I am writing in strong support of the proposed changes to the Virginia Board of Audiology and Speech-Language Pathology regulations, particularly regarding the development of an alternative pathway to licensure that does not require the Certificate of Clinical Competence (CCC).

Establishing an alternative pathway to licensure without the CCC is a necessary step that aligns more effectively with the needs of the profession and the individuals we serve. The CCC is a third-party, nonprofit certification product that generates substantial revenue for the American Speech-Language-Hearing Association (ASHA). Furthermore, it does not guarantee any initial or ongoing competency across the scope of SLP beyond what is already assured by Virginia’s licensing standards. While the CCC may hold value for some professionals, it should NOT be the sole pathway to licensure when Virginia’s licensing requirements and continuing education standards already ensure competence and accountability. Its exclusivity creates unnecessary barriers, restricting access to the profession and preventing qualified individuals from entering or remaining in the field—particularly in underserved areas. Implementing alternative pathways will promote greater flexibility and inclusivity while maintaining high professional standards to ensure quality care.

The proposed change represents a pivotal opportunity to modernize licensure for SLPs in Virginia. By establishing an alternative pathway to licensure without the CCC, the Board can remove unnecessary barriers that hinder accessibility and choice in the profession. These reforms will empower clinicians to pursue meaningful growth, attract more professionals to underserved areas, and reduce administrative burdens for both the Board and practitioners while maintaining the high standards of care that patients deserve.

I strongly urge the Board to adopt this change and remove the ASHA CCC requirement for state licensure. Thank you for your commitment to advancing the field of SLP in Virginia.

Sincerely,
Anonymous
Speech-Language Pathologist and Advocate