Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Audiology and Speech-Language Pathology
 
chapter
Regulations Governing the Practice of Audiology and Speech-Language Pathology [18 VAC 30 ‑ 21]
Action Regulatory Reduction 2024
Stage Fast-Track
Comment Period Ended on 1/29/2025
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1/28/25  2:47 pm
Commenter: Daniel

In support of new licensing without CCC-A requirement
 

As others have suggested -- and as others might anecdotally report --  the requirement for new audiologists in Virginia to hold a CCC-A in order to obtain licensure likely deters some competent providers from practicing in the Commonwealth. Should a prospective licensee prove completion of all degree requirements from an accredited college or university, as well as a passing score on the Praxis, then ASHA or ABA certification ought to be seen as redundant. 

Processing of certificate applications is estimated to take 4-6 weeks. Therefore, for new practitioners, a certificate requirement extends the Virginia licensing process unnecessarily, putting further strain on individuals competing to join the work force.

The criteria for reinstatement of one's CCC-A appear intentionally burdensome, as if to deter providers from considering dropping the certificate when its value fails to meet the cost of annual renewal. Currently, a Praxis retake is required along with a $371-$400 reinstatement fee. Therefore, for experienced providers outside the Commonwealth who have dropped their certificate but wish to join our workforce, the CCC-A requirement can add two months or more of processing time to the licensing process. 

I support approving new audiologist license applications without the requirement of a CCC-A, arguing that such a change would attract more professionals to the Commonwealth by removing a superfluous obstacle without sacrificing generally accepted standards for clinical competency. 

CommentID: 230172