I am writing to provide feedback on the proposed changes to the speech-language pathology licensing regulations in Virginia.

While the American Speech-Language-Hearing Association (ASHA) has been an invaluable resource and partner for speech-language pathologists in Virginia—particularly in their collaborative efforts during the 2024 legislative session on interstate compact legislation—the current requirement for the Certificate of Clinical Competence (CCC) creates an unnecessary barrier to licensure in the state.

The CCC, a third-party certification issued by ASHA, holds significant value for many professionals. However, it should not be the sole pathway to licensure when Virginia's existing licensing requirements, along with its continuing education standards, already ensure the competence and accountability of licensed professionals.

I recommend that Virginia revise its licensing requirements to focus on applicants' educational and clinical practicum experiences, which can be effectively assessed through their academic records and Praxis examination scores. The CCC should not be a mandatory requirement for licensure.

As our profession continues to evolve, it is critical that practitioners stay current with evidence-based practices and research. This can be achieved through the ongoing requirement of high-quality professional education. Maintaining board-approved continuing education is essential for consistency and credibility across the field. I suggest that the board establish a list of accredited continuing education providers from which speech-language pathologists (SLPs) and audiologists can meet their licensure requirements.

Additionally, I strongly oppose the differentiation of licensing fees based on employment settings. Such a distinction creates unnecessary barriers within the profession. Many SLPs work across multiple settings, and if this proposal passes, it may require practitioners to obtain multiple licenses within a single state. As an SLP practicing in the greater Washington, D.C. area, I am already required to hold licenses in multiple states. An additional licensing burden within Virginia would only complicate this further.

Finally, the proposed restriction on school-based SLPs practicing outside the public-school setting should be repealed. Virginia already has a significant shortage of SLPs in our educational system. This provision would impose an unnecessary administrative burden and potentially limit the availability of SLPs to serve school populations. Allowing flexibility in practice settings is crucial to ensuring greater access to services for all individuals.

Thank you for your time and consideration of these points. I appreciate the opportunity to contribute to this important discussion and value the work of the board in reviewing these standards.