Unlicensed, Unclear, and Untamed - The SLPA Regulation Mess

4:04AM Apr 22, 2025

Speakers:

Jeanette Benigas

Elizabeth Nielsen

Minivan Meltdown

Keywords:

SLPA regulation

speech language pathology

ASHA

C-SLPA

clinical autonomy

supervision requirements

state licensing boards

patient care

training standards

advocacy

state teams

regulatory consistency

SLP aides

professional development

state boards.

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, I'm not here to vent, but I want to just thank fix SLP for teaching me about how ASHA has not been utilizing our dues with clarity and transparency because of your advocacy and information, I have just let my C's lapse, and had a conversation with my employer regarding the underhanded policies and ways that ASHA has been using our dues, and my employer was very open to that conversation. So I just wanted to say thank you guys, and I am proud to be a sustaining partner. I am going to send your information to my other graduate school friends, and I'm just very grateful for your work. That wasn't a meltdown, but it came in after Elizabeth and I recorded the podcast that was a recording on our meltdown in our minivan. Line you can head to fix slp.com, scroll down just a little bit, and you'll see a button that says, record here. You have three minutes to climb into our fixer minivan and meltdown. We don't include the tissues. You can rage about your job, share your SLP sorrows. I even say you can share about the hot PT from your PRN job. We don't care. We just like hearing from you. So we like to say it's like a rage room a coffee shop and a martini bar all rolled into one, but better. So please take a minute go shoot us a message. And here's today's episode.

Hey everybody. Welcome back to the Fix SLP podcast. It's Jeanette. We're gonna say what needs to be said today. That's what we've been doing. I've got Elizabeth Nielsen, our content coordinator, with me today. Preston is not here, so Elizabeth has very big shoes to fill. We're gonna stir the pot a little bit today. We're gonna discuss one of our, I think, most requested topics over the last year, probably, and we've been working on this. And I will tell people we're working on it. It's time to unveil. We're going to dive into the confusing, inconsistent and really downright chaotic world of SLPA regulation. In the United States, we've seen a boom in personnel. With that boom has come a very clear lack of clarity, oversight and consistency. It's not just a policy issue. This is becoming a patient care issue. States are doing the best they can, so we're going to talk about it. Hey, Elizabeth!

Hey, how are you?

It's spring break. It's it's spring break. So how am I already crazy? We're 12 hours. Okay, yeah, so with that, everybody, we do do this in real life. I have six kids outside my house in the yard. I have locked all of the doors, but there are two doorbells. My husband took the day off, but I don't have a podcast studio, so if you hear extra noise or power tools or ringing bells, I'm sorry. We're doing the best we can. So... here we are.

We got this. We got this. Yeah, I'm excited to talk to you about this today, because I know we've all been kind of waiting just kind of the right time to put this out. And you know, if you've ever supervised or trained or been asked to just clean up after an SLPA with zero guidance, you know this episode is definitely for you guys. We are very grateful for all the help that we get on the fixed SLP area. So we've had so many people that are helping in all of our states, and we had someone who helped compile a massive 50 state SLPA regulation review, and it's pretty impressive. We will be putting that out on the fixed SLP website. So it's great. It's breaks it down state by state what you need to know. So some states just don't regulate at all. Some require an associate's degree. Some a bachelor's some just on the job training. And the rules change depending on the setting. So it's kind of like the wild wild west out there. So hopefully this will Be a great breakdown for all of you guys. And looking at the massive spreadsheet that we're going to have on the website, it's going to be super helpful for that breakdown.

Yeah, what we didn't do, and what is so impressive because everything else we've done so far in terms of these spreadsheets and and regulations, is we have done a crowd sourced contribution. So we will come to you guys and say, Hey, can you email us about this thing? And then we go through those emails, we double check things, we click links and regulations. This time, we did not do that because stuff is so all over the place that this fixer, it probably has been doing this for a year. I don't know how long, but it has been a very long time that this person has been working on this. For us, wants to be completely anonymous. Didn't even want to come on and talk about the work on the podcast today. We totally respect it. We love it. But the next piece is going to be that you guys check this stuff for your state and email us and let us know. I think for this, we are going to have you email states@fixslp.com, and that'll be at the top of the spreadsheet. But things are changing rapidly, so we could have put something in for a state that has already changed, because there are states with regulations and bills and things that are passing or not passing, and so if you find something that is not correct or that has been changed, all we ask is that you provide us the link to the actual regulation. We are never going to put something forward unless there is an actual regulation that we can point to that says this is the rule my employer said is not enough. We need to see what your state, like the state Practice Act, or the license board, or whatever actually says. So that's what we need. Send it our way, but we kind of need to frame this for our listeners, so they have definitions of who does what and what those things look like. There are two main different ways that a licensed speech language pathologist can be assisted. One is an SLPA, which I think is what we are most familiar with. Typically, you need to at least have a bachelor's degree in communication sciences and disorders or speech language pathology or whatever it is that that university offers. But in some cases, all you need is an associate's degree. So for an SLPA, you at least need to be degreed somehow. Some states are going to have a licensure process or registration. ASHA has their own certification, the C-SLPA, which we'll talk about as we get through this podcast episode. A little more every state has different requirements, but what is consistent is that they work under the supervision of a licensed SLP. They can be doing therapy sessions with preset goals. They cannot write the goals the SLP does that. They can collect data, they can report progress. They can assist with screenings, but not do anything diagnostic, and they can assist with documentation. So they're not allowed to treat, to create treatment plans. They're not allowed to diagnose, and they can't adjust a therapy plan without the SLP instructing them to do so. So that's an SLPA. Then other type of assistance we can get is an SLP aide, an aide, not an assistant. Sometimes this is called an SLP tech or an SLP parapro, a paraprofessional. All you need for that, typically, is a high school diploma or equivalent. There is no formal degree or education required. This is generally not a licensed position, although some training might be required by the employer or the state, and they do require direct supervision, and sometimes constant supervision by an SLP. So it's not like the SLP can be at the high school while the aide is at the elementary school. There's typically much stricter standards on where physical bodies can be. What can they do? They can prep therapy materials. They can manage scheduling and clerical tasks. They can assist during therapy, like behavior management, but they're not supposed to be providing the actual therapy. They can clean and organize spaces. They cannot give a therapy service, they cannot interpret data, and they can't work independently with clients. So those are the definitions, the actual definitions of what those things are now. Are there states that maybe use these terms differently and interchangably, maybe, maybe that is a thing. And so as we talk through this today, maybe it'll come up.

Yeah, let's start with some training requirements. Colorado requires the national C-SLPA for early intervention, and that is through ASHA. That's the equivalent of the CCC. Other states don't even mention it. In Georgia, you can be an SLP aide, not the SLPA, but the SLP aide with the high school diploma, where in Illinois you need the SLPA, so the bachelor's degree and the 100 hours of supervised practicum. And so there's a big difference there. Then, so you can see why. With the aide with a D, you just 40 hours of on the job training. They're going to show you, okay, this is what we do here. This is what we do here. This is how we manage the behavior. But then in Illinois, supervised practicum is supervised practicum. We all know what that looks like. There's big difference there. So that's why the aide with a D can't touch patients independently or students, so huge difference. So in Colorado, it requires the national the C-SLPA like what Jeanette said, and that's the equivalent to like the CCC for SLPs. So you need the C-SLPA for early intervention. Other states don't even mention the C-SLPA. Again, widely different levels of what's required, state by state for the C-SLPA. And that's where just the inconsistency just creates inequity for clinicians, confusion for administrators, especially if in Georgia, if you're looking at the SLP aide versus the SLPA, what are these SLP aides really doing in Georgia? Then, are they doing more than they what they are actually able to do just because there's burnout, there's high case loads. How regulated is that? And so there's just risks in the schools for patients everywhere, with the wide range and different names for everything and regulations for it.

So I do want to be really clear about this Fix SLP is not against SLPAs or SLP aides. We think that in some cases, especially with these high case loads in schools, they are absolutely needed. I do have concerns about what might happen with these types of professionals in medical settings, especially when we have SLPs traveling from sniff to sniff to sniff, just trying to create a full time job for themselves. But I think in school settings, especially where caseload and workload is high, these are good things to have, so we're not against them. So I just want to be very clear with that. I also want to say very clearly that all of this confusion is not the fault of the assistants or the aides. It's the fault of the system that launched them into practice with unclear expectations, without realizing that there are different names for things and different states have different regulations or not. In some states, they let SLPAs treat medically fragile patients with almost no clinical oversight. To me, that's a little bit of a problem that can be a risk for patients. Others require weeks and weeks and weeks of direct supervision before they can touch a caseload. So it's kind of madness. So we found ourselves in this position where, I think maybe in the 40s, SLPs found themselves that we have this job where there is no regulation and no oversight, really, at least nationally. The difference is, when SLPs started, there were also no state licensing boards, and so that's when the CCC was created to help standardize practice across the nation. And then as state licensing boards popped up across all 50 states and Washington DC, it made the CCC irrelevant. So that's how SLPs have found themselves in the place that they're in. Well, we know how much ASHA likes to grab money. There is no national standard at the moment, and because ASHA has now tied its name to the C-SLPA, which is like the CCC for SLPs, a lot of people presume it's required everywhere, just like a lot of people presume that the CCC is required for an SLP to practice. And you know what I'm about to say, it's not. It's not, and in many places, thank goodness, states are getting wiser and smarter, it's not even recognized, and so we just want to be really, really clear. I hope everybody is listening right now, if SLPs do not start advocating for our counterparts, for our SLPAs, and if SLPAs don't stand up and get this under control with very and loud and persistent advocacy in their states, they are going to find themselves exactly where SLPs are right now, tethered to a national organization that has zero business controlling you or your availability to practice via a bug certification that has zero evidence behind it. If you think that ASHA has done research and collected evidence on the effectiveness of an SLPA or the effectiveness of whatever the hell they're requiring for that C-SLPA, you are sadly mistaken. This is another money grab. That's what's happening here. And so ASHA sees an opportunity to be the leader. And so they're they've created this certification that states are beginning to lean into if you don't want that for your state. Because here's the other thing, if your state doesn't require the CCC, but they require the C-SLPA. Guess what? You're going to have to have the CCC to supervise your assistant.

Mm-hmm

So it is another way that they are going to sneakily just get in there, get into the fabric of what we have to do to practice if you have 100 student workload and you need that SLPA, and your state has said you need the C-SLPA to be an assistant, you're gonna have to go buy that CCC if you want that help.

Yeah

Don't be fooled. ASHA is not dumb. Don't be fooled. They know what they're doing. They know.

Yeah, it's gatekeeping, and it's harming everyone. So like when only CCC holders can supervise, we're limiting that growth for SLPs and SLPAs. There's so many licensed and experienced clinicians who can provide excellent supervision, but can't, because they've chosen not to pay a private organization. And that's not about quality. It's about power. At that point,

Yeah, and PTAs run this show in the therapy world for providing therapy, right? Physical therapy has figured out how to do this without a national certification. The degree is enough. They have figured out standardization without a C-PTA. They've figured it out. So everyone listening, you need to get this under control in your state, wake up, pay attention, or we are going to be further tied to the CCC and SLPAs. Are going to be stuck like we are now is the time when these bills are on the table in your house and in your Senate, in your state, speak up. Talk to your senators, talk to your congressmen, talk to people and stop it, make the case. We can help you with that. State teams can take this stuff on that. That's why we're here. That's that's the kind of advocacy we want to help with. Because right now, our mission is choice, making choices for SLPs, getting our clinical autonomy back. That's why we're here. We are losing autonomy. If your state requires the C-SLPA. That's it.We're losing autonomy by your states doing this.

Right. And then at that point, it's not about that regulation again. It's like, how can we continue to control all these situations so that we can make money for ourselves, and that's what they worry about. They're not worried about, are they getting the proper supervision? What does that even look like? So let's talk about supervision.

In Alabama, we know we've looked at our little chart. We're just going to be sprinkling in state information as we go, and usually I'm bringing up Ohio, but I I think we can have SLPAs, but we have not yet jumped into that. We can use SLP aides with a D. And I think I looked, I think there's only one practicing in Ohio right now. I looked at the state licensing board a couple months ago, and I that's when I realized there was a difference between aide with a D and assistant, because I was like, How is there only one SLPA in the state? And then I realized it was something different. So I don't have a lot to contribute in terms of what's going on in my own state, but we've looked at the chart, so in Alabama, supervising SLPs. So that's if you're the state licensed, SLP, you have to be in the same building at all times to supervise. In other states, supervision can be virtual. Some states require as little as 10% direct supervision over your SLPA every 90 days. Some require a specific number of direct hours every week. There is zero consistency across the states on what is required. And again, this is kind of being just made up on the fly. What feels right, I would suggest, as states are looking at this, to look at what's required for their PTAs and their COTAs. There is no reason to use the C-SLPAS as a model when your state already has this going for them in two other very closely related professions. So the number of support personnel, one SLP, can supervise. Supervise ranges from two to six, depending on where you are. It's not always based on evidence or safety. It's very much arbitrary.

Yeah, and most states don't require any special CE to supervise. So California and Illinois where I am, the expectations, you know, they mandate training, but most of us are kind of left to figure it out alone. You know, training, even just for students, even for grad students, it's two hours of training. But is that enough? Does that? Is that enough to help these SLPAs? We've heard from SLPs, who are given three aides, SLP aides, and a full caseload with just no guidance. And that's not supervision, it's expectation, like, we need, oh gosh, having even just in grad school, a class on how to supervise that would be helpful. I don't know what you think Jeanette like...

What a, what a brilliant idea. But, you know, universities, I can see this too from having been a faculty member. Where do you plug that class in at? There are already too many hours, and we are already can't hit everything, so oh my gosh, one more. But you know, at the very

week of a class, like or two, like, you know, or just

very least, building it into the professional issues course or like segment that they do would be good or even another way. I don't I don't know that you can always require students to attend things like this, but at one of the universities I was at, we had a summer CEU weekend where we did a CEU weekend where all of our supervisors could come and get CE hours, professional development hours, and actually that's where our graduating Master's class would do presentations. So they they would have poster presentations in the hallway that people could look at after from their capstone projects. So that that is one way to get students there. So you always know that your outgoing cohort would hear this, because then they sat in the CEUs, so they were required, and they knew at the beginning, like, hey, this weekend is when you're going to be presenting your capstone. So that's a way to do it. You could do a three hour or a whatever our talk on supervision, and at least get something to your students and to the people who are supervising them, which is also helpful. So it doesn't just have to be supervising students. If you're in a state that uses the aides with a D or an SLPA. You could be providing supervision for that too, because it's gonna benefit everybody.

Yeah, absolutely no. I think that's a great idea. And so, like, here's the kicker, many of these same states have language that, like, implies you need the CCC to supervise, kind of like what Jeanette was saying, even though it might not technically be required. So again, that language just needs to be out of all of our laws and regulations across the states, you know, especially with like Minnesota coming in, with all their news laws and registrations. We're in the Minnesota team trying to figure out, okay, well, what does this definition mean? How can we get clarification of this? Like, let's get this all clarified and in before the ball starts rolling in July, when everything gets rolled out. So like, look at your laws, look at your regulations, look at the language about the CCC and about the C-SLPA, so we don't get tied to that certification.

Yeah, here's something concerning that I've been watching happen in the state of Delaware. If you don't follow us closely before Fix SLP started only days, days before Fix SLP started, there was a bill that was passed in their state that required the CCC for practice. We have been fighting hard, and not us. Delaware. Fixers have been fighting hard. They spoke up. They went to their board meetings. They wrote into the board during public comment periods, and they were very vocal that this shouldn't happen. And so what they've been able to do is, I don't think it's been finalized yet. I've kind of lost track of board meeting. I've been attending all of them myself. I might have missed the last one. It might have been this week, or they might be skipping. It's usually around this time. So I've been watching all of this happen. So what they've been able to do is get the board to decide which is, this is what they were already doing, that you need to have the CCC for the initial license, but you don't have to keep it. What they, the board themselves, has discussed is potentially getting a bill to then undo the bill that was passed that's requiring the CCC in the first place, but for right now, it is a law. So they're doing the best they can with what they have, which I completely commend them for. However, I have also sat through the process of watching them develop their SLPA regulation, and they are going to be requiring the C-SLPA for their SLPAs. Preston and I sat in one of their state board meetings where the SLP literally said in this meeting, I feel like we need to require the C-SLPA, because this is so new.

No

Hand on face. Uh, ma'am? This is not new. California has been doing this for years. PTs and COTAs, PTAs and cotas have existed in your state for years, for years that Delaware board needs to do their due diligence, get off their butts and research the state requirements in places where SLP-As are effective, like California, and write their own policies, or look to PTA and COTA and work with those state boards from their state to write the same policies. That's what the that's what the board is there for, not to lean into ASHA because and be a mini ASHA because this is so new, and now we're going to tie ASHA to its clinicians and the CCC with one more layer of nonsense. Your clinicians are already telling you, we don't want this, and you're tying supervision to the CCC. Good job. Way to go. I don't think that has gone through yet. So pay attention if you're in Delaware. Start looking for a public comment period and lean into them. Make it for initial licensure only, just like they are for the CCC. After that, you can be an SLPA without, without the C-SLPA.

that's

andmthat's where we are going to need those subscribers to be updating their states so that something like this, where, hey, we're going to need a lot of Delaware SLPs to be commenting on something that's huge, like this. So if you haven't yet update your state on your subscriber for fixed. SLP, we have instructions out on Instagram, on Facebook that's going to be huge. We're going to need to gather all of you guys to make some change.

And what she means by that is, if you receive our newsletter, there are over 6000 of you who receive our newsletter. That is a huge number for such a niche little thing. By the way, I can see right now from the most recent legal update that we sent at the beginning of April, I can see right now that 60% of you have opened the email. So there are 40% of you who had either went to spam, maybe you never got it and didn't see it, maybe you deleted it and didn't care. That's fine, whatever, but it's, I think it. Last time I looked, it was like a 63% open rate. So if you are one of those people who has clicked that email and looked at it, all we are asking you to do is add your state to your email. We're not asking for the hair of your first born child. All we want is for you to go in there and put your state with your email. There is a place to also put your name in your city, and that's fine. We don't do this yet, but someday we might, I might learn how to code a little email that when you open it, it says, Hey, Elizabeth, hope you're having a great day. And then it, you know, I can code it to put your first name. I'm not doing that at this time. It could come down the road. You can put in your name. You don't have to, but that's what Elizabeth means by updating your subscription. If you're getting our newsletter, you can go back to the newsletter. At the beginning of the newsletter, there was a link there to update your state. That's all we need to know. Is what state you're in. Elizabeth has a heart out, so we're gonna wrap up, I think, really fast, and we have a few more points that I might go ahead without her. Elizabeth, is there anything you want to say before you go?

Like I said, we just need our SLPAs. I think they're often caught just like in the middle of this dilemma that we didn't create. And sometimes they're probably told to do more than what they're trained for, and again, without like that supervision and so it's just not fair to them either, and we don't want to keep creating that burnout that we're creating for ourselves too, like we we need to just stop it. We need to support each other. We need to join forces and help our each other with just these systems that aren't working for us. So we love our SLPAs. We love you guys, so

and I love you, Elizabeth. I say this every time she's on, when you are looking at our content, Elizabeth coordinates that she is creating. We have a little bit of a collaboration at the end, but she does the research. She puts all the tiles together that you're seeing on Facebook and Instagram, and then I she does it all, and then I just do some editing and reformatting, and then I post them. So I'd say 99% of what you are seeing is coming from her, and she we couldn't do this without Elizabeth. She is a lifesaver and amazing. So Elizabeth, we appreciate you. Thanks for taking time in the middle of your day to help us get out ahead with our recordings, and you and I will talk soon. Don't turn off the podcast. I have a few more points I want to point out to you guys. So

all right, bye guys!

Okay. So without Elizabeth, I gotta kind of look at our talking points and see what she said and what we have left. So when we're thinking about steps to take. We don't want to just get on here and scream and shout, which I've done a lot of today. We have some points here on what can we do as SLPs, what can we do to help with this process, and especially like, stop getting ASHA like from putting their tentacles in first. We need to clarify. We need clarity. Every state should be clearly defining the scope of support personnel. No more vague references, no more conflicting rules. Do you have SLPAs? Do you have SLP aides with a D what does each one of those do? Second to me, most important, stop hiding behind ASHA. If a state doesn't require the CCC or the C-SLPA, don't write it into your forms or rules. Don't stop. It causes confusion. It restricts the workforce unnecessarily. And that's what we're about here, is getting those things clarified in every state for the CCC. So let's just do it from the gate with the SLPAs. It's what we're trying to do. Let's keep it clean. Just keep it clean. Guys, keep it clean. Three standardized minimum training and supervision expectations. So this would protect patients, it would support clinicians, and that's what state boards are there to do, really, is protect the consumer. So some standardization with minimum trainings would go a long way and for the supervision. So again, I've already said this. We're not against SLPAs, we're against unregulated practice, which we're not asserting is happening, but I think in some states, it's kind of kissing the line. And patients really deserve better, and clinicians, SLPs, state licensed SLPs, deserve better, better guidelines, knowing how to do our job, and ASHA doesn't need to be the one to regulate it, or to pretend to regulate it, because they're not a regulatory body. We need a shared, state led model that's empowering supervisors, it's supporting personnel, it's supporting everybody. So Fix SLP is ready to draft this. We're here to help. We haven't really jumped in. We did actually have a conversation with one state who came to us. I shared the spreadsheet that is now accessible to all of you to look at. I shared what we had, and we collaborated very minimally, but at least I was able to share resources, which was a joy to be able to do again. It's why we're here. We imagine most state boards have zero interest in collaborating with us, and that's fine, but then that's where our state teams come in. We're here to collaborate with like minded professionals in the field in every state. So we have existing state teams. We have state teams on deck. We have state teams that still need leaders if you want to collaborate, and especially if you're feeling like a really strong leader. And we can get this launched within your state without a ton of help from us. We're here to do it. We just don't have a ton of manpower on our end, where you heard Elizabeth talking about Minnesota. She's heavily involved in Minnesota, but she's not licensed there, and we can only do that for so many states. There's only three of us really, really doing it, so that takes time, and so that's what slows us down. If our collaborators need a lot of help from us collaborating, it prevents us from launching in other states. So if you're interested, email your name and state to states@fixslp.com. If you think you can lead, if you want to take this on, if you want to be monitoring in your state, message us. The other thing is, there should be a group of you just monitoring the state board meetings period so you know what's going on. There's 12 months in a year. Most state boards do not meet every month, but at max, you're looking at 12 meetings. Sometimes you're looking at one, a quarter, four. If there's four of you, you all go to one meeting, or if there's eight of you to go and sit in take notes and then share the notes. That's what I'm doing with a team for the interstate compact. We've been doing that for two years, and I more than that, longer than that now, and I've only sat in a handful of meetings. So, active, engaged clinicians need to be monitoring what's going on, not because your state boards are being nefarious, but you need to know what's happening. So when stuff like this pops up, you're ready to speak up and you're ready to take charge. And again, we're here to help with that. If you'd like, like us to and honestly, in a state with vague and outdated regulations, now is the time to act. So again, join your state teams. Let's get this all cleaned up for our SLPAs, for us as practitioners, so we have good guidelines. Let's fix it, people. Okay, so with Elizabeth gone, I think that's a wrap on this week's episode. If you learned something, maybe you got a little nugget. If your jaw dropped even once, please share the episode. It means a lot to us. When you do that, check your state regulations. We're going to have this up so you can look for for sure, Elizabeth will be creating a post. You can go to our website fix slp.com, at the time that we're recording this, we are still using our old website. It is coming along nicely. It's not ready to let the new ones not ready to launch yet. So on our old website, there is a tab that says regulations for SLPs. That's probably where I'm going to stick this power or this spreadsheet for you to look at. So go ahead check it out. Go look for it. If you see any mistakes or something that needs updated, please let us know, states@fixslp.com, don't assume your state is right because things have changed, but at least there should be a link for you to click to check your state. So join your state team. Get involved. Help us fight for clarity and fairness. What is happening right now isn't working in every state. It is in some but not in every we'll be back next week, until then. Thanks for fixing it, guys. Have a good week!