Clarification: The University of Maryland does not currently require students to obtain the CCC before graduation. Hi everyone. I'm Megan Berg
and I'm Dr. Jeanette Benigas.
And we are here to fix SLP.
We are discussing the biggest challenges that are currently holding back the field of speech language pathology.
We present the issues with facts and invite you to be part of joining our movement to make things better one conversation at a time.
Let's fix SLP
Hi, fearless fixers. Welcome back. It's Jeanette. We have a really exciting episode today. Whoa, yeah. Through some professional connections. We were introduced to Dr. Angela Levin Brooke, who's been around the actual block a couple times. And she's she has a lot of things to say. So
we're gonna jump right in with her and then we'll get to some of our housekeeping stuff after but we just want to share with you who she is. So Megan, we don't usually do this, but Megan is gonna go ahead and read her bio. And then we'll just jump right in.
Yeah, we're gonna read it because there it's a hell of a bio. There's a lot this woman has done and continues to do. So Dr. Angela Loavenbruck was in private practice in Rockland County, New York from 1976 to 2020. She is the author of numerous articles and along with Dr. Jean matal. Am I saying that right now, middle, Dr. Jane Lee Dell, the first textbook about hearing aid dispensing for audiologists, Dr. Levin Brooke received her doctorate in audiology from Teachers College Columbia University. She was the director of the audiology clinic at Teachers College and associate professor in that program. She has served on numerous boards and committees for several state and national audiology organizations, and served as president of both the New York State speech hearing in Language Association and the American Academy of Audiology. She served as the first chair for a Cae. She has been prominent in the development of standards and ethics for the audiology profession, and in lobbying for direct access to professional audiology services for Medicare patients. Most recently, she has been awarded the honors of the profession by the American Academy of Audiology for her work on behalf of audiologists and individuals with hearing impairment. Earlier in her career. She also served on many committees but for Asha, and also served on ashes board as vice president of standards. She became a fellow of Asha, she was refused membership and accused of violating the ASHA Code of Ethics when she dropped her CCC in the early 2000s. And she has lived happily ever after since that time. I just want to say that other than our hero and our unsung hero, Dale bogus
This is an this is like early fearless fixer right here. She was a fearless fixer before anyone was fixing anything. Her and Dale bogus they weren't fixing.
Welcome.
Well, thank you. I'm glad to be here. I am thrilled to see what what's going on and what speech language pathologists are, are coming to see
as part of the problem of their profession and of the professional association that represents them. I mean, audiologists have fought this battle for quite a while, and we're a small group.
My own personal opinion is that audiologists have no business being in in Asha at all because Asha is an association for speech language pathologists, and audiologists are represented very well by other professional organizations. So
and I really thought with the when the AUD became a requirement for Audiology, that this that certificate would have less appeal. But it is so ASHA has had its fingers, and its tentacles in so many places for so many years. Not the least of which is in academia, because that's where it all starts. People are indoctrinated in their academic programs from day one to believe that if they do not buy that certificate, odd infinitum throughout their professional careers, that somehow their world will collapse, and that and ASHA has insinuated itself into so many regulations and laws and policies and procedures, that it takes years to kind of unravel at all to see where the problem originates, and who
believes, who was it that believed this lie about what that certificate app actually represents. So you have a huge job ahead of you to unravel at all. And to help people understand how that certificate gets in their way.
It to me, it always seemed like, like Asha treated us like a bunch of Girl Scouts, you know, and we're still trying to get our badges. And that's what it's infantilizing. I think, yeah, Girl Scout leader here. That's exactly what it's like I G Yeah, it is. seven year olds. And it's like herding cats and getting them their badge, your badge. Correct. And that's what that's what people are still doing grown women. And I say women, because that's mainly what, who, who is represented in that in that organization? So it's a bunch of grown women still believing that they have to get these Girl Scout badges every year, in order to be considered relevant. And competent, professional, worthy. Yeah. You like, so there's a lot of conversation happening right now. That's like, but if we don't have the CCC, everything goes to hell. Like there's no regulation, anyone can do anything. There's no competency standards, there's nothing we would have nothing like why would you want to get rid of this thing that's holding this whole profession together? What would you say to that, write that down. The seas are not the seas are nothing more than a continuing education certificate. That's all they are. The place where standards are important are in academic programs. I mean, it is, first of all, a professional organization, a major job of a professional organization, is to define scope of practice, and to define the knowledge, skills and competencies that define a profession. So that's an important job that Asha, and frankly, at without Asha, that job initially would not have been done that organization and the volunteers, standards committees for years ethics committees, they help define your profession and mind. I have a master's degree in in an SLP. So I was a practicing, like, licensed practicing speech pathologist for the early part of my career. And then got a doctorate in audiology and then stopped practicing speech language pathology. But
Asha did that work. There was no other organization to do it. And and I in the late 60s, that's when I first joined Asha, mid 60s, late 60s. Very well, that would have been right around the time that they introduced the CCC, right? Exactly. That's the time when they were beginning to work on standards and then introduce that certificate. And at the time, there was no licensure. There was nothing that legally defined what an audiologist was and what a speech language pathologist was. So that worked that early work of Ashens was critical, because it did all that it did in as an organization, it did an enormous amount of work, and standards. And there was a massive study in the early 70s. That was a knowledge skills competency thing they hired the organization that runs
it's a standards organization and a testing organization that still runs the practice test. For Asha. They hired them and did this massive study to define what skills do speech pathologists and audiologists have to have, what knowledge what competencies, enormously important. And that work became the basis for licensure, which is the only legal
it's the only legal definition it is the only thing that legally defines and separates SLPs and audiologists from other people who might lay claim to part of our scope of practice. So, Asha, initially opposed licensure, tooth and nail, they did not want and that was the, for me. That was the early sign that something was amiss in this organization because it didn't see how critical licensure was to the success of both professions, as legal entities that could compete in a world of other licensed healthcare professionals.
So just for just for historical context for people listening, it was 1969 in Florida was the first state to install a licensing board
because they were seeing all these fake SLP practices and Asha had zero legal authority to shut them down. And they were like, we need some legal teeth here.
And after your license, if you go back, I don't know if you can still find this on in anywhere on national land, but a lot of early writing and opposition, tooth and nail, and then they solve that problem. By state by state, inserting the seas,
not the standards for the seas. Actually, the seas were a group of standards that you needed in competencies that you needed in order to start out as a competent speech language pathologist. Yeah. The other problem that our SEL P has that audiology no longer has, is that the vast majority of your training programs are in academic, not professional schools. So audiologists, let's take PTs and OTs and physicians and dentists and chiropractors, they get their training in professional schools. So the school is responsible for everything, they're responsible for the educational, the coursework, they're responsible for the internships, and the clinical training. All of that is part of the degree speech language pathology, that's not the case anymore. It is the it is the case now for Audiology, because we have a doctorate. So our academic programs are responsible for that final fourth year where people are out getting their clinical experience that's arranged by the school's master's degrees in speech pathology, all the school is responsible for is that is whatever you get in those two years, minimum number of hours, the vast majority of your clinical hours are obtained outside of the aegis of the academic program. They're they've they're done with you once you get your master's degree. They're done. And then the onus is on the student, the graduate to go find the CFI year and get supervised and all that business so so you can't just say you can't for an audiologist you can say an AUD is all you need to get a license because your of all your clinical work is done. Then not true for this for the
getting a master's degree doesn't even and
Can we talk about like how that's affecting consumers like why is that okay with us? Why are we okay with getting a job? Or not even fully? It has
We would never won our doctor getting their clinical hours practicing on us in their first nine months of flooding, right? How about
OTs and PTs? For years they were an MA field right? They still I think PT now is PT work require a PhD and a Doctor Oh DBT is not a PhD. It's a DPT to professional degree, like I didn't like the AUD is a professional degree. Yes, PhD is a research degree. And for years, people who wanted doctorates in audiology, the only one they could get was this academic degree wasn't a practical degree.
I don't have an AUD, I'm dual. I mean, I was I'm old, you know this. I'm 80. This is my 80th year. So I've been around a long time. And
so that is a problem for SLP. That's one of your problems. The other major problem, I think that that you have in trying to really change Asha, and how it behaves about the certificate is the fact that I think 80 I think I'm right, I think about 80% of the SLP members of Asha, are public school speech pathologists. And is that correct?
I can look it up real quick while you're talking.
I think that it is. And the fact that the vast majority of Asha SLP members, practice within a school setting complicates your goal. Because in this in an educational setting, lots of people do the things that SLPs do. Teachers of the hearing impaired
teachers of the death special ed teachers, I can't remember there's a whole list of people
I'll give you one that they're really really really having problems with now that I one of our fixers added us to a page and I've just been like in the rabbit hole, our ABA practitioners, big problem there that
for SLPAs is to treat by so it's Yeah. And who and what is that? Those are the ABH are the people who work with a lot of autistic kids and those kinds of kids, right? Yeah.
So lots of people claim to do what SLPs
have as their scope of practice. And the vast majority of the burden in the public schools, where I understand now licensure is required in more public schools, settings and SLPs. Or, you know, audiologists are often contract hires in in public school settings, they're not in the educational thing. But SLPs are often hired as their they have to fit in as teachers. That's why they're called a lot of times teachers have the speech impaired, or teachers of the communication, do whatever word they're given. But not only do they have to keep up with these SLP requirements, but their whole educational system, they have other metrics for deciding when you get a raise, and when you're in a different hierarchy in terms of your salary and stuff like that. So in order to hurt that group, that huge group have its membership. ASHA has worked really hard to insert that CCC requirement into every educate every certificate, every educational requirement that teachers have to maintain their certification to continue to get raises and salary upgrades and whatever promotions in public school setting. And that is, that is, I believe what Ash is the most terrified about, they're their most terrified of losing their hold on that public school group, which has the least reason
to be loyal to ASHA. So you know, if you're in a hospital setting, or if you're in a private practice, or if you're an other clinic, you're defined by your licensure, if you're in a healthcare setting, you're defined by your licensure not by your certificate. And lots of people worked really hard on licensure laws to to change them. So that CCC is we're not required to get your license. Almost all of them. I think every single one of them says the CCC or the equivalent, right? There's one one recently that requires the CCC. And that could be that could be challenged legally, because they're requiring you to buy a proprietary private certificate
you that the state has no control over. Exactly. Nevada, right. Nevada. Yeah. And I just want to happen and clarify.
Nevada, do you hear that? I'm putting my hand up by my face. But none of you can see me like I'm making an announcement you hear that get in Pombal? Did you hear what she said? That can be challenged legally, because they are requiring you to purchase a private product to
go get them speak up. I woke up at 9am raging on Facebook about someone else's problem. So now we're going to take it out here, go get up tech, go get up meet meet where they're the key thing is, you don't want to go to the state legislation and be like we don't want to buy this product. You want to go to the state legislation and be like you are putting yourself in a horrible situation. You are required your you're leaning on this certification product that is entirely out of your control that this company could change at any time, and that is unmonitored. Megan, can I propose here? Is this where appropriate use of cease and desist letters could be
where you're just gonna tell them to stop? Is that how an SLP could appropriately they just changed that one about it? They did. Somebody proposed that change. Asha supported it and it went through. I do before we get too much deeper into this. I do want to clarify that school SLPs makeup according to ashes member affiliate profile from 2022. They make up 50.3% of the body. And I I think that's probably changed a lot in the last 20 years as dysphasia has grown.
But I do think it's very, very weird that we have ASHA trying to sell a certification. We have licensing bodies, which is the gold standard for all other professions. And then we also have departments of education, selling their own certifications, and then you get the school SLPs who
that's an interesting statistic that 50% Because I know that that's less than it used to be. But if you take a look at there's a do you know about SOC codes or standard occupational codes
Okay, that's an interesting place for you to go look, because the Department of Labor defines and codes every single profession that there is. And it's via this, the standard occupational codes, and audiologist had a huge battle with ASHA over where we were placed in those SOC codes. years ago, if you wanted to find audiologists in that occupational code list, you had to look under speech line, there was no there was no place for Audiology to look under speech language pathology, and then it was down underneath there and speech language pathologists are listed as therapists, and audiologists consider themselves diagnostic and treating professionals. So the codes have been redone.
Carol Flexor, one of the presidents of Asha was the AAA was the first to notice that we were in the wrong place there and started triple A's advocacy efforts to get us changed. But if you look at
it's a wealth of information. If you look at the SOC Code for speech language pathology, there are charts there that tell you where the vast majority of SLPs people who call themselves SLPs, where they are employed, and 80% of them are employed in public schools. So it gives their average hourly rate you can get an enormous amount of information. But as a result of the work of audiologists, speech language pathologist position in that Standard Occupational Code list is what employers used to decide which are equivalent professions that define the professions. It's a standard coding system for every single profession in the country. So take a look at that. It's under the Department of Law. But if you Google SOC codes, I think I sent you a I might have sent you a link earlier today, because I thought you'd find it interesting, but believe me when I tell you that the the the public school membership of Asha is a critical membership group to it. Because it's still the largest group, you know, so 50% of them are speech pathologist. And then you know, how many are in smaller, much smaller numbers are in hospital settings are in and probably in every other setting. Licensure is 100% of the time the legal requirement.
And most licensure laws allow for other methods of, of maintaining your license. Lots of places where I've read Asha and Ashish responsible for this. They say, Well, yes, you get your degree in your license. And then some people go on to earn the CCC, as if
earning the CCC is some higher requirement than licensure. And it is the same exact thing.
In some cases, it's harder to get the license. Yes, yeah. So I want to ask a question. I've been sitting here like processing, I'm still on this rampage about suing in Nevada. I want to ask a question. And I, I'll see what you think. Um, there are some
insurance companies like Medicaid in 11 states. And then this, we found out yesterday, very few numbers, small handful of private health care insurance companies that require the CCC. Is that also something that could be challenged legally, because they've been led to believe that that is sort of like board certification? Okay, because we're we're trying to develop the state the sustaining partnership program where, you know, we maybe hire a law firm, and people are asking, Well, what are they going to look at? I think this is a very good first step, Megan, and I had no, no prior information. So I this is just at home. But there might be something we have a law firm with attorneys nationwide that they look at, because AAA,
again, had a law passed that
required Medicaid to stop using the C's as a requirement for audiologists, and we won that. So the Medicaid definition of audiologists does not specify the CS still does for speech language pathology. Why? Because in the public schools, where you sometimes have unlicensed SLPs, they don't have to have a license, but there are SLPs, they're billing Medicaid. So in those states where licensure doesn't cover SLPs Medicaid has that they wanted that requirement in there for some
I'm credential.
So sorry, can we talk about this because my understanding is Medicare's federal regulation in Medicare, the CCC is not required, but you're talking about Medicaid
is covered by the same federal law as Medicare is Medicare, Medicaid. So when I, when I email
Medicaid is a state run program, so they there are certain the federal Medicaid law requires a certain number of services that must be included in every Medicaid law on the state level. But the states don't have they can choose to provide other things. They don't have to. And they can set up their own requirements in a lot of instances. So it's SLP is a problem for them because SLPs in the public schools,
are billing Medicaid for some of those services for some for Medicaid eligible children's. But in some states, licensure is not required for SLPs in the public school, there are teachers of the speech impaired such a mess, it is a mess. It's such a mess. So so when I when I talked to CMS, I specifically asked them, I was like, I understand that the federal regulation does not require the CCC. But if a state has a regulation, does that supersede federal regulation? And they said, Yes, the end, and that didn't used to be the case. So they said if eight adds a regulation that supersedes the federal one. Yeah. So they're, their commentary was basically and I can pull up exactly what they said. So I requested assistance from our Medicaid staff, they indicated that there are no known federal requirements for a certificate of clinical competency only state licensure, we believe this is best answered by the state Medicaid provider regarding what they are referencing with that statement of certificate of clinical competency. States can have more stringent requirements than the federal statutes. In addition, providers are required to follow all applicable federal, state and local laws, providers are required to follow the most stringent requirements. Okay, so there you go. The CCC is not more stringent than state licensure. They have been led to believe that it is, but it is not. And if you go to the state of Nevada, or I don't know, any state, where Medicaid still requires the CS, for SLPs, to participate in that, if I were doing this, I would go line by line
through what the licensure requirements are in that state, and what the CCC requirements are, and demonstrate that the C's are not more stringent. They are simply a duplicate. And the state is requiring providers to buy a proprietary certificate when the license isn't equivalent to document.
I mean, it almost seems like a an efficient approach could be to go to departments of Ed and be like, You need to require a license or go to this. I mean, I don't know who controls like our schools just in their own little world with regular
departments like in Ohio website has every state requirement I just was on there today. Let's not
I just don't understand how you can work as an SLP without being licensed. Like how is that even legal? Are you can?
Because they're teachers? Yeah, because they're teachers
like in Pennsylvania. They have teachers, they are in the state of Pennsylvania. They have they they so in Pennsylvania, you have to take extra classes. You can remember we've talked about this before. Even I could never get licensed as a an SLP working in the schools in PA unless I take like three additional courses in education. Yeah, yeah. So schools in Pennsylvania, as part of their programs automatically, like prep. That's part of their coursework, as undergrads is they have to take those courses. So when they leave school, when they graduate, they're prepared to get that that license that teach me just like and frankly, if you tried, a lot of people become SLPs.
Not because they want to work in clinical settings, working in a hospital settings with all of the swallowing and dysphasia and all that they become SLPs because they want to work in the public schools. They don't they don't want to be teachers, but they want that teacher setting. Schedule.
salary thing they want that. So So you have to sort of be careful what you're messing with here. Because in a lot of instances, public school SLPs have used those C's to their advantage it gotten them things. I'll give you one example years ago, I don't know if this still exists. But there used to be this thing called master teacher.
And teachers in the public school could take on extra coursework.
They had to create an actual portfolio to show they had to be observed. And they and they created this portfolio. And then, and they became something called a master teacher. And what that got them was a boost in salary and a boost in other their place on the on the spectrum of things in the public schools. Asha went to those departments of education in those states where that master teacher thing was, and convinced them that somebody who got
a master's degree in SLP, and then got the C's was the same thing, as these teachers who had gone through this years long process of preparing this portfolio, getting all the secondary education. And so SLPs, then were able to use those C's to get that same boost. ASHA has used a an inflated definition. And they've been very successful at
to make people think that that CCC is something that it is not.
And that that standard has changed a little bit. It's now like masters plus 30, Masters plus 45. And there's no to my knowledge, at least in Ohio, there's no portfolio or anything like that. If you complete the coursework, you get the raise. And so most teachers to my knowledge, and I'm sure we'll get emails and angry comments if I'm wrong. If you know if you've completed your master's degree, a lot of times we have the plus 30 already, or we're awfully close. Right? So yeah, that that's how they sort of do it. Now. It's not a master's teacher. It's like a plus 30 plus 45 plus 60, whatever. But I mean, I've heard I've heard people say that.
Like, if teachers get board certified, then the CCC is equivalent. I think that's still happened. Yeah, that's still a thing that lots of schools are negotiating for an additional stipend. And we've seen, I've seen some really high numbers, I think one person told us they get $9,000 a year, or something, which is what Megan and I have continued to say is that we will tell these people, you're someone who needs to keep your CCC like we there are there are people who should keep it and who can make that choice. The point of this movement, this platform is that people have the choice. So if I'm making $9,000 a year with my CCC stipend, I choose to keep it but if Megan's not, she should have the right to not have to pay for the CCC. And that's what we want to see.
Probably nobody would object to ASHA selling a continuing education certificate. If they simply called it what it was, you know, I would have stayed a member
I would have, I would have been a member because I get information from it. You know, I just got a good website. There's information there, I worked with hearing impaired people, many children had speech language difficulties. I wanted to keep informed.
I didn't want to buy that certificate. I didn't need it. And the the notion that the only person that can supervise somebody was somebody who's buying that certificate is ridiculous. Insulting, so but they won't do that. And that's what they should do. Let's say they charged everybody who wants to quote unquote, maintain their CS, that C E registry 50 bucks a year. They've got 200,000 members, you know how much $200,000 times 50. Now, they could still make a fortune. But doing nothing more than being a registry for your CPE hours that you could then use for your license to say see I completed I completed the CPE requirements are equivalent and state requirements 50 bucks a year I pay for that well, and based on their financial report, we've calculated that it should cost them around eight to $12 a year just in what it costs them according to them to run their certification program. That's what it should actually cost 50 bucks a year. Pay them that. You know it's not the 200 $250 A year is nothing for membership. And I saw your chart today that said it's not the 250 it's that they're lying about what it is or not going is it they have a they might have a useful product. That's your
tificate is a useful product, they should sell it as that a useful product. They should not pretend that it is anything more than what it is. And certainly for audiologists, it's it's ridiculous that audiologist have doctorates.
Anybody with a master's degree who graduates from a program accredited by ASHA,
by definition has has completed an academic program that contains all of those standards. And then they get that CFI year
which is nine months, it's still nine months, it's nine months because that's what the public schools are nine months. That's why it's nine months, not a year.
It's a it's not a CFY it's a CF nine months.
All geared to the public schools. So yeah, take a look, I would say at challenging
Medicaid laws, not suing,
can we can I just and I know Jeanette wants to talk about in a minute, but like, just so I'm clear, and everyone listening is clear. When you're hired by our school district, as a psychologist, you're hired as a site, a licensed psychologist, when you're hired by a school district as an occupational therapist, you're hired as a licensed occupational therapist. When you're hired by a school district as a speech pathologist, you're hired as a teacher,
sometimes some states, some states require the license. Okay.
So we need to we need to dig into that and figuring
in Ohio you, you have a there's a different type of license for a speech language pathologist. I can't think of the name right now, because I did. I hung on to it yet, I deeply relate to this. I hung on to it for years and years after I stopped working in the schools, because I was afraid to let it lapse, because I was afraid to like what I would have to do to get it back. Even though I started going to school to get a Ph. D, focusing on dysphasia and dementia, I'm still paying for the school teaching certificate just in case. But somewhere in there, they did change it. And so I guess I can't remember what it is.
But, you know, in you, you understand that when you get a master's degree, you do not get a master's degree in speech language pathology, you get a master's degree in a discipline, communication disorders and whatever the hell it's called. And hearing science, Speech and Hearing science, it's not whereas an OT, when an OT gets master's degree, they get an acute they get a master's degree in occupational therapy, a master's degree in physical therapy. Physicians get a Doctor of Medicine degree, you don't get a doctor of speech language pathology degree, you get a doctor of some science unless you're in a
I don't know if they're professional programs, but but it is all because of our origins and academic programs. We came out of drama, you know, Speech and Drama programs.
Communicate, we came out of an academic place.
This is this isn't a master's degree that just happened to be hanging out on the table. It just says Master of Arts. It doesn't even say
it's
because they can't they can't that academic program cannot qualify you or call you a speech language pathologist your your practical training, they have nothing, no responsibility for that. Yeah, I'm pretty sure my PhD said something different. But that's in a different room. I just had that out for a different reason.
I just had to realize, you know, yeah, I don't even know what my degree was in. No, that's true.
Why isn't it framed hanging on your wall with your with your certificate?
And
MEd, Master of Education, MS Master of Science and a Master of Arts,
PhD.
Usually it's not going to say speech language pathology.
Don't say that they say PhD and they don't say PhD in audiology. AUD is audiology, but PhD No. You're getting PhD in a discipline
or acoustics experience something
not in audio.
audiologists have made huge strides in ensuring that entry level competency is in place without the CCC or the CFI. And in fact, like we're about to post information on this like so do OT so does PT like we it's it's just a nine to me that we hold on to the CS as some sort of like competency regulatory
The major difference is that the academic programs in audiology in PT and in OT, they are profession
dental schools. So the technical requirements, the practicum requirements are included in the degree program itself and the academic program, that professional school program is responsible for them. So we have another episode called practice analysis paralysis, where we talk about the practice analysis and like all of the research that goes into setting the standards, and the way that ASHA has written that practice analysis is they they set it up so that you only can learn a certain amount in grad school. And then most of it is learned after you leave grad school. And so when they're saying that the CCC is evidence based, it's they're saying that it's based on this practice analysis survey. And the way the survey is written, is designed to keep the CCC alive. And well like until that analysis, or that survey changes smooth, if you added the obtain the necessity to obtain all of those practicum hours within the master's degree program, people would be paying for.
I mean, how many credit hours now is it to get a master's degree, now you add the more practicum hours, the school would be charging you tuition for those hours. So the cost of a master's degree would be enormous. The way it is set up now, your academic program is finished with you after two years, they don't have to worry about where you get. And ASHA has set it up so that it's the professional responsibility of people practicing speech language pathologists to provide primary education for is it for nothing. We call that the MLM, the the SLP, multi level marketing scheme.
I have my PhD here now. And there's a lot more words on the degree but it says that I did it it did all these things, satisfactory completion of the course prescribed in the Graduate School. And it's a degree of Doctor of Philosophy, there's no writing, I could go out and say I did academic diviner kind of work and just show them this degree and no one would know the difference. So your professional read my dissertation.
Professional status is not defined by your degree because it's from an academic program. They were not responsible for any practicum you did.
Well, this was a PhD. So you don't do practicum?
Well, in audio in a in a professional degree you do? Yeah. Yeah. No, this is philosophy.
And this is a good point to say like the SLPD program. Those programs are not part of the CAA. ASHA has nothing to do with regulating SLPD programs. Those are regulated by the Department of Education. How the hell did that happen? Like, how is our profession just like being scattered to the wind? And like whoever wants to come regulate? Just get in there. Join the club, join the line, get in line and money, and I'll pay you Yeah, like money get in?
Right, let's do a Fix SLP degree with our ACE award.
Your master's degree programs are accredited by ASHA and the CAA and and you should take I mean, I have some testimony before the department of education about the CAA because the CAA used to require as a condition of accreditation, that the seas had to be part that the season had to head. That used to be a thing. Yeah, we went in hours and hours of testimony and the Department of Education told after they had to stop, which is when this whole business came up out that Oh, yes, you you have to have a supervisor who has the C's, only for students who wish to get their C's.
You can go get a supervisor without C's if you want to, but you can't count those hours towards getting your C's because those people aren't qualified. In my price. Why? Oh, yeah. That's so the Department of Education told the CAA that they could no longer use that requirement.
Oh my god. Okay. Credit for people who are like we need to fix ASHA from within. This is why we need an external force keeping ASHA accountable because they're pulling stuff like this. Sorry,
but
but also so now. Yes. Okay. First of all, I have two things to say about that. Recently, because I am the social media monitor. Somebody actually said, Some programs require the CCC before you get your degree. That might be someone who's older maybe because we have a lot of people who state things as fact that don't actually know the facts. So it sounds like if that's actually if you're listening and that's actually happening, let us know we have a problem. That statement claim that
act that some people, I'll give you, I believe the University of Maryland requires the C's as a condition of graduation, get their CS before they graduate, they take the practice before they graduate, it's a requirement. And they weren't going to graduate. Now, they had sorry, they have to do their cf Why? And then they graduate. Now they have to in the to get their CS. In the Doctor of Audiology program at the University of Maryland, I believe, Oh, the audiology. This is one example. In order to get the degree.
They had to get their C's,
there was a requirement of graduation, which I thought how can a state university have a requirement
for a student to have to purchase a proprietary certificate in order to graduate from that program? Let's let's play conspiracy theorist, Maryland, University of Maryland, where's the app? The offense is that there are some programs that require it of their graduates, most programs tell their graduates that it's critical that they get there. Yes.
There are some programs that don't do that. But also, yes.
And so then the second part of this is it because we've been saying this all along, and I don't think people are quite hearing it. That because we get a lot of questions about
having your Cs to supervise. This is not what you just heard her say this requirement is not an ASHA, or a CA requirement that you have to have your CCC to supervise. This is a requirement of the program, the program has written into their accreditation,
like program, like
what they written into their program is that if you want your C's, you have to be supervised by somebody with their CDs that's written in the program, right. But so I've talked recently, in the past couple of weeks, I've talked to a couple people in academia specifically, that there is this box that says you have prepared your students for licensure and national certification and all these things, and you just check it. But in terms of like what they submit to the CAA to be accredited and maintain accreditation, they have to have a plan on how they're going to do that. And some universities right in that plan, that their supervisors must have the CCC, because one person I said, we'd have to that I talked to said, Well, if we ever changed that, that that would we'd have to go up for re accreditation. And that's a whole, that's a whole thing.
And another person told me, Well, if if you succeed with this, this is going to close programs. And I'm thinking why would it close programs, if if they haven't written into their policy, then take the time and change it don't put the don't put the burden on never informed its academic programs did that they didn't have to have that requirement, right.
These rumors perpetuate. And then they make it they make they make it they make practicing clinicians who are underpaid and overworked and who are caring and in this profession, because they are nice and want to help people. They make us feel like it's our responsibility to uphold this freakin system that like all the university has to do is changed their policy, or have a staff meeting. You don't even have to go up against a board. I mean, now in terms of like, yes, this isn't even coursework where you have to, like, get it approved by your like, at a university, there's typically a committee that you have to a curriculum committee. This isn't curriculum, but it might take somebody higher, like another committee higher in the university just because checks and balances or whatever. But if the department is coming forward with it with a plan that makes sense. They're presenting to like math colleagues and English colleagues, you know, even if there's somebody else who needs to look at this, they don't understand, give them the well thought out plan and why we're putting in for this change. And people will say yes, because no one wants to sit in those meetings anyway. No one's trying to fight it, I think, versus the level that you're asking for is that in order to get in order to be certified, you have to be in order to be supervised. You have to be supervised by a licensed professional. That's it.
So that's all.
So it's not that hard.
And ASHA could not
use that as a reason to deny accreditation. And I have another suggestion there. If universities have written that very thing, like you have to have a CCC, then after should just say, anyone who is making change to that statement alone, you can't make any other changes. But anyone who wants to change from CCC, a supervisor who holds the CCC to licensed clinician if you want to change that verbiage, we will give you a grace period of two years to do that, without having to go up for re accreditation or whatever reason to go for re accreditation.
That is not that's what PhDs think so unless they're gonna
educate, you know that but that these are the things that at least Asher's not gonna do. They're not change anything, no, but at least the PhDs who are at least engaging with us, and thank you if you're listening, because we appreciate these, like really great conversations.
These are the things they're saying these are the things they're afraid of programs, clothing, reaccreditation, how will we ever get our students through the program? These are the fears of academic SLPs? And who and who, in God's name, fashion.
So I mean, that goes back to the original sort of conversation of like, academic SLPs are feeling the weight of having to fully prepare us LPs. But what we're saying in this conversation is that's not how the system is set up. So why do they feel so much responsibility for that they shouldn't. But I understand we're not going to change people's minds, it's just, it's just a broken system mentality program,
you do have a certain number of hours of practicum, that have to be completed within 400.
It's 25 of that is just guided supervision. So like, that's done an undergrad, and then the one on one is 375.
Still 375 is all the academic program is responsible for. And they are telling students that those 375 must be obtained from a person with the CS. Not true in the event that they eventually want, like, I think, don't want to be in the know, I know, I understand that. But I think they're doing that because they don't want to be sued. They don't want to misconstrue what they're selling. But but they are also they go further than that. They say, you have to you have to use a supervisor who's got the CS if you want to apply for your CS. And if you don't get your CS, you're not going to be able to get licensed. If you move from state yo you're terrible trouble getting you won't be able to get we don't have your CS and all of that business. So they use the end, the end argument for pushing people to purchase and to bolster this financial
bullying that ASHA has done for hundreds of 75 years. 80 years, however long they've been around a long time. Yeah, they're about to turn 100. Yes. Next year. Yeah. Cool.
So you have done a lot of work, you've gone in testified many times you have been called forth by the ASHA ethics board for when you were a member of ASHA, but you were not holding the Cs.
But when I sent in my dues, I sent what I did was I paid them just to be a member. And I said, I didn't want my CS anymore. So I did that. And then I was, you know, I had I was an ASHA member without C's. And I was still responding on boards, you know, and I was responding and somebody reported me, they said, Angela Levin, Brooke is a practicing audiologist, who does not have her C's. She's a member of Asha, but she doesn't have receipts. And you're not permitted to do that. So that I got a letter from the ethical practice board at the time saying you have violated the code of ethics. I hired a lawyer, I went and had a hearing before the ASHA ethical practice board, where they I said to them, I have done nothing unethical. I I maintain the highest standards of ethics. What I have simply done is to not pay you for your certificate. I continue to get continuing education credits. I have proof of that. I have done nothing unethical, tell me what I've done. That's unethical. And so they they went away. And then the next thing I knew is I got a letter from them saying, Oh, it was a mistake. We never should have let you join because you don't meet the criteria for being a member only
The criteria for being member only status in Asha is that you may not be a practicing audiologist, I was practicing audiologists, therefore I could not only be a member, and that was their response. Yeah, so what what would you say to people who are afraid of Asha,
I would say that Asha hat only has a hold on us because we continue to give them that status. And that people unmasked started to say to Asha, I don't want to buy your certificate that certificates too expensive. I want to be a member, but I don't want to be I don't want to buy your certificate, then as you would have to change its structure. I would also as a as a, your state organizations are really important here, because many of these regulations are on the state level. And and state organizations have to challenge them. And the other thing is that we all have to be bolstering licensure laws to make sure we have the strongest possible licensure laws. My argument is, if you want to tell me that there's that that
there's a certificate that has a higher standard than licensure, because somehow, those are those are important qualifications for a practitioner, then I would say everybody deserves practitioners who have those qualifications. If it's important, then it should be part of the licensure law, because everybody deserves to have the highest qualified provider, not just some few. So Ash has got to change its structure, it's got to start calling that CCC what it is continuing education certificate, sell it is that and then change the membership structure. That's what they need to be,
they could even have two certificates. Because the CCC is a one time training milestone, it indicates that you've done all these things XYZ, boom, done, you pay for that, you get it and then they can sell another. I mean, they could have multiple certification products, if they want to sell continuing education certification you want
if you want Girl Scout badges for getting
CE credits you if that's important to you, then you can do that. If that gets you something in your workplace, then you can buy that. But everybody shouldn't have to and the licensure, the licensure should be the standard that should be stringent. So what we should spend our energy on, yeah, that should separate it. And, you know, I think that some things have changed since I was a young person like you. I was my training and my master's degree and and my doctoral training,
the responsibility to be part of professional organization to give your time both on the state level and on the on the national level. That was part and parcel it mean, we knew that that was as much of our responsibility as anything we were ever going to do for patients. And we did. And I don't think that that's true. Now I started, you know, I started I tried to start an audiology organization in New York state. Because New York State doesn't have a New York Academy of Audiology. It has a New York State Speech Language Hearing Association, which I was president for two terms. They represent both speech language pathologists and audiologists licensure boards or licensure boards for Speech, Language Pathology, and audiology, in spite of the fact that they're two separate professions, you know, having a licensure board that licenses both physical therapists and physicians, you know, doesn't. So you can't get people to volunteer can't give people to give their time. And I think that the notion of the importance of individual efforts on the state level state level is critical. And then on the national level, for unsexy things, you know, writing standards, not fun
writing codes of ethics, not a lot of fun, but critical to the profession. So that's, that would be my advice.
One challenge that we're seeing, even through our efforts, is that some of these state organizations are run by people in academia who are not who, who and these are quotes that we have received. What because we invited every state to come on our podcast for the state by state series, which has been a huge hit. People like hearing about their state. We've gotten some feedback that from one state in particular that as soon as their episode aired their requests for membership skyrocketed. They reached out to us we didn't even follow up to ask that question. They told us
but some of these states that have either formally declined or who just ignore us, we've heard from people on those exec boards, we
We're told to toe the ASHA line, or we don't want to throw Asha under the bus. Michigan is trying, there's a group in Michigan right now trying to change the Medicaid regulation to get the CCC out of it. And they sent letters to their state association. And that association said, we're not doing this. We're gonna we're gonna go with our own agenda pretty much is what they said back. And that's ludicrous. You're you're supposed to be serving the members of your state, whether you're it, if you're an academia fine. You get accolades and raises and tenure and promotions and all of these things, for serving on those committees. But if you are serving, you need to serve the members not serve your members don't have any idea. Yeah, but like in Michigan, they haven't. They're they're asking, can we partner with you to work on this? No.
No, that was the answer. No.
Why is it that we feel like if we're questioning something with ASHA, that we're throwing them under the bus? Like, why is that?
That's always been that's called Asha bashing. It's not allowed, though, I think I think they have to be taking notice. I think that you have to keep informing speech language pathologists, what this means to them.
And, and then, I mean, do take a look at this. So that's the SOC codes. I think that'll inform give you some more information.
And I think partnering with state associations is a really important thing, because a lot of regs come there be another example,
to get a job in a hospital.
Hospitals will tell you SLPs and audiologists, they have to have their seats because it's a requirement of jch. The Joint Commission commission I'm not, we looked it up, we got another part of car fever.
And it's because it's been presented to the hospitals as if that is the equivalent of board certification.
Or how about this? Megan, I haven't even told you about this one yet. I recently took a job with a home health company who had no idea what the CCC was, I was so proud of them and praise them. But when I was signing the paperwork this week, I was going through the job description. And it didn't even say you had to have the CCC it said Asha membership preferred. And I was like,
I was like, What is this? And she's like, I don't really know. And I was like, well, it's in your paperwork. And so she looked at it because it was all electronic. And she's like, Oh, that probably came straight from chap. So chap is the accrediting body that they use. And so she's like, that is probably the job description that we're using from chap. So a chap, they don't care if you have your CCC, they just prefer a membership. Well, you can't be a member without the CCC. So yeah, I was like, well, at least it says preferred. We'd have to discuss this if it was required.
Yeah. And so but but that, you know, it is a strategy. It's a strategy, it was a strategy that was a decision at an executive board meeting of Asha, to do exactly what they've done with the C's.
To make them required in as many places as they could and to and to kind of distort their budget process so that it looks like everything they do. Is that certificate work?
filling my one question inside about lawsuits and the CCC. So what about these companies? Like in the state of Ohio, the CCC is not required for anything, we're pretty free here. Other than employers requiring it? Can Do you think that can be challenged legally, if they're not paying for it? Because? Or is it because they're private companies, they can require whatever they want?
I think a lot of times, they're requiring it because they don't understand even what they're requiring.
I don't know I'm not a lawyer, so I don't have any sustainability or sustaining partners people come on in
to be a discriminatory or
trying to think well, I like that word, though. That's a good word. You're mandatory. It's discriminatory. For for no reason whatsoever, because it has nothing to do with the competencies required for the position.
So can I ask, just I mean, you've been at this for, I mean, audiologists have been fighting ASHA for
I had balck hair when I started working.
So like, Jeanette and I have talked a lot about how do we want to move forward and I know odd
geologists move forward by creating an alternative membership association. And that's one tactic. And the way that Jeanette and I are approaching this is different in that we want to create this advocacy firm. And we want to be supported by very small monthly donations from sustaining partners, because there needs to be a counteracting force to keep Asha accountable. Given, like, how you've seen things evolve and unfold with audiology, do you have any advice for us as we move forward and try to build something that is that force?
I think starting a new organization is an enormous task. And
just an enormous task, I think that
doing get you a speech pathologist, I think, have a better chance of getting changed from within than audiologists did, because we were such a small group that they didn't care what we wanted, they were they were mostly concerned about their SLP membership, as they should be. It's, you know, 90% 95% of their membership. But you want to start getting people elected to the Board, who run on a
campaign that says they want to change the CCC, you want to start getting people to do it.
The problem is that we they've changed the election policy. So it's, it's done through a committee.
And you have to be vetted. And there's no way that if any of us would survive the vetting process,
could you imagine if Megan or Jeanette were put forth as a person they already know us by name, they'd be like, No, that we don't even need to vet them. No, they would say no, though, you would never be able to go up for we would never be able to be elected.
But others would be.
I mean, I don't know what their vetting process is. But I imagine it has something to do to get people
I think you're gonna have to keep challenging them. Every regulation that you find that requires those sees you to challenge and and you can do state by state on the federal level, you can do that. Just start asking questions, start pushing,
and getting people to do that.
state licensure boards, that's another place where you can go, because you have to, you have to loosen the hold that ASHA has had, I'm getting the name of that certificate embedded in dozens of places as if it's something other than what it is.
And the other thing would be to to get universities to understand that they are denying their students, supervisors, who are perfectly qualified supervisors who choose not to purchase that certificate. So I mean, that was more successful in audiology that was more easily successful in audiology, because a lot of private practices. You know, I had a premier private practice. And people were told they couldn't come to my office to do their, their practicum because nobody in my office had the seats, and we wouldn't play the game. I mean, there was just no way playing the game. So students miss out. Right, so another, another word they can use is like denying access to quality education outside of the classroom, correct. The quality supervision outside of the classroom.
And kind of documenting that they were told no, they couldn't go to that place. Because that person didn't have their sees.
What, what else? I mean, as we kind of wrap this up, like, what else have you
noticed as far as the shift in culture at ASHA, or the shift in culture of its membership base? Like, what do you what have you seen evolve recently? And what are you hopeful for in the future?
You know, I haven't watched speech language pathology, I mean, I really have not. So I'm only audiology. And I think that among audiologists, there are still a bunch.
There are people who buy that certificate who have nothing else to do with ASHA, they don't go to their conventions, they don't do anything.
But there are still a group of audiologists who who are kind of go along to, you know, go along, just go along with it. It's not a big deal. It's 200 some dollars a year just go along with it, it makes life easier. Don't challenge it. To me. It's a matter of principle. And and if if there's such a thing as ethical behavior by it by a professional association, just as there's ethical behavior by practitioners, what Ash is doing is unethical. It's unethical, it's dishonest, and I don't think that
are professional organizations should run themselves unethically while insisting that there are codes of ethics that we as practitioners need to follow. So it's more of a matter of principles to me.
I always said before I die, I want that certificate to die. I just want it or at least I want there to be honesty about it. And so far, that's not been true.
So we're five months closer with fix SLP, where five minutes
I have great hope I was very excited to see what you guys are doing and that there's truth telling, and I'm impressed by the data you've gathered. So keep up the good work, anything I can do to be helpful. I will.
Keep going
I have a question. Hopefully you're comfortable sharing this, do you have grandkids?
Six of them.
What do they call you?
Mema.
Okay. So you are the Mema fixer that I believe that Big Daddy Asha
Mima fixer, like that is who you are. I just I'm so impressed. I'm so thank you that
introduced us, me
when I saw that stuff I have written to every audiologist, I know all my old and I'll tell you there are some folks, I won't say it out loud, but I'll text you. There's some other audiologists who were part of this certainly just as active as I in in the work that AAA has done, that I think have useful information to you about academia, and about some of the particular challenges there that you want to talk to. So I'll send you that information privately. I mean, I certainly have not been alone here. There are people who came long before me and who have done
incredible work in getting audiologists to understand their status as autonomous practitioners.
Thank you for all the work that you've done.
You're very welcome.
You're inspiring all of us.
Go get him.
We're trying. We're trying.
So far, so good. So far, so good.
Okay, I'm just gonna wrap up real quick. If you love what we're doing. We do not have a Patreon like you're used to hearing. We have something called a sustaining partnership. We asked that people just throw us $5 A month you can find out more information about that at fixed slp.com. I have got a review. I've got a review. This one is from running Jess. She said I can't think Megan and Jeanette enough for this podcast and movement. They take the time to research issues on our behalf and give clear pathways on how to advocate for ourselves. From podcast to social media, the information you will receive is so valuable. Asha better sleep with one eye open. These amazing professionals know how to find answers and they bring the documentation and proof. It will take all of us to solve the big national issues. They give us a way to embrace our autonomy and help move in the right direction. Thank you for helping all of us get clear on our vision. You are welcome Ron in jest that was I randomly chose that. That was gorgeous. Thank you. Okay, so if no one has anything else, everyone's good, Megan. Yep. Then we're just gonna tell everybody thanks for fixing it and we will see you next time. Bye, everybody.