Having read the proposal, I believe the initial qualifications for SLPA's are not restrictive enough. An SLPA should hold a bachelor's degree from an ASHA approved training institution OR an ASHA certified SLPA associate degree program (though I'm not sure ASHA certifies such programs at this time). In addition, an SLPA seeking employment in VA, having worked in that capacity in another state---no matter how long ---must meet the training criteria established by ASHA and/or the Commonwealth of VA. Additionally, as written, I feel the proposed language places the burden of competency of an SLPA too much on the supervising SLP. We need the stricter educational guidelines to help ensure that the consumer is receiving the best possible service reasonably available and afford the supervising SLP confidence that the SLPA is indeed as competent as possible with implementing a therapeutic plan across a variety of disorders. I'm not convinced that two observations per month per SLPA is enough to ensure best-practice.  I would also suggest that the proposal include regulations for mandated  annual continuing education for the SLPA.  Finally, I would  like to see a notation that the use of 'assistant' and similar terms that may be assigned to an individual working in the capacity of an SLPA be governed by this regulatory board. I appreciate that the proposal includes restrictions on an SLPA's scope of practice, including assessments, consultations, meetings, dissemination of client information,  inclusions and dismissals of clients etc. I will only feel comfortable advocating for employment of SLPA's in my workplace if these training criteria are mandated. Thank you.