Compact Confusion: Is the CCC Sneaking Into the Interstate Compact?

4:00AM Apr 1, 2025

Speakers:

Jeanette Benigas

Candice Harrell

Keywords:

Interstate Compact

speech language pathology

Medicaid policy

CCC

ASHA

licensing boards

practice portability

background checks

data system

state legislation

privilege holder

continuing education

financial independence

public comment

conflict of interest.

Hey, fixers. I'm Dr Jeanette Benigas, the owner of Fix SLP, a grassroots advocacy firm here to challenge the status quo in speech language pathology by driving real change from insurance regulations to removing barriers that prevent full autonomy like the CCC, this podcast is your space to learn, engage and take action in the field of speech language pathology. We don't wait for change. We make it so let's fix SLP!

Hey everybody, welcome back. It's Jeanette. I have a new friend with me today. I have Candace Harrell. She's a speech pathologist in North Carolina. Candace was instrumental in helping to change the Medicaid policy through the North Carolina team. But that's not why we're here today. Candace and I both volunteer our time, as if either of us have any extra time to be a part of a small group of clinicians that are sitting in if you want to, say, monitoring the interstate compact meetings. And so that's what we'll be discussing today. We're not going to do any reviews or a minivan meltdown, because we may have a lot to say, but before we get started, I'm just going to let Candace introduce herself. Thanks for coming, Candace!

Yeah, absolutely. You're actually having me back because I was on for a brief segment about the North Carolina Medicaid

okay, I remember it, but that was so long ago that I don't remember it.

Yeah, that's okay.

Welcome back!!!

Thank you. My name is Candace. I'm a SLP in North Carolina. I've been in the adult sphere for most of my career. Kind of done all the settings. I'm in outpatient right now. I started in Oregon, actually, but I've been here for about almost eight years now, which is hard for me to believe, but yeah, that's me.

And somehow we got roped into this. Yes, we got roped into this from our friend Meredith Harold. And really, by roped all she did was ask, and we just said yes. And we started this well before Fix SLP ever started. We started Fix SLP in September of 2023 and we started our interstate compact team in October of 2022 and we started with the purpose of monitoring these administrative meetings, which are open to the public, to ensure that the CCC was not wrapped up into this because wrapping up the CCC into the interstate compact would only solidify ashes power and control over our profession. So I was interested in this topic well before Fix SLP came around. The number one thing we've been monitoring is, are they going to wrap the CCC up into this? If you go to their website, there is nothing about the CCC in the FAQs. There's no information. So it leaves it to interpretation. And I've seen that a lot on social media. So the interstate compact, that administration, the people who are pulling together and launching this thing, have stated over and over again, the CCC cannot and will not be a part of the interstate compact, right? And then they took it a little further right. Candice, you went to the annual meeting where they sort of discussed, there were some lawyers that discussed their role as part of the Compact team. Can you tell me what they said?

Yeah, so during that meeting, someone that was actually present for it, I believe she was an SLP in Oregon, got up to the mic and expressed these concerns that not just us but a lot of people, have had about potential conflicts of interest with ASHA being a primary funder of this, and then all of us wondering like, Okay, what is their return on investment? And are they going to try to wrap the season to this, which would automatically be more power for them, more guaranteed revenue for them all the above. So, yeah, the answer to that question came from a lawyer, and this is kind of the shortened response to what was actually a very thorough response at the meeting. There is precedent for when it comes to compacts for the associations to be primary funders. So most other compacts that you know about have been funded by their version of ASHA, whoever that is. So this isn't an odd thing for them to be doing, but they voiced very clear that they are also concerned about potential conflicts of interest, and there. Very aware of that, and so they have what they consider to be firewalls against ASHA or any of the other funders having any undue influence on this. And the biggest one is that you do not find the seas mentioned anywhere in this compact. It's not in the legislation. It hasn't been there's been no rule made about the seas. The seas do not exist here. They're aware of that conflict of interest, and they stated it very clearly in that meeting, that seas are not a part of this.

And I remember you telling us, because we all take turns going to these meetings, so it's not a huge commitment, but it is. Sometimes they're in the middle of the day. They cancel them at last minute, we don't get noticed, so sometimes it's a little annoying, but we all take turns, just so we can live our lives, and then we share the details in the notes in a group. And I remember Candace sharing, she specifically said they said that if you sort of, what they said was, if you know, are aware of bad behavior, if you're aware of a stakeholder doing something that would give them more influence or power or benefit, they said, reach out to us. That's why we're here. We need to know about it immediately. So they're monitoring, they're watching, and they're not going to allow it. And the thing is, while there is precedent, what there isn't precedent of is these membership associations selling their members a product that is largely required across the country, right? So I think that this is a very unique situation, and like Candace said, that they are very aware of and so it's not going to be required. My problem is that it is also not spelled out on their website. Yeah. So if you had a question about this, you couldn't go to the website to find an answer. And I think that's a problem, because it's the number one question a lot of people have, so we need to get them to add that. Candace said she is going to write in and ask. I am also going to do that, but we're going to have a call to action this week where we give you the information, so you can also write in and ask for them to add that to the FAQs, so employers and other folks who are interested in having this information have an official place to go. This is something I often tell the state teams, or when we're working on Medicaid changes, it doesn't matter what Medicaid in Michigan tells Fix SLP, it doesn't matter what Medicaid in North Carolina tells Candace and the North Carolina team. They need to put out a bulletin. They need to make some type of official statement on their website, because that's where people go to get correct information. And it's the same thing here. People are concerned about this, and so they need to put it out. And this isn't ASHA. This isn't ASHA needing to do this, although we would never see this. It would be great if ASHA also defined on their website where they discuss the interstate compact, that it be highlighted there. And so maybe we'll do a double call to action. I think that's a better idea. Anytime we can get ASHA to do the right thing, we should. So we'll have Elizabeth get together a post, and we'll have that out this week, so you can go and see where to send these requests to, because it's important. So that's thing number one. Thing number two is, you know, everybody listening knows I can be highly critical of ASHA, but I do want to highlight here that this is the reason why we need ASHA. This is the type of activity that ASHA should be engaging in to help clinicians. This is what a membership association should be doing. This is a legitimate thing for them to do. So this is, this is admirable. Oh my gosh, right. Was everybody sitting down for that? I just said something Asher is doing was admirable, but this is admirable, right? Because they're not really getting a return on investment here. However, as a membership association, do they really need to be investing? We've talked about their finances before. They have the money to do this, right? They can afford this, and so this is something that they should and need to be doing, and I applaud them for doing it. And we need to see more of these things from ASHA, and we need to be doing less value of the CCC top. That's not what this podcast is about today. But I did want to put it out there, because I'm not someone who. Just complains when the waitress is awful. I also seek out management to tell them when the waitress has been awesome. So you know, you give flowers where flowers are due. Ash is doing a good thing here and now. I will move on and get back to my cranky ASHA attitude. So that's you'll never hear that again. So yeah, so Candace, we just wanted to come on. We wanted to clarify that. But also, a 10 minute podcast is too short. We also wanted to go through some other funding, not funding, but application things. How much is this going to cost us? Some things still aren't clear. We wanted to kind of run it down for everyone, because not everyone is going to the website to search. We have years worth of notes in front of us. We could probably talk for hours, but this is just a nice little place where people can come and learn a little more in a little chunk of time. So what do you want to talk about next?

So we can give a brief rundown of who's already in this you know that has already passed legislation. I think the first five groups started in like 2020, and more have been added pretty consistently since then.

I'm gonna give you the states that do not have active legislation to enter the compact. They haven't passed anything, and they're they might be working on it, but there's nothing presented yet that's being deliberated by their state government. So we haveCalifornia, North Dakota, South Dakota, Michigan, New Jersey, Connecticut and Massachusetts. Have I missed any Candace that are gray?

I don't think so. But one quick correction, New Jersey actually has legislation in the works right now.

Okay, perfect, and then the states that have legislation on the table, Oregan, Nevada, Arizona, New Mexico, Texas, Illinois, Pennsylvania, New York, New Jersey. That might be it. I think that's it. Yep, that's it. If you want to keep up with this, you can go to their website, aslp, compact.com and there is a heading that says compact map and it is color coded. We will link that up at the Fix SLP website as well, and we'll put it in the show notes, and maybe we'll even put it in some content this week. We always try to theme out our content to go with our podcast. So if you're listening to this in a year from now, you could take a look at the date and then scroll back, but a lot will have changed if you're not listening to this in real time. So those are the states. Those are the states that are left if you did not hear your state, that means they have signed into the compact. So what does that mean? What does it mean when a state has signed into the compact. So I'm in Ohio, how does that change my practice? I think that's another question that people have, and I sometimes see misinformation being shared about it, and I want to be clear with that too, when people are sharing misinformation, that doesn't mean they're being egregious. It just means they don't have all the information. Maybe somebody shared something incorrect with them, or they don't understand the information that's been provided. So we just want to give some clear guidelines on what all of this means if your state has entered the compact.

Right, so it's essentially a formal agreement among states that you know facilitates what we're calling interstate practice, meaning it's a means of practice portability, kind of like how we our driver's license are, where we have our license in our home state, but we can drive all over,

Right

It so if your state has joined and you have a license in good standing in your member state, your home state, you will be eligible to apply for a privilege to practice in other member states. It's not going to be like automatic you will have to apply. And if all that goes according to plan, you will then have be a privilege holder, right? So this is not something that's giving us a national license, so to speak, your home state license is still your license,

and you can't get around that you must hold a license in the state where your permanent address is low. Indicated, yep. So, for example, I am licensed in Michigan, Ohio and Pennsylvania. Right now, Michigan and Pennsylvania are not in the compact. So if I, let's just say I moved to PA. I've lived in PA a variety of times my entire life, since I was born. I was born in PA. We've gone back and forth over the state line a lot of times. If I move back to Pennsylvania and they don't enter the compact, I have lost the privilege to take advantage of the Compact. Even if I keep my Ohio license, it's no longer my home state. So even if I move, man, I lived once on the state line, the middle of the road was the state line. So in that case, even if I moved across the street to Pennsylvania, I would have to be licensed in Pennsylvania, because that's where my permanent address is, and I would no longer be able to take advantage of the privilege if Pennsylvania doesn't enter so correct your state where you live must enter the compact. That's Thing Number one, you are bound by the rules, laws and regulations of your home state. You must do those things.

And in addition to that, when, if so, say you are a privilege holder, if you are seeing somebody in you know, a different state while you're practicing there, you are bound by the scope and the rules in that state.

And that's important. So what Candace just said is really important. I'm going to give you another example. Let's say that Pennsylvania enters the compact. If I were a school, SLP, in Ohio, I could provide services under the privilege, if I follow all of the rules, and we're going to get into that in Pennsylvania, I could go to Pennsylvania and practice. I could give teletherapy in practice. However, this only applies to our speech language pathology state license. What it doesn't apply to school. SLPs are certificates and licenses that you need to work in the schools. So Pennsylvania is a particularly difficult state for schools. They have some extra requirements. There's some extra things. It has gotten better over the years, but there's still a lot of hoops to jump through to be allowed to practice in the schools in Pennsylvania. So if I'm taking advantage of the interstate compact, I'm covered as far as speech language pathology goes. I am not covered as far as whatever it takes to get a certificate or license to work in that state in the schools, correct. So I want everyone to understand that this is not a free for all. It's not like, Hey guys, hey, I have this. I, you know, we passed it, and now I'm going to do teletherapy all over the country. You have to follow anything outside of our license. You have to follow you have to follow it and do it.

Same goes for you know, insurance billing, Medicaid, if we talked about they require a jurisprudence exam in that state, so you are still bound by all of those things according to each state. There's nothing about the compact that's like homogenizing our scopes and regulations. They don't have the power to do that. This Compact Commission does not have the authority to tell your state board or any of those other entities to do anything

Right. And so what this is an agreement between are the state licensing boards basically so Ohio is saying to Pennsylvania, your your residents can practice here with a PA Home license as a speech pathologist. There's reciprocity now, but they can only give reciprocity for the license. They don't have control or power over like the state, the State Department of Education, right? Or any other, any other state department that's controlling our practice. They can't change that. It's just one board agreeing with another board for reciprocity.

Right. And another thing to mention, and we can probably get more into this when we discuss like the cost involved is that just because your state has joined into this, you are not automatically getting. Would access to all other states. Immediately, you are going to apply and request privileges per state for the states that you need. So if I just need to hop over the border to South Carolina and Virginia, I'm going to request for those states. If you're someone that does telehealth and needs every single one you're going to be requesting per state. So don't assume that just because your state is involved in this, that you can just practice anywhere that you want automatically.

So let's talk about that cost. So it is still unclear how much it will cost,

So we have some idea right as of right now. So you will pay a fee to the Compact Commission, which is as of right now. The idea there is $50 I don't think it's been completely approved by the Commission yet, but that's the number that's out there right now.

Is it $50 per year or a $50 one time fee?

Okay, so it's $50 per state that you want privileges in. So it's you know, if you need 10 states, you're paying $50 for each of those. And then on top of that, you will pay a fee to the state boards, which will be determined by each state individually. And the compact, again, cannot determine what that fee is. That's up to the states. Some might choose to absorb the cost. Some might choose to pass it on. And then the frequency at which you will be paying these is going to be in accordance with how often you pay your state license fees. So if you're annually in your state, that's going to be how often you pay, if you're on like a two year, three year cycle, that will be how often you pay, as far as I understand it right now.

Do we know if we're paying that $50 though, one time or biannually, or triangle tri annually?

It's going to depend on how often you're paying your state licensing fees, as far as I understand it.

Hopefully we'll get some clarification on that, but I've run the math in my head and there, the idea of this is that it would save people money and cost less, not but I don't think that's going to be the case in for some of this. I think this could cost people more money because of that $50 fee every time.

Right. So, like, if we were to assume, so you're paying the $50 fee per state to the commission, and then if we just, you know, we're hypothetical, and said that the states were going to match that, and you have to pay 100 to them too. That's $100 per state. So if you need all these states, that's going to be as of right now, you know $3,400 that you might be paying every year, every couple of years.

Right. But you know, hopefully states are doing this math. Hopefully they're taking this into consideration because of that $50 fee. So let's just say that a state license is $100 every two years. So we're gonna pay the 50. We would need them to come in under the $100 you know, for this to make sense, right? If they say you're just gonna pay our state license fee. It's now more expensive, and it's cheaper just to apply for their license. Yep. And then you have the hassle of, like, having to provide all the things but you know, it could, it could end up being more money, and that's what's undetermined at this time.

Yeah. So I think it's going to come down to people's personal needs here, you know, in which states they need in a in how many like, you know, like you're saying, it might just make more sense for me to just apply directly to South Carolina and Virginia, whether, rather than doing it all through this so kind of to be determined there. I do think it will have a benefit as far as logistics. I mean, if you're someone that does need to practice in a lot of states, I'm sure this would be a much quicker kind of fluid way to do it, rather than applying individually and waiting on all those different wait times and submitting the paperwork to all those different people, you know. So I do think that that's a big fit here.

This is definitely a good thing. We're just trying to point out some of the things people aren't thinking about. The other thing is, if you're in and out of states, like right now, I'm not practicing in Michigan, but I hold a Michigan license, I could call Michigan and ask them to and not every state has this. I know Pennsylvania and Ohio both have it. You can change to an inactive status, which is typically less money. And again, I've been in and out of Pennsylvania. You know, when I moved to Pennsylvania, all the way to the East Coast, I made my. Ohio license inactive, because I knew there was a very good chance I would be returning someday. So that fee was a lot cheaper than the yearly fee, or the BI yearly fee to hold the license and have an active license. So that's another way where the this interstate compact would be more expensive, because if you're not practicing in that state, and you want to hold on to it, probably making it inactive is going to be cheaper than paying the $50 and the fee for the the license on whatever cycle they're on. So that's something else to think about. Like, I'm probably just gonna, if pa passes this thing, I'm probably just still gonna keep my PA license. I probably won't take advantage of the Compact because, again, I'm always like, using it, not using it. And it's cheaper for me just to make it inactive than to, you know, pay all those fees.

Now that you brought that up, I don't think that we know, at least at this point in the game, if the compact will eventually implement anything similar to where you could kind of make some inactive, you know, I don't, I don't think I've heard that come up yet. That's definitely something we should keep our ears out for

I haven't, and it would be a great thing if they did. I think it's a lot more administration stuff that's going to end up costing more money, maybe. But who knows? Who knows?

Then another thing to point out about the fees that they did bring up in a recent meeting, like obviously, their goal with the fees right now is to become financially independent so they're no longer the ash is no longer, you know, contributing. They want to stand on their own two feet. They did mention that as this goes along, those fees could change so they could lessen in the future. But again, time will tell, to be determined,

Right. And to point out there too, I've also heard that discussed in the meeting for them to become financially independent. That means they are now their own operating entity. So that means a group like ASHA, who's helping this get off the ground, will no longer be a part of it. I'm sure there will be people from ASHA on the board or whatever, but they're not going to play the role that they're playing right now with the finances. And so that's sort of a phase out of ashes contribution that their financial contribution will go away.

Yep, um, and we, I don't know if this is jumping near too far in the wrong direction, but ashes, other big role here has been, they've been the primary people getting states on board. So they've been the ones working with the states to pass legislation and all of that. And in all of this, I think it's also important to point out that their members that are on the compact commissions are ex officio members. Do you know what that means?

I don't. Or maybe I do, but I bet a lot of people don't know who are listening. Do you know? Can you explain it?

Yes, so okay, means that you do not vote. So anybody from ASHA that is on those committees does not have voting power. They can provide information, they can give an opinion, but they cannot vote on any of this. So that's another one of those firewalls that they mentioned in that meeting, you know, to avoid conflicts of interest and having ASHA or any of the other payers, you know, having undue influence on the rules that they're passing, etc.

Yeah, that's great. Another question that I think has come up a few times is, will I be able to use this in my nine month post graduate experience? And that answer is no, because this is reciprocity between an actual license and you are not fully licensed in any state until you complete that nine month experience, yep, with the exception right now, by the way, of North Dakota, which is possibly one reason why they are not in this Compact yet. I believe that they have some legislation going that is going to add the nine month experience. I believe someone in the state reached out to me to tell me that it could have been a dream. We don't have a we don't have a team there yet. So I'm not super up on what's happening there, but I'm almost positive they are working on that. Okay, so that that will be helpful. So maybe that's maybe that is in the works too. You know, who else isn't in the compact that we didn't name is Hawaii? Oh yeah, Hawaii is not in the interstate compact. I don't know the scenario there, but they're another. State where the state license requirements are lacking. So that could be a reason why the state of Hawaii does not require continuing education to maintain their license. So I don't know. I don't know what the compact says. So on the on the topic of continuing education, you do still have to do it per your state license. So it's not like you have to do extra to be a part of the Compact. Whatever your home state requires is the continuing education that you have to continue to do.

Yep, home state still the rule of the road there. We also didn't mention someone that is that has passed legislation recently, is Virgin Islands territory. So those are also potentially in the in the mix here. I haven't heard about anybody else. Something else that we could talk about is kind of like the remaining hurdles that are keeping this thing from being active yet, because privileges are not yet being issued. They're not officially up and running.

I feel like it keeps getting rolled back from the beginning of this little team, dates have come and gone for rollout keeps getting pushed back, yeah, by years, literally by years. And so I think some people think, Oh, it'll never happen. It is going to happen. It is. They're they're getting close. And I think are they trialing it in a couple of the states? They're starting to onboard in some of the first entering states?

Yeah. So one of the the kind of biggest things that stalled this process is the creation of the data system. And this actually, they decided for this data system to be a joint venture between us, OT and counseling compacts, which are all trying to get up and running right now, so that way they can split the cost between all of us. I think the estimated cost of this is like 1.5 million. So we're each paying like $500,000 but finding someone to build out the data system and just everything involved, there has been a long process, but they finally have that going and you can actually find out more information at compact connect.org That's a website dedicated just to the data system development, right? So that's going to be the system that all the states, all the people that are requesting privileges are logging into to complete the process. So it has to be something that all of these states can have fluid access to right? The other thing that's been a hold up is background checks. So the legislat, the model legislation that they put out there for all the states to use, you know, to get this passed, included the requirement for background checks. But it turns out that the FBI has an issue with background checks related to compacts. I don't know the full reason why there, but that's currently a hold up. So all these states have said we require this, but they can't actually follow through on it.

Hmm, I haven't been in any meetings where they've discussed that, so that's an interesting point as well. I wonder how long that will take to flesh out, and I wonder if then all of these states that have signed in will have to re sign?

So yeah, this is, I don't know the full answer here, but one of the last meetings I was in, they said that they were checking with, I think the nursing compact to see a compact has been up and running for a long time. If our Compact Commission has the authority to tell states that they don't have to do the background check, at least while this is all in flux, given but it's in their legislation, so it's unclear if the compact can do anything to remedy this little hiccup that's happened. So I'm not sure kind of it was a seemed like a cart before the horse situation. You know that they put something in there before they knew. I guess it could actually be followed through on

but isn't that how we do it in speech pathology? As a medical professional, isn't that how we started thickening liquids before we knew the actual outcomes on the body systems?

Oh yeah, World of dysphasia is like, hold my beer, right?

Yeah. So I don't know. What else have we required? Have we covered everything?

Those were the big points that I like, like you were mentioning before. Though I do think that they want to start soft onboarding some states into the data system this spring, with the hopes that privileges are being done. Given out sometime in summer. So that's the current timeline. Will we see that who knows? Right? Who knows.

Right now on their website, it says they anticipate applications for compact privileges available mid to late 2025 so that could be like December 24 they've given themselves a six month window there.

Yeah. Another thing you know, just for all the people listening like we said, These meetings are open to the public, the compact people have been welcoming, you know, when I've been there and open to questions, when we've written in with concerns, they've gotten back to us really pretty quickly. They most of them are doing this on volunteer time, putting in their blood, sweat and tears for years now. So if other people are interested in this, I mean, go to the meetings, you know, keep your eye out on the website.

And if you're super heavily interested in this, reach out to me privately at team@fixslp.com and we can talk a little bit more. I am actually shocked at how welcoming they are. I don't know if they still do this. I haven't really paid attention, but early on, they occasionally would welcome me by name, because I would be the only person not on the compact committee in the meeting, and they would thank me for being there. And it it's interesting, because, as I said, this was before Fix SLP. And once Fix SLP started, and once we started launching state teams and attending state licensing board meetings. I thought that outsiders would be welcomed like they're welcomed in the interstate compact meeting. And boy, was I freaking wrong. So it is not even so much that it's fixed. SLP, and we're abrasive. Sometimes these people don't even know who we are. But there is a large swing between how I have seen myself treated in a compact meeting, even now I'm still going to the meetings, and no one is ever unkind. You know, we are still very welcomed. I remember in one of the last meetings, they were running late, and I was literally the only one in the meeting. And so I wrote in the chat, because they were worried about public comment. I have no public comment, and I'm the only one here, so if you want to keep rolling, you can keep rolling. And they still stopped and said, Are you sure you don't have anything to say? Yeah, but I that has not been the case.

No, they're like, afraid of license here.

Yeah, in state licensing board meetings, it's, it's, it's a large swing, um, so be prepared for that. If you have, you know, if you attend these meetings and then go to a state licensing board meeting in your own state, people have very different attitudes, which brings me to one of the reasons I know this is because I have attended a lot of Delaware State Licensing Board meetings. And I wanted to touch on this really briefly, because we said at the top of the episode that the CCC is not going to be required, right? But we still have these four outstanding states that require the CCC for initial licensure. Only. Virginia has some legislation. They have some proposals on the table to remove that requirement. That was one of the states that was thinking about removing that CCC requirement quite some time ago, but they held off because they wanted to see what was happening with the compact. So we had a call to action where people wrote in with their public comment on their website. I haven't followed up to see what has come of that, but and so now that's prompting me to see that I probably should, but this was a proposal by the State Board for their own license, so I can't imagine why it wouldn't happen. I read all of the public comments. They were largely in support of removing the CCC for initial application. And the couple that weren't, you could tell that they had not actually read what it said, so some of their responses didn't even make sense. So anyway, if you are in one of those four states, you will still have to get the CCC when you apply for your state license, for your home license, but in none of those states are is the CCC required to maintain your state license, which means if you don't have the CCC, you will not have to have it to take advantage. Much of the privilege in those states, because once you're licensed, you can apply for the privilege. So and there was some outstanding question about Delaware, this is how I got even more deeply into this topic. Because Delaware, if you've been following us, right before Fix SLP started four days before Fix SLP made its very first post. Delaware passed a law that you had to have the CCC in Delaware to practice. And so our team, we have, like a mighty little team of Delaware SLPs, who are on top of this. They're in the meetings, and they have successfully been able to influence the board to clarify and change that you will not need the CCC on an ongoing basis. And part of that argument that we put forward was the CCC can't and won't be a part of this compact, and so you've already signed into the compact saying that people from other states can take advantage of the Compact. People are dropping their CCCS. So you are a state that is surrounded by a bunch of other states where the CCC is not going to be required. So theoretically, you would be requiring the CCC of your own practitioners, but allowing people from outside of the state and not having practice in your state without the CCC through their license, because this is a reciprocity through license and your requirement there is only for your license, an outsider would not have to follow that rule. And I think that was an oh shit moment for them. Yeah, truly, because now we have the problem of, will people move? Because it's going to be more expensive to practice in the state of Delaware, if you do this, people could just move over the state line, live in a state that's in the compact, and then take advantage of the compact to work in your state. You could theoretically lose clinicians in your state over this, or at least Delaware residents. And I mean, that's a big people are like, picking up and moving, but when it comes to people moving to the east coast, certainly you're looking at cost of living and all of those things as you're making those decisions. And so yeah, so they have defined it is not official yet. It's it's back in revision, and they're going to talk about it in the April meeting again, and I think there will be a vote, an official vote coming up very soon. I think it has to go up for public comment one more time, even just a few more weeks, because they've made these revisions to clarify that you do not need the CCC to maintain a license in Delaware. So again, public vote or public comment, then they'll take a vote if they don't make any other substantial changes. But that's why I have been so deeply invested in this topic. Was because we were we were trying to make sure that Delaware wasn't going backwards and it, and they did. They have done the right thing again. It's not official, but they have to maintain that CCC at application, because that is the law, and they've been like that anyway. So it's nothing new, but I just want to clarify that that these states that that are requiring it for initial licensure, four, hopefully three soon. Um, it won't apply to this compact at all. And I have also confirmed that verbally. So you said, Candace, you can, you can attend the compact meetings, but you also have compact representatives in your state, yep, and you can find it on their website, yeah, yeah. You can find that on their website. And I will mention there that the information that these people have ranges broadly. So when we are in these meetings, what it's like five or six or seven people? It's not like these interstate compact representatives are in any of these meetings ever. I'm not even sure where they get their information. Do you know Candace?

No, not really. I mean, I think they're encouraged to attend these things, but, like, I don't know if they have a requirement of x per year. I really don't know.

So the meetings are in the middle of the day. These are working clinicians, so we're not slamming them for not being at these meetings, but asking them a question might not lead you to the answer you're probably gonna get. I don't know. I'll find out if they even say that to you. So I. Just be aware of that. You're much better off going straight to the compact to ask them your questions. You'll get the answer fast. It'll be accurate. It'll be more direct. And there is on their FAQ, at the bottom of their FAQ, it says something like, what if I have a question that isn't answered? Here, there's a contact form, so you can click it and fill out the contact form and ask your question. But I've been very lucky in Ohio that the executive director, who is a lawyer of the Ohio State license, is extremely active on the interstate compact Committee. He has specific roles. I've had him on the phone multiple times, and he is wonderful. And there have been times where he's like, I'm not sure, especially when it comes to the CCC stuff, he always wants to just confirm and make sure. And I've told him before, if you don't, if what we've agreed here, that this is what we think and know is accurate, don't even worry about calling me back or writing back to me. And he still does. He'll like, Okay, I won't worry about and then he does anyway. So I just shout out to Greg Thornton in Ohio. He's amazing, and he has been very helpful in helping me understand all of this. So just reach out to the board.

Yeah, when I've reached out to them, just whatever that link is on their site that says, contact us. You fill it out that it goes then to the most appropriate committee or person to respond to you. And that's like, I say, I usually get a response back within, you know, 24 or 48 hours, which is pretty lickety split compared to

Yeah

other places.

So I think this is a good place to wrap up. You know, we don't have all of the information, as you heard, we will link up the state compact website again. In the show notes, you'll see some content posted throughout the week. Call to Action is we're gonna we're gonna hit ASHA and we're gonna hit the compact committee. We're gonna ask them to make statements on their website to clarify, because lots of SLPs have this question, and and I think it is completely appropriate to be answered by the compact. The only thing that I could see being a problem is one of the people, I think, who answers these questions is She's a paid employee of ASHA, correct? Yep. So there might be some pushback. And if we're getting that, you know, Fix SLP is going to dig into that

anybody has a concern or even a sniff of a conflict of interest, they want to hear about it. I mean, it was a lawyer that gave that response in the meeting. You know, that's part of why they're there.

So if you have one of these concerns, reach out to me, Candace, and I have notes about how to get a hold of the appropriate people. When you have these concerns, I would say, especially if it is ASHA related, you're probably not going to put in that Contact Us form, because someone from ASHA could be the one receiving that and responding to it. So there are some other avenues. We haven't really noticed anything yet. Everything seems to be status quo. We're pleased. We have no complaints. The only complaint is there's no clarification on the FAQ, and that's an easy fix, so hopefully they'll do the right thing. Yeah, yeah. So thanks for joining today, Candace, if anything comes up in the next several years, because it could take that long. Maybe we'll have you back briefly for a little update or something on another episode, or I can do it, but I think this is sufficient for now. We've got some questions answered. We have some outstanding questions, and now let's just stay tuned so

Always happy to come back if you need me.

Yeah, thanks, Candace. All right, everybody. We will see you next week. Thanks for fixing it!