I am the Director of Communication Services at Woodrow Wilson Rehabilitation Center.  I am fully in support of the use of SLP-As, but my thoughts on regulations may be considered stringent:

1.  The SLP-A should have a minimum of a Bachelor’s Degree in the field of Speech-Language Pathology (most individuals interested in this position already do).
2. The SLP-A should pass a praxis type of standardized test commensurate with a B.S./B.A.
3. I did not understand the language stated which read, “no statutory authority to issue a license to assistants?”- If an individual has a minimum of a B.S./B.A. and passes a praxis, then the licensing board should be able to create a license for the SLP-A.  It is also more cost effective for the consumer if the SLP-A can bill under his/her own license at a reduced cost.

Naturally an SLP-A should not be involved with assessments or any dysphagia therapy.  I personally would want to know an exact percentage of supervision with each client that would need to occur, and feel a log/documentation should be kept and submitted in compliance with that regulatory standard.

Thank—you!

Ginger  Shifflett, M.S. CCC-SLP

I am very concerned about the regulation of SLP-As.  I am concerned that in small localities where staffing is very difficult, the SLP-A position will not be adequately supervised and thus impact the quality and job opportunities for licensed SLPs.  I am also concerned about the increased workload of adequately supervising SLP-As without appropriate reduction is caseload.  Also, I feel that the educational requirements for the SLP-A certification need to be specific to the area of speech/language disorders. 

Thank you for the opportunity to express my feelings and concerns,

Brenda Wallace, MA CCC/SLP

SLP-A Comments on Proposed Regulatory Action

Background:  Marie Owens (mowens@nkcps.k12.va.us) is a SLP-CCC and Heidi Dellert (hdellert@nkcps.k12.va.us) has a Bachelor’s degree in Speech Language Pathology and Audiology with a TSHH (Teacher of Speech and Hearing Handicapped).  Marie has twenty five years of experience and Heidi has twenty years of experience in this field.

Ideas to be considered in proposal:

• Education.  In our opinion a bachelor’s degree is necessary for the capacity in which we have utilized the SLP-A position.  The SLP-A has a unique skill set which, if utilized in a productive manner, can increase the productivity and efficiency of the speech team dramatically. If an SLP-CCC was to utilize an assistant to merely execute administrative tasks, it would be a waste of a manning resource.

• Responsibilities.  Ultimately these are at the discretion of the SLP-CCC. For New Kent Elementary School, SLP-A responsibilities have included:

~Hearing and kindergarten screenings

~Selective (usually articulation and language based) direct therapy

~Administrative duties (typing IEP outlines, making copies, constructing therapy schedules, scheduling meetings)

~Recording progress in cum files  

~Recording data when taking fluency or intelligibility counts

~Taking data in a small articulation groups to maximize the therapy time

~Obtaining updates on consultative students from classroom teachers, IEP information (recent grades, SOL scores, etc.), scheduling meetings, etc.

• Location/Proximity.  We initially began in different buildings and both agree that it is very important not only to be in the same building but to be in close proximity in that building.

• Disclosure.   We mail an informational letter at the beginning of each year to parents/guardians of all speech therapy students that clearly states the background and education of the SLP-CCC and SLP-A.

Cost/Benefits:

• We feel that SLP-A’s are a financial “bargain” for school districts.  They can be hired for a substantially lower salary than a SLP-CCC and help to reduce the workload and allow execution of therapy to be done efficiently while maintaining a high caseload.

Potential impacts of the regulation:

• Several positive impacts (costing and reduction of workload, as mentioned above) are potential positive results.
• A potential negative impact could result in compromised quality of therapy if not strictly regulated by the supervising SLP-CCC.

I have a B.S. in Speech and Language Pathology from James Madison University. I worked as a speech pathologist in Alaska for 10 years for two school divisions. In 1987, husband and I moved overseas. Upon returning to the USA, I discovered that a master's degree in speech and language pathology  was required. As I could not quit work to pursue a M. S. in Speech and Language Pathology, I chose other options. I have  M. Ed in Rehabilitation Teaching of the Blind and graduate certification in DeafBlind counseling. I have researched options of online master's degrees in speech pathology, but they all seem to require a special ed degree and/or current employement in a school division.

I am very interested to see how the SPLA program will develop in Virginia, as I still have an interest in working in this field.

Background: The following comments pertain to the use of unlicensed SLP assistants at Central Virginia Training Center, a residential facility of the Commonwealth of Virginia Department of Behavioral Health and Developmental Services.  Individuals served have a diagnosis of intellectual disability and also may have other medical diagnoses.  The facility has two levels of care: Intermediate care facility for individuals with intellectual disability which has a major regulatory emphasis on active treatment and integration back into the community.  There is also a licensed nursing facility on site with both skilled and long term beds. The facility has utilized SLP assistants since 2006.

Current assignments of unlicensed assistants: Currently 4 SLP assistants serve the facility.  There are 6 licensed speech-language pathologists (SLP's) who supervise them.  Supervisory duties of SLP’s are divided into clinical and administrative.  Each SLP is responsible for clinical supervision of the assistant(s) assigned to their caseload.  One SLP has administrative supervision duties for 3 assistants and another SLP has administrative supervision duties for 1 assistant.

Duties of unlicensed assistants:

• Assists SLP with observations and gathering information to assist SLP with assessments.
• Develops a “communication dictionary” describing the individual’s communication.
• Conducts routine interaction programs for individuals as assigned by the SLP.
• Conducts reinforcement activities for individuals as assigned by the SLP.
• Produces communication materials as requested by SLP.
• Assists SLP during therapy sessions, as assigned (SLP is conducting the therapy).
• Provides hearing screenings as assigned and discusses results with SLP.
• Arranges audiological evaluations and accompanies individual to audiology appointments.
• Performs hearing aid checks and arranges for repairs.
• Trains direct support staff in hearing aid care.
• Models communication strategies for functional settings and trains direct support staff to provide communication supports.
• Monitors AAC for availability and working order.
• Represents speech-language pathology discipline at team meetings when therapist has schedule conflicts.
• Checks off/approves new direct support staff’s competence at mealtime and supports adherence to facility mealtime protocols and individuals’ eating precaution plans.
• Supports SLP department with development and maintenance of databases that are used in shared department computer files.

Qualifications:  The SLP assistant is classified as a Therapist I.  A bachelor’s degree is preferred but not required since there are no current regulatory requirements.  Of the 4 assistants currently in positions, 2 have a bachelor’s degree (only one has a degree in communication disorders).  Two have other certifications-one is a certified nursing assistant (CNA) and one is an emergency medical technician (EMT). Both have current certifications in those fields.  All of them have been trained by licensed speech-language pathologists to perform the tasks that they have been assigned and have demonstrated competency in performing those tasks.

Comments: The use of SLP assistants has been of enormous value to us in this setting.  They provide quality services to the individuals that we serve, and are in close communication with the SLP who provides clinical supervision.  If a requirement of a bachelor’s degree becomes the standard, I would like to see a clause for grandfathering in assistants who do not have the degree so that our assistants can continue in their current position.  Not being able to continue in their current position may pose a financial hardship on these staff, the individuals they serve, and to the facility.

If SLPAs are going tbe able to provide services in Virginia, the following areas need to be addressed in order to ensure quality assessment and treatment for clients and support for the licensed supervising SLP:

• Clear guidelines for the scope of practice of the SLPA
• Clear guideslines as to the amount and level of supervision for SLPAs
• Clear process/documention/registerion of the supervising, licensed SLP and the SLPA.
• Criteria for individuals who may be a SLP (must have a BA or BS)

I highly recommend the use of SLPAs in providing services to students with Speech or Language Impairments. I agree that regulations should be in place and they must be supervised by licensed speech/language therapists.  Living in far southwest Virginia, we do not have access to universities that offer a master's degree in speech-language pathlogy.  We have several people who have completed the bachelor's degree in speech and communication sciences but are unable to get accepted into a master's program---on campus OR online.  We do not have enough speech therapists to cover the number of students with speech-language impairments so we are forced to overload the few therapists that we have and that does not create a good work environment for them or a good learning environment for our students!  An SLPA can certainly be qualified to carry out the instructions of the SLP and provide much needed practive in speech articulation and social skills training based on the students needs and recommendations of the therapist.  We certainly want our students to get the best services we can offer; however, our need is so great and the staff is so small!  I believe our students would greatly benefit from the services of a qualified SLPA and we would be much more likely to fill those positions than SLP positions at this time.  I strongly encourage you to consider helping the small rural communities and the children with disabilities that we serve.

I would like to discuss the issue concerning the use of Speeh-Language Pathologists-Assistants.  The recent discussion through the VA Speech-Language Pathology Licensure board was summarized that SLP-Assistants in Virginia could work under the licensure of Speech-Language Pathologists.  

This is of great concern to me as a licensed SLP.  When we look to our peers in Physical and Occupational therapy, it is clear that there are specific standards in place for Occupational Therapy Assistants and Physical Therapy Assistants (LPTA) to become licensed professionals.  This is not the case for Speech-Language Pathologists.  Our field is working on procedures to utilize personnel that have completed their Bachelors degree in Speech Pathology to work as assistants until they complete their Master's Degree which is entry level in the field of Speech-Language Pathology.

My concern is that there are no standards in place for "speech assistants" to practice.  LPTA and OTA complete requirements for their programs before they are licensed and subsequently seeing patients.  The use of licensed speech therapy assistants could be a great asset to the field of Speech Pathology, but a course of training needs to be completed with possibility of licensure.  If SLP assistants are used as currently described, it could easily result in a substitute teacher or high school graduate performing professional skills without training.  Please reconsider a means for SLP assistants to receive training and licensure versus having non professionals providing services under the license of SLPs.

As a school based SLP, I am concerned about the proper training and credentialling of SLPAs. In my opinion, the minimal requirement for SLPA training should be a Bachelors degree from an accredited CSD program. SHAV and ASHA guidelines should also be considered. I strongly agree with the following point:

e over this text and enter your comments here. You are limited to approximately 3000 words.

Dear Colleagues on the Board of Audiology and Speech-Language Pathology,

Thank you for considering public comment regarding the practice of assistant speech-language pathologists in the Commonwealth of Virginia.  Clearly specified regulations for SLPAs is critical to protect the clients and students receiving the services, as well as the licensed professionals committed to the provision of quality services. 

Consideration should be given to regulations concerning the education requirements for an SLPA and the specific duties an SLPA can complete.  These duties should be stated clearly so that all professionals, clients, agencies, and employers will understand the scope of practice for an SLPA and how it differs from the scope of practice for an SLP.

Regulations also should consider issues related to supervision of the SLPA.  These would include the minimum percentage of time per month that an SLPA must be supervised directly by an SLP with each client/student and the importance of having a licensed SLP on site.  In addition, time should be specified for discussion and coordination services between the SLPA and the SLP.  Regulations should specify the documentation required to ensure that time is provided and the supervision is completed.  Further, regulations should ensure that employers do not assign SLPAs to licensed professionals without the SLP’s consent. 

These regulatory actions regarding SLPAs will be critical in guiding licensed professionals and their employers to provide effective, ethical treatment for their clients/students.  Thank you for your thoughtful consideration of these comments.

Sincerely,

Donna A. Bryant, MS, CCC-SLP

Lead Speech Language Pathologist

Spotsylvania County Schools

Cedar Forest Elementary

3412 Massaponax Church Road

Fredericksburg, VA 22408

540-834-4569

email:  dbryant@spotsylvania.k12.va.us

Dear Colleagues on the Board of Audiology & Speech-Language Pathology,

Thank you for the opportunity to provide input with regard to the intended regulatory action that will govern the practice of assistant speech-language pathologists.  Licensed professionals appreciate your willingness to listen to our concerns about actions that will greatly impact the practice of speech-language pathology in the Commonwealth of Virginia.

The call for public comment requested input about ideas that need to be considered during the development of the practice of assistant speech-language pathologist proposal.  Of great concern is the need to have clearly specified regulations that address the following issues:

• Supervision requirements must specify minimum percentage or number of hours per week that each SLPA must be supervised as well as the proportion of therapy sessions for each client that must be conducted by the licensed SLP rather than the SLPA to ensure that each client receives adequate guidance from the supervising SLP.In addition, regulations must state the minimum proportion of therapy sessions conducted by an SLPA that must be directly observed by the licensed SLP on a per client per month basis. Further, the minimum amount of time that SLPs and SLPAs must be given for discussion and coordination activities beyond the provision and observation of direct intervention needs to be specified.

• Regulations must be written that will prevent agencies or employers from assigning assistants to licensed professionals without the SLP’s consent. Regulatory language must prevent circumstances in which licensed professional would be forced to supervise an assistant rather provide the intervention directly to the client themselves.

• Specific actions that SLPAs will be allowed to complete versus the specific components of practices that can only be completed by the licensed SLP must be clearly stated, i.e., carry out therapy activities planned by the licensed SLP vs planning therapy, collecting data vs deciding what treatment data need to be collected or in what format, attending IEP meetings, eligibility meetings, and/or parent conferences.

• Documentation requirements must be clearly delineated.In other words, how will supervisory activities be documented to ensure that regulations are being followed?Who will be responsible for this documentation?How will supervision and documentation be overseen and by whom?

• A variety of questions must be addressed to cover worst-case scenarios.For example, to whom will a licensed SLP turn if their employer requests or requires supervisory actions that are unethical or impractical? What redress will a supervising SLP have in the event that a SLPA has unsatisfactory performance? What is the maximum number of SLPAs that a licensed SLP can supervise at the same time?

The potential impacts of the regulatory actions that The Board is considering will be broad and substantial.  As the Commonwealth transitions to the inclusion of speech-language pathology assistants, it is paramount that regulatory standards must prevent licensed professionals from being placed in ethical dilemmas that could be created by employers who seek to provide the maximum number of service hours at the least financial outlay by structuring practices that are conducted by minimally trained or supervised individuals for whom licensed professionals are responsible without adequate protection or support.

You are entrusted with the welfare of a vulnerable population, namely individuals in the Commonwealth of Virginia and their families, as well as the licensed professionals who spend their lifetime serving them. The responsibility is tremendous.  We collectively and individually look to you for regulatory guidelines that will ensure the benefit and safety of intervention services within our state.  Thank you for acting responsibly upon the concerns that are laid before you.

LaVae M. Hoffman, Ph.D., CCC-SLP

Associate Professor

University of Virginia

Communication Disorders Program

Early Childhood Special Education: Leaders for Tomorrow’s Children

Thank you for this opportunity to comment on the proposed regulatory action related to the practice of assistant speech/language pathologists.  As a certified speech/language pathologist practicing in the schools, I would rate the following problems as top priorities in the schools: 1) high caseloads with budget constraints preventing the hiring of additional personnel to alleviate this problem and 2) difficulties obtaining qualified and certified speech/language pathologists to substitute when our therapists are ill or need to attend required professional development activities.  While I would be strongly in favor of the ability to hire assistant speech/language pathologist’s  to help address these issues, I have the following concerns that I would want to see addressed:

• There should be firm guidelines outlining the supervisory requirements from fully licensed speech/language pathologist’s.  When guidelines are not firm, it adds additional stress to these individuals.
• Qualifications for these assistants should be firmly established and they should include a minimum of a B.S. or B.A. Specialized programs for assistant SLP’s would be recommended for consideration for the future.  Without these minimum requirements, it is likely that supervising SLP’s may have the additional burden of providing more extensive training.  It is unlikely, given the current budget constraints ,that consideration will be given for the need for providing this training when considering caseload demands.
• The scope of practice for these individuals should include provision of therapy at the discretion of the supervising therapist as well as other administrative duties that would help support the caseload of a supervising therapist.  

Again, thank you for considering the opinions of those of us who will be impacted by this regulatory action.  

Sincerely,

Melonie E. Melton M.S.,CCC/SLP

Speech/Language Pathologist

New Horizons Regional Education Centers

13400 Woodside Lane

Newport News, VA 23608

That a BS or BA in communication disorders or speech-language pathology be the minimum requirement for SLPAs.

That the process for registration and documentation of educational and professional experience be similar in depth and scope to current VA SLP certification/licensure.

That the role of SLPAs and the role of supervising SLPs (specific expectations and procedures) be clearly stated in guidelines based on ethics and practices outlined by national and state organizations (ASHA and SHAV).

That supervising an SLPA not be a mandatory requirement but rather a choice of the SLP who can consider professional factors related to caseload, workload, professional responsibilities, etc.

That a fair professional compensation (financial/professional development opportunity) be provided that recognizes the time, professionalism and scope of responsibilities required of supervising SLPs.

That throughout this process continued feedback be sought via this forum, communication with Marie Ireland, MA, CCC-SLP with VDOE, input from VA district SLP Team Leaders, college and university programs offering degrees communication disorders, data from districts that have successfully implemented SLPAs, and most importantly basing guidelines for SLPAs and supervising SLPs on SHAV and ASHA professional ethics and guidelines.

Dear Colleagues on the Board of Audiology & Speech-Language Pathology,

Thank you for providing a forum for concerned professionals to provide input regarding the regulation of speech-language pathology assistants (SLPAs) in the Commonwealth of Virginia. The regulation of the qualifications necessary to become a SLPA and the way in which licensed speech-language pathologists (SLPs) supervise and work with the SLPAs has tremendous ramifications for our profession. More importantly, careful regulation is necessary to ensure the safety and wellbeing of the people we provide our services to.  

The call for public comment requested input about ideas that need to be considered during the development of the practice of assistant speech-language pathologist proposal.  As regulations are considered, please consider the following ideas:

• The educational requirements and training required to become a SLPA must be clearly stipulated. Post high school, specialized training must be a requirement for hire and licensure as a SLPA. As you know, the minimum requirements for being a licensed SLP are a master’s degree and the accrual of clinical experiences across a variety of domains. If a SLPA is going to effectively assist the SLP without causing harm, specialized training in the area that the SLPA is going to practice is necessary.
• As others have stated, the specific regulations regarding the supervising SLP must specify minimum percentage, or number of hours, per week that each SLPA must be supervised as well as the proportion of therapy sessions for each client that must be conducted by the licensed SLP. Please see Dr. Hoffman’s comments on this. 
• Employers should not be able to place SLPAs with SLPs who have less than 2 years of experience following the completion of the requirements for national certification.Additionally, the supervising SLP should have coursework or continuing education credits specific to supervision practices prior to becoming a supervisor for a SLPA.
• In order to protect the public and the supervising SLP, the diagnostic profile of clients the SLPA can treat should be specified to exclude medically fragile individuals.
• As Dr. Hoffman indicated, ethical considerations need to be addressed regarding the potential conflicts that may arise for supervising SLPs relative to their employers, and the individual SLPAs they are asked to supervise.

The inclusion of SLPAs in the everyday practice within the field of speech-language pathology has the potential to improve the quality of the services that SLPs provide by allowing more concentrated care. Conversely, without vigilant attention to the structure of the scope of practice for the SLPA the potential for harm to come to the people who need us the most is profound.

We are grateful for your careful consideration of the regulatory actions that will protect us, the licensed SLPs, and most importantly the people of the Commonwealth whom we serve.

Dear Colleagues on the Board of Audiology & Speech-Language Pathology,

Thank you for providing a forum to provide input regarding the regulation of speech-language pathology assistants (SLPAs) in the Commonwealth of Virginia.

 As regulations are considered, please consider the following ideas:

The educational requirements and training required to become a SLPA must be clearly stipulated.   Please consider a BS or BA in communication disorders or speech-language pathology to be the minimum requirement for SLPAs, with some provision for those individuals who are already functioning in this capacity to continue in to work, as they meet this requirement over time.

The role of SLPAs and the role of supervising SLPs (specific expectations and procedures) must be clearly stated in guidelines based on ethics and practices outlined by national and state organizations (ASHA and SHAV).

• These guidelines should include specific actions that SLPAs will be allowed to complete versus the specific components of practices that can only be completed by the licensed SLP, i.e., SLPAs can function within prescripted activities and not be responsible for diagnosis or interpretation of any communication disorder.
• Supervision requirements must specify minimum percentage or number of hours per week that each SLPA must be supervised as well as the proportion of therapy sessions for each client that must be conducted by the licensed SLP rather than the SLPA to ensure that each client receives adequate guidance from the supervising SLP.  Some provision should be made to stipulate that SLPAs work with supervising SLPs within a reasonable physical proximity.

Employers should not be able to place SLPAs with SLPs who have less than 2 years of experience following the completion of the requirements for national certification.  Additionally, the supervising SLP should have coursework or continuing education credits specific to supervision practices prior to becoming a supervisor for a SLPA.

• That supervising an SLPA not be a mandatory requirement but rather a choice of the SLP who must consider professional factors related to caseload, workload, professional responsibilities, etc.
• That a fair professional compensation (financial/professional development opportunity) be provided that recognizes the time, professionalism and scope of responsibilities required of supervising SLPs.

Procedures for recourse should be stated regarding any potential conflicts that may arise for supervising SLPs relative to their employers, and the individual SLPAs they are asked to supervise, and their clients’ welfare.

Thank you for your careful consideration of the regulatory actions that will protect us, the licensed SLPs, and most importantly the people of the Commonwealth whom we serve.

Sincerely,

Alisha P. Springle, MS, CCC-SLP, BCS-CL

Lecturer/Clinical Educator

Communication Sciences and Disorders

Old Dominion University

Norfolk, VA 23529-0136