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