I support the alternative qualification for an assistant who has had employment as an SLPA in a US jurisdiction within the last 5 years preceding the effective date of the regulations.  I work in a Commonwealth of Virginia facility that has utilized SLP assistants for about 8 years. Some have had bachelor's degrees and some have not. We have been able to use them effectively to help us meet our demand for services-not by using them as "junior SLP's," but in supportive ways that do not include clinical duties that are restricted to an SLP. We work closely with them, and they are keenly aware of their boundaries. If SLPA's were to be licensed in Virginia, then they would be expected to have increased education and they could be used in a very different way; however, these proposed regulations are written for unlicensed assistants, and it is important to realize that it would be difficult to attract people into these unlicensed jobs if the qualifications were restricted to a bachelor's degree in communication disorders.

I would like to comment on 18VAC30-20-240 item D #5 which restricts the SLPA from participating in formal conferences or meetings without the presence of the supervising speech-language pathologist. In my facility, we do allow SLPA's to attend meetings in the absence of a SLP but they only are allowed to contribute general information cleared by the SLP in advance and they never discuss clinical issues. I suggest that #5 be rephrased to say that they should not participate in formal conferences or meetings where clinical information is provided without the presence of the supervising speech-language pathologist.  This also supports item #6 which makes it clear that they are not to provide interpretive information to the client or others.