I support the petitioner's requests. The requirements should be set by the board rather than a 3rd party. 

I support the petitioners request. SLP requirements should be based off of educational status and not a 3rd party organization’s arbitrary rules. ASHA is a biased organization that does not support professionals who question ASHA’s stance on political issues. Politics do not belong in our profession and should not govern how we provide services. 

When agencies promote ideology that is not ground in fact and professional skill sets, it becomes a political influence. If you do not agree with the ideology there should be no threat to your right to practice in your profession without undergoing some kind of “reeducation”. That is communism. 

I am in support of this change. There is no need to hold an ASHA license. 

Robert M. Augustine, PhD, CCC-SLP

2023 ASHA President

i support the current prerequisite degrees and certifications.

please do not lessen the standard

This petition would be detrimental to the industry 

our office opposes this proposal 

I strongly and wholly oppose this petition 

I support this petition. 

SLP‘s for public schools are hard to come by. Removing the bureaucratic red tape of requiring costly, ADDITIONAL credentialing by private corporate club would be a step in the right direction. SLPs exit grad schools and enter the workforce highly trained and strapped in school debt. Requiring private corporate club (ASHA) certification - on top of state licensure and education department requirements adds unnecessary financial burden that often drives SLPs away from schools and other potentially lower paying, understaffed, high-need human services settings. States can maintain their own high standard of education and continuing education requirements without the additional “lobbying group stamp of approval,” and their speech-language professionals and student/patient populations will be blessed for it.

Strongly Support 

Requirements for professional licensing should be set by a board and be based off of educational status and not by a 3rd party, especially when that 3rd party allocates money to support their political views and creates arbitrary rules.  When agencies promote ideology and then change rules that we have to be "re-educated" in order to still practice in our profession, it is flat out wrong.  Once again, I strongly support the petitioner's request.  

There is currently no requirement that public school SLPs have ASHA CCC’s in the Commonwealth of Virginia but private practice SLPs have to even though we diagnose and treat the exact same disorders. This is illogical. 

Other states do not require CCCs for licensure. 

ASHA is a private organization. My Commonwealth of Virginia government license to practice speech shouldn’t be tethered to a non-government entity. The Commonwealth of Virginia should not subcontract out licensure requirements. If ASHA wants to ‘uphold’ standards in speech then they can work with our colleges and universities to influence, guide, and ensure their SLP programs are ‘ASHA certified’ but enough with their  requirements for my CCCs. 

In response to another post: “………ASHA is the national professional, scientific, and credentialing association for 223,000 members a…..”. Of course you have 223,000 members! You’ve lobbied the government to make membership a requirement only to turn around and use your membership totals as a reason to maintain the ASHA CCC requirement while citing membership numbers.. Seems like a conflict of interest and  self-serving. 

ASHA does not advocate enough for SLP’s for me to pay them to hold a license. ASHAs political agenda is one I cannot support. I should not have to pay a private agency who is pushing an agenda on me.  Practice nonpartisan ASHA! 

I don’t think ASHA membership should be a requirement, and for those who choose membership, I think we should only have to pay once every cycle (3 years). $225 every 3 years would be fair. At $225 EVERY year, we should be able to take ASHA’s online courses for free.

ASHA has worked with universities to ensure high standards are taught to graduating SLPs. The unnecessary enforcement in having to pay ASHA yearly, just for the CCCs, does not increase our skill level or abilities. Physical therapists and occupational therapists are not required to pay their respective representative bodies (APTA and AOTA) in order to be considered eligible for state licensure. The only logical reason this mandate has happened is due to ASHA lobbying for this additional state licensure requirement. Meaning, they are forcing SLPs to pay ($225/yr) to provide money used to lobby against our own financial health.  The Supreme Court ruling in Janus v. AFSCME on June 27, 2018 meant teachers nationwide were no longer required to be part of a teachers union in order to keep their jobs. In this state, the mandate for CCCs is effectively forcing us to remain in an untitled union. 

It is a conflict of interest for ASHA to require annual dues in order for me to keep something I've already earned.  Each state licensure board requires continuing education.  There's no reason for ASHA certification/membership to be necessary, much less mandatory.  Neither OT nor PT are required to be members of their national associations.  We shouldn't be required to do so either.

I strongly support this initiative to remove this requirement. 

ASHA certification should not be required to work. We acquire a license from the state. ASHA is a private organization that profits from this requirement. In addition, ASHA has become political activists on social issues that do not align with all members. ASHA holds too much power over therapists’ careers. One has to continue sending money to organization in order to work…even if their activism is a direct violation of one’s religious convictions.

Furthermore, other therapists (OT,PT) do not have the same cerification requirements.

There is a shortage of SLPs in Virginia.  Eliminating the requirement may increase the applicant pool.  Additionally, there are challenges with the CCC and individuals who receive degrees and clinical training in other countries and are interested in working in the United States.  Employers vet the coursework and these individuals fill positions to provide services. 

The CCC provides a competency designation that a graduate degree does not.  It seems that it may be appropriate to work with ASHA to open avenues for obtaining the CCC and keeping the requirement.

January 23, 2023

Leslie Knachel, Executive Director

VABASLP

9960 Mayland Drive, Suite 300

Henrico, VA 23233

RE:      Petition to amend 18VAC30-21-60(A)(1)

Dear Ms. Knachel and the VABASLP,

I am writing to oppose a petitioner’s request that the Board amend 18VAC30-21-60(A)(1) to eliminate the requirement that initial licensure applicants hold a Certificate of Clinical Competence (CCC) issued by ASHA, thereby replacing that requirement with holding a master’s degree in speech-language pathology, communication disorders, speech and hearing science, or equivalent.   

Though I understand and appreciate the request, there are many concerns about approaching initial licensure in this manner.  The biggest concern is that a master’s degree in speech-language pathology, communication disorders, speech and hearing science, or equivalent is solely insufficient.  A minimum qualifying standard must remain to be met by all license applicants, which ASHA certification presently provides.  This request eliminates not only the ASHA CCC’s but the requirement for a passing score on the national qualifying examination and completion of the clinical fellowship. We should not be looking to further dilute the qualifications and capabilities, and constituents’ expectations, of the professions.

This is an opportunity for further discussion, but in the present form, this request is not the solution.

Thank you for your consideration.

Respectfully,

Laura Purcell Verdun, M.A., CCC/SLP

I understand the concern with the ties to ASHA for the initial credentials/licensing. However, the board needs to consider the criteria that the initial license offers compared to the suggested 'requirement to hold a master's degree in speech-language pathology, communication disorders, speech and hearing science, or equivalent.'

Currently, initial license requirements include: 

• PRAXIS Scores (which are incorporated into ASHA accredited SLP programs and required for CF/CCCs) - this ensures they have met the standards in terms of the content
• ASHA CCCs (which are earned after a new clinician has completed their clinical fellowship under the supervision of a clinician that holds their ASHA CCCs) - this ensures they have met the standards in terms of clinical practice. The 2-3 semesters of mostly part-time placements are not sufficient for new clinicians. The clinical fellowship year provides continued support and supervision, ensuring safety for both the clinican as well as the clients they serve. 

By requiring this component (ASHA CCCs) just for the initial license, the Board is protecting the clients served as well as the qualifications and readiness of the clinician. 

As proposed, a master's degree in speech-language pathology, communication disorders, speech and hearing science, or equivalent could be provided by any college/university - it does not specify that it is an accredited program. 

It should be noted that ASHA CCCs are not required for renewal of one's BASLP license.

Others have referenced OTs and PTs not needing such requirements. Based on what I have found, each of these professions have similar requirements tied to their national association/board in order to ensure the quality and completion of their program. 

• Occupational therapists are required to submit their certification of credentials from the National Board of Certification of Occupational Therapy (equivalent to SLP CCCs) as well as transcripts as their verification of professional education. http://www.dhp.virginia.gov/Boards/Medicine/ApplicantResources/ApplyforLicense/OccupationalTherapy/
• Physical therapists are required to demonstrate completion of a physical therapy program (which is now a doctor of physical therapy degree) that is approved by the American Physical Therapy Association (or a school outside of the US/Canada which is acceptable to the board) and has satisfactorily passed an examination approved by the board. https://www.dhp.virginia.gov/physicaltherapy/pt_faq.htm

Eliminate the need for ASHA certification to tied with VA licensed. State licenses for our profession should be separate not contingent. There are plenty of other states in this country that allow state licensures without ASHA certification. ASHA does nothing to support our profession, simply using our money to support whatever way the political culture blows. 

I strongly oppose the proposal that initial licensure for Speech Language Pathologists would no longer need the Certificate of Clinical Competence.  The CCC is the culmination of earning a master’s degree, working for a year under the mentorship of a certified SLP ( the Clinical Fellowship Year), and then passing a national exam through the American Speech-Language-Hearing Association (ASHA).  It verifies that the individual possesses the highest qualifications for the field.  A public school SLP treats children with every disability imaginable.  I understand that SLPs are in short supply, but hiring any but the very best professionals for this very important job is not the answer! It is short-sighted and not in the best interest of the children who so desperately need the services.  We as a state would not consider licensing other health professionals without the highest level of qualifications. Why would we do it for SLPs, save for expediency? Please don’t do this!

Going through education which requires a practical component, should be enough to be able to practice. Holding CCC's requires SLPs to spend more money in addition to the amount of money that they paid to receive their education which should readily prepare their students for the job. 

Strongly support removing the requirement of CCC for initial license.  ASHA membership should not be a requirement.

I strongly support this petition. The Commonwealth of Virginia does not need to rely on ASHA to provide a Praxis score and proof of CFY. ASHA has NO bearing on SLP's performance, ethics, and success. 

SLPs in VA should be licensed by BASLP.  There should be no requirement to hold CCC for initial licensure.  Holding the CCC should be an option and a choice.

M.S., CCC-SLP

It should be easier to provide an important service such as diagnosing and treating speech-language impairments. When you make it easier, you jeopardize the pay in the field and the ability to be a trusted profession.  I don't see medical doctors lobbying to make it easier to become an MD. This is a respected field and should remain as such. Pay will only decrease if the path to licensure is as simple as getting an unaccredited degree.

Neither OT nor PT are required to be members of their national associations and SLPs shouldn't be required to do so either.  Each state licensure board requires continuing education, therefore there's no reason for ASHA certification/membership to be necessary, much less mandatory. The mere $25 that’s saved by being a “certified non-member” is insulting. 

K. Durham MCD, CCC-SLP

I strongly support this petition to disengage ASHA certification restricting anything. They no longer represent me as an SLP or support our profession as a whole. 

I strongly support this petition. In NJ, SLP state licensure criteria is very similar to the criteria for earning the ASHA CCC, but it does not tie them together as a mandate to have ASHA CCCs.  It’s very possible for the Board to create its own set of criteria (i.e. Master’s Degree, PRAXIS, xxx number of hours of work experience under a fully licensed SLP) without tying it to a requirement of membership in a private organization.  ASHA is a terrible organization with very obvious partisan political leanings.  It’s a travesty to force SLPs into membership in this private political organization as a condition of state licensure.  

ASHA has become too political and their bias leans one way which does not support the all therapists in the field.  The licensure board can make the requirements the same and therefore maintain quality therapists.

As an SLP, I strongly support eliminating the national requirements - the national organization requires excessive dues that are used to support political ideology that not all members do not agree with.  Continuing education should be the focus of the organization and not used to make political statements.

Support

Support

I strongly support this petition.  I completely agree with another post: That ASHA is a private organization and that the Commonwealth of Virginia government license to practice speech shouldn’t be tethered to a non-government entity. Other states do not require CCCs for licensure. The VA board should create its own set of criteria without tying it to a requirement of membership in a private organization.  

Physical therapists and occupational therapists are not required to pay their representative bodies in order to be considered eligible for state licensure. So why should SLPs? Each state licensure board requires continuing education; therefore, there's no reason for ASHA certification/membership to be necessary.

- MS, CCC-SLP for 25+ years in various settings including hospital, home-based, school, and private practice

I have emailed the board directly with a screen capture of a survey I conducted on the group "Speech Pathologists at Large" (facebook SLP group).  The poll in question was titled, "Do you think that your state licensure should be contingent upon your membership to ASHA?"  The response choices were "Yes," "No," and "Not sure."  Of 361 respondents, 96% responded with "No," with two percent responding with both "Yes" and "Not sure."  Creating a poll was a quick and easy way to gauge SLPs' stance on this without them needing to take the time to fill out a comment on a petition.  Please see the email I sent you all to view the results directly yourselves.  Thank you, Suzanne

Strongly support 

I believe it is important to ensure that licensed SLPs have attended an accredited program, passed a competency exam, and completed a clinical fellowship to learn clinical skills not completed in graduate school.  This is the case with the ASHA CCCs as a pathway to initial licensure.  If they are not required , an alternate pathway should include those pieces.