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