Thank you for creating this guidance document! I appreciate the specific references to 18VAC30-21-140 within the document. Regarding 18VAC30-21-140 (1-7), I appreciate its alignment and near-congruence with ASHA’s statements/policies on the SLPA’s scope of practice (https://www.asha.org/assistants-certification-program/slpa-faqs/). And regarding 18VAC30-21-140 E, I appreciate its alignment with other state policies related to SLPA supervision (California, Colorado, Georgia, and Maryland, to name a few states, similarly limit the number of full-time SLPA-supervisees to two).

Further reviewing 18VAC30-21-140, I do suggest a few modifications for future consideration. If these questions/concerns are already addressed within existing regulatory or guidance documents, my sincerest apologies. 

• 18VAC30-21-140(5) reads that SLPAs may "assist the client in repetitive use of such [AAC] devices." As an SLP who frequently serves AAC users, “repetitive use” seems detached from the intervention strategies typically implemented with this population. Perhaps “instruct the client in the use of such devices” would be more accurate (and worded similarly to ASHA policy on the SLPA scope of practice).

• ASHA adds that SLPAs may “assist the speech-language pathologist with bilingual translation during screening and assessment activities exclusive of interpretation” and “serve as interpreter for patients, clients, students, and families who do not speak English.” While these activities may arguably be encapsulated by 18VAC30-21-140(8), outlining the SLPAs role in bilingual translation/interpretation services may provide some assurances to practitioners who are already, uncertainly, utilizing their SLPAs in this capacity or unaware that they may do so.

• Does/should supervision requirements differ when an SLPA’s client is medically fragile? ASHA states “100% direct supervision of SLPAs for medically fragile students, patients, or clients is required,” though I could not find a similar statement in 18VAC30-21-140. 

And a few exceedingly minor notes on the guidance document itself:

• It may have been helpful to some readers to include an additional reference to 18VAC30-21- 140(1-8) in the response to Question 4.

• The response to Question 6 reads “No, the SLP is required to provide onsite supervision of a minimum of [at] least two client sessions per SLPA every 30 days as provided in the response to Question 4.” I think the latter part was meant to say “...in the response to Question 5."

• As one other commenter noted, perhaps the inclusion of 18VAC30-21-140 A in the response to Question 8?