adjustments will improve the licensure process to better support audiologists. We appreciate the board’s consideration of these recommendations and are committed to working collaboratively to improve the regulatory framework for the benefit of audiologists and the patients they serve. Thank you for your time and attention to this important matter. If you have any questions about any of the information included in this letter, please contact Joanne Zurcher, Vice President of Government Relations and Policy, at jzurcher@audiology.org

Sincerely,

Patricia Gaffney, AUD

President, American Academy of Audiology

January 27, 2025

VA Professional and Occupational Licensing Board of Audiology and Speech-Language Pathology, 9960 Mayland Drive, Suite 300,Henrico, VA 23233

I am an audiologist, practicing in Prince William County, and I ask that you amend the requirements for our licensure as stated below.  

Submitted Via Online Townhall & Emailed to Executive Director Kelli Moss (kelli.moss@dhp.virginia.gov)

Re: Requesting Amendments to Proposed Rule Changes to 18 VAC 30-21

Dear Members of the Board,

The American Academy of Audiology (the Academy) appreciates the opportunity to submit comments on proposed rule changes to 18 VAC 30-21.  The Academy is the largest organization of, by, and for audiologists. We are dedicated to the provision of quality hearing and balance care services through professional development, education, research, and increased public awareness of hearing and balance disorders.

We commend the board's efforts to streamline licensure processes and improve accessibility for audiologists. However, we respectfully suggest amendments to further clarify and strengthen the proposed regulations. Our recommendations address our concerns on the removal of the ABA certification, the ambiguity of ACAE accreditation, and providing additional guidance on CEUs. These adjustments would improve the rules, ensuring they better serve audiologists in Virginia.

ABA Certification Language Removal

The removal of ABA certification language from 18VAC30-21-50, “Qualifications for Initial Licensure,” creates inconsistency in the regulations and potential confusion for applicants. While we understand that ABA certification remains a viable option, its exclusion unfairly disadvantages ABA-certified audiologists compared to ASHA’s CCC, which is retained in the regulations. Furthermore, 18VAC30-21-110, “Inactive Licensure,” explicitly includes ABA certification, highlighting a discrepancy that undermines regulatory consistency. To ensure fairness and clarity throughout the licensure process, we strongly urge the inclusion of ABA certification in the initial licensure qualifications. If the board decides not to incorporate ABA certification language, we respectfully request the removal of ASHA certification language to maintain equitable treatment of professional certifications.

ACAE Accreditation

The Academy advocates for the explicit inclusion of ACAE accreditation in the regulations to provide greater clarity and certainty for applicants from ACAE-accredited programs. Although the board’s existing guidance document acknowledges ACAE as board-approved, embedding this recognition directly in the regulations would eliminate any potential ambiguity. This change aligns with the proposed rule’s intent to streamline licensure processes and reduce barriers for qualified professionals. By increasing transparency, this amendment would not only encourage more qualified applicants but also help expand Virginia’s audiology workforce more efficiently.

CEU Guidance Document

We recognize the intent behind removing CEU program language to reduce redundancy; however, this change could create confusion about acceptable continuing education programs. To address this, we respectfully request the Board draft a guidance document that outlines approved CEU programs and publish it to the website’s guidance section. Such a resource would be a proactive step to support professionals in meeting continuing education requirements confidently.

Amendment Language Recommendations

The Academy respectfully submits the following recommended language, which is in red, for your consideration:

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, a current unrestricted certification issued by the ABA; or

2. Holds a current and unrestricted certification issued by the ABA or any other accrediting body recognized by the board and provides documentation of having passed the qualifying examination from an accrediting body recognized by the board; or 3. Provides documentation of (i) graduation from an audiology program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body as recognized by the board; and (ii) having passed the qualifying examination from an accrediting body recognized by the board. Submits evidence of the following:

a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA, Accreditation Commission for Audiology Education (ACAE),or an equivalent accrediting body recognized by the board;

Or another alternative language recommendation:

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. 1. Holds a current and unrestricted certification issued by the ABA or any other accrediting body recognized by the board and provides documentation of having passed the qualifying examination from an accrediting body recognized by the board; or 3. Provides documentation of (i) graduation from an audiology program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body as recognized by the board; and (ii) having passed the qualifying examination from an accrediting body recognized by the board. Submits evidence of the following:

a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA, Accreditation Commission for Audiology Education (ACAE), or an equivalent accrediting body recognized by the board;

Conclusion

The American Academy of Audiology commend the board’s efforts to improve licensure processes and accessibility for audiologists. By addressing our concerns regarding ABA certification, ACAE accreditation, and CEU guidance, we are confident that these adjustments will improve the licensure process to better support audiologists. We appreciate the board’s consideration of these recommendations and are committed to working collaboratively to improve the regulatory framework for the benefit of audiologists and the patients they serve. Thank you for your time and attention to this important matter. If you have any questions about any of the information included in this letter, please contact Joanne Zurcher, Vice President of Government Relations and Policy, at jzurcher@audiology.org

Sincerely,

Patricia Gaffney, AUD

President, American Academy of Audiology

While the American Speech-Language-Hearing Association (ASHA) has been a fantastic resource and collaborator for speech-language pathologists in Virginia, including their clear and active partnership on interstate compact legislation during Virginia's 2024 legislative session, the current CCC requirement is creating an unnecessary barrier to speech-language pathology licensing in Virginia.

We are currently facing a provider shortage, with school-based caseloads often exceeding the Virginia cap of 68(!) and productivity rates in healthcare settings often exceeding 80%, ultimately impacting the quality of speech-language pathology services that our clients receive. Licensing requirements for prospective speech-language pathologists in the Commonwealth should be revised to ensure that applicants have adequate educational and clinical practicum experiences (i.e., discerned through their educational record and Praxis examination scores); however, the CCC should not be mandatory. Doing so not only hinders the licensing of competent practitioners who could enhance the quality of healthcare services in Virginia, but it also requires their payment of certification maintenance fees to ASHA. State regulations should not require affiliation with a national organization that is not otherwise mandated by state or federal legislation. 

Thus, I support the removal of the CCC requirement.

To the Virginia Board of Speech-Language Pathology,

I am writing to express my support for removing the requirement for National Certification from ASHA as part of the state licensure requirements in Virginia.

Over the course of my career, I have spent at least $5,000 on ASHA dues, and I anticipate spending an additional $5,000 or more before I retire. This is money that could have been better invested in continuing education opportunities within Virginia or in resources to enhance my practice. I do not feel that the benefits provided by ASHA justify the cost, as I receive everything I need for professional practice and development through my state license.

Additionally, continuing to link Virginia’s licensing requirements to ASHA certification places unnecessary reliance on an external organization. Should ASHA change its certification requirements in the future, it could force Virginia’s licensing requirements to shift as well, creating potential instability. Maintaining independent state control over licensure requirements would allow the Virginia Board to better serve and protect the interests of professionals and the public.

Thank you for considering this important matter.

Sincerely,

Elizabeth 

Virginia should not require the CCC-A for state licensing because it creates unnecessary expenses and barriers to practice audiology. The CCC-A involves additional time, cost, and administrative burden that may not directly correlate with improved clinical competence. Many audiologists already meet rigorous educational and clinical training standards through their graduate programs and state licensure exams. Requiring the CCC-A could limit the workforce, particularly in underserved areas, and deter qualified professionals from practicing in Virginia. State-specific licensing requirements, combined with practical experience, are sufficient to ensure public safety and professional competency without mandating the CCC-A.  

I am writing to support the proposed changes for VA SLP licensing to remove the requirement of the ASHA CCC. The current mandate is redundant and creates a perception that SLPs must annually purchase a proprietary product in order to be considered "competent" to practice, even though the state license itself mandates rigorous educational, ethical, and professional standards. Removal of the CCC alleviates a financial burden on practicing SLPs and allows for real choice in electing to obtain the additional certification. 

I am in support of the proposal to remove the CCC from initial licensure requirement for both audiology and SLP. There are a growing number of audiologists who elect not to get the CCCs when they graduate with their doctorate degree as the university and their internship placement meet the requirements to be a competent audiologist. And those who do get their CCCs because their universities tell them they need them to practice, will often drop them due to the high cost to keep them and the higher cost to renew them if you let the membership lapse. Once you obtain your CCCs initially you are just paying a yearly "membership" and it's not an organization that is requiring continued testing for competency past their initial Praxis test. So the annual fee we pay to be a member doesn't mean that we are more or less competent to do our job than people who don't have their CCCs or who had them at once but dropped them. 

There is a shortage of audiologists in Virginia right now and this would also help bring others in state if it was easier to obtain their license. I talked to one audiologist recently who has been practicing in another state for years and is moving to VA but is having to jump through a bunch of hoops to get her license because she dropped her CCCs. I don't see any negative issues with this passing. 

Removal of the CCC would be beneficial in many ways. These dues are alot of money each year to renew them. the CCC dot give much more to an SLP. A great SLP is still a great SLP without having their CCC.

There are several other aspects of your CCCs that most are not talking about.  I am all for cutting cost and making CEUs more affordable.  But students have to have supervisors with their CCCs and approved courses to obtain their degree as a speech language pathologist.  It is a burden at times to even find a supervisor with the qualifications.  Also students that attend VA universities and then return back home need their CCCs. So as for the shortage, it would have a negative effect on student retention and students won’t want to stay in VA for internships, which makes them move to other states and increases the shortage. All ASHA credentialed universities have to meet this requirement for accreditation. So with the decrease in individuals with their CCCs will negatively affect university programs, which will affect the amount of SLPs in VA.  

Support removal of CCC requirement

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 of 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 professional and those they serve.  

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 that 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

Janet Tatem, M.A., SLP 

I am writing in strong support of the proposed changes to the regulations. As a Virginia school SLP, I'm proud to work in a state with so many excellent resources, such as the VDOE SLP Handbook. Separating licensure from the CCC is a progressive and necessary step that allows Virginia to continue to be a leader in SLP practice. Additionally, removing the requirement for ASHA-approved CEUs will allow Virginia SLPs to seek relevant continuing education from a wider variety of sources. I encourage the board to consider further expand what can be considered professional development for SLPs, such as allowing some amount of supervision hours to count toward license maintenance or allowing independent study. Thank you for all you do to advance and support the field of SLP in Virginia!

-- Anonymous licensed and certified SLP

I am writing to support the removal of CCC-A from licensure. It is reasonable that maintaining state licensure and meeting continuing education requirements should sufficiently demonstrate professional competency. 

The notion of professional competence goes beyond just holding a certificate; it encompasses your dedication to staying updated with the latest practices and consisently providing the best care for your patients. Continuous learning is what truly reflects an Audiologist's expertise and committment. 

As others have suggested -- and as others might anecdotally report --  the requirement for new audiologists in Virginia to hold a CCC-A in order to obtain licensure likely deters some competent providers from practicing in the Commonwealth. Should a prospective licensee prove completion of all degree requirements from an accredited college or university, as well as a passing score on the Praxis, then ASHA or ABA certification ought to be seen as redundant. 

Processing of certificate applications is estimated to take 4-6 weeks. Therefore, for new practitioners, a certificate requirement extends the Virginia licensing process unnecessarily, putting further strain on individuals competing to join the work force.

The criteria for reinstatement of one's CCC-A appear intentionally burdensome, as if to deter providers from considering dropping the certificate when its value fails to meet the cost of annual renewal. Currently, a Praxis retake is required along with a $371-$400 reinstatement fee. Therefore, for experienced providers outside the Commonwealth who have dropped their certificate but wish to join our workforce, the CCC-A requirement can add two months or more of processing time to the licensing process. 

I support approving new audiologist license applications without the requirement of a CCC-A, arguing that such a change would attract more professionals to the Commonwealth by removing a superfluous obstacle without sacrificing generally accepted standards for clinical competency. 

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,
Amy
Speech-Language Pathologist and Advocate

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,
Alicia McFadden
Speech-Language Pathologist 

This is very sad to think that you would lower standards for our profession. Our children deserve better.  It is tough to recruit SLP's in schools and other areas but it should not change our high standards of the profession.  Perhaps if you paid SLP's and lowered the caseload it would attract more and stronger candidates. 

I am shocked that removing the requirement for a certificate of clinical competence for SLPs would be considered. I worked without my CCC for the first years of my career in the 70s and early 80s. In those days, however, children in schools were only served for articulation and language; and children with more complex issues were likely not even in our schools. Or, more complex issues were less well understood. Now, as of the early 80s, we educate everyone in our schools; and children with complex issues are more numerous than ever. I ended my career recently by supervising strong SLPs; but still, there was always more to learn and new case presentations to consider. We cannot consider leaving the job to less prepared staff. I am not even comfortable that SLP assistants are strong enough to recognize relevant patterns that matter and should alter course of treatment or add strategies to course of care. We all need to continue to strive to be stronger, not to accept less preparedness.

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,
Kelly Shenk
Speech-Language Pathologist and Advocate

Rockingham County Public Schools

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

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,

Rachel
Speech-Language Pathologist and Advocate Licensed and Practicing in VA 

I fully support the removal of the requirement to obtain the Certificate of Clinical Competence (CCC) issued by ASHA in order to be licensed in Virginia. However, I do have a concern about the requirement of a provisional license in order to be licensed in the state. Historically, SLPs have done a clinical fellowship year (CFY) following their graduation in order to obtain their CCCs. During the CFY, SLPs are supervised by another SLP who would be able to serve as a supervisor while the new SLP has their provisional license in order to be fully licensed. In audiology, students complete a year long clinical experience prior to graduating. Audiologists do NOT need to complete the CFY in order to earn their CCCs.

I do not believe that audiologists should have to obtain a provisional license and have a supervisor in order to be fully licensed. In several audiology settings, there is only one audiologist at a given practice location. The requirement of audiologists having a provisional license and supervised by another audiologist will significantly impact audiologists hired to work in several settings. Audiologists complete their supervised training as part of their year long clinical experience while still enrolled in school.