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, Fixers, welcome back. Jeanette and Preston are here for you today with a very quick, very last minute episode. We have already recorded the episode that you were supposed to be hearing today. But like I say, we do this in real life. Some fixers have contacted us and asked us for help in the state of Texas, we looked into their issue, and we said, Yes, we need to move on this right now. And not only do we need to move on this right now because it's happening, but we need to bring this to all of the fixers to expose some information. So while we have state teams in many states, and we are working behind the scenes with those teams and team leaders, we're not always talking about it on the podcast or putting it out in content with you, but today kind of feels like a little emergency in my heart. It's raising my blood pressure, for sure. So I'm at my mother in law's house. We just had a Lisa Frank baby shower yesterday for my sister in law. I'm sitting on a bed because there are so many people in this house, so hopefully audio stays stable, and we get through this, but Preston, we're just gonna open right now. Preston is more than just my right hand man on the podcast. He has also fixed SLPs, director of public policy and legislative affairs. He has done a deep dive. He doesn't mess around. ASHA is not hiding anymore in plain sight. We are watching them. Preston play us the clip you found.
All right from the Texas State Senate. This was back on, I believe, April the 30th, and it's a bill that was being introduced. I'll let the bill sponsor, Texas State Senator describe it right now.
Welcome this morning, Dean Zaferini.
Thank you, Madam Chair. Madam Chair and members. Senate Bill 905 relates to the Licensing and Regulation of speech language pathologists and audiologists. This is a cleanup bill requested by the Texas Department of Licensing and Regulation member Senate Bill 905 is similar to my Senate Bill 904 and that both focus on regulations for certain hearing related professions. This bill, however, focuses on speech language pathologists and audiologists, while Senate Bill 904 which you heard last week focused on hearing instrument fitters and dispensers. Senate Bill 905 would streamline regulations for speech language pathologist and audiologist generally, by allowing the Texas Commission on licensing and regulations to consult only with the relevant advisory board on hearing instrument rules, rather than mandating and consult both the speech language pathologist audiologist Advisory Board and the hearing instrument fitters advisory board. It also would remove provisional licenses, which are no longer necessary, and remove the requirement that only physicians specializing in ear diseases may authorize the purchase of hearing instruments for minors. The committee substitute was requested by the Texas Department of Licensing and Regulation, the Texas Hearing Aid Association, the American Speech Language Hearing Association, and the Texas Academy of Audiology, and differs from the bill it's filed in that it would ensure compliance with federal law that's always a good thing by allowing any licensed physician to sign the authorization statement, thereby increasing access to hearing instruments for minors. And that's all the bill does, Madam Chair and members. Thank you, members. Any questions, we have a resource witness. I don't know that we need one. Everybody good. Sen zaffrey is my intent to vote this bill today. So thank you. Thank you, Madam Chair and members.
So really, what we're looking at is largely a bill that deals with hearing aid dispensers and cleaning up some of the laws there, and how physicians can request things, and all of those things are good, but like a lot of situations that we've encountered, there's always that one little nugget in there and here. We hear the great name of ASHA mentioned is having a part in this. And so how does it affect the SLP, we've looked into the bill by removing their provisional licensure process, which actually is not a bad thing, when you get down to it. They have this part in there, though. So you take out the provisional, you're going to go for the full license. And Texas, like a lot of states, has the different things they require, the transcripts, your intern experience and examination. Currently, if you hold a CCC, then you can potentially get exempted from that examination. The existing law for provisional though, allows you to enter in other experience and things of that nature without the CCC. So section two of the bill, and actually it's section 401, point 308. A ll that's left there is certificate of criminal competence waiver. So basically, that is the thing that's going to get you around taking a Praxis in Texas is holding the CCC. Jeanette and I both feel that it's okay to have to take a Praxis sometimes when you get your license, but our issue is that don't make the CCC the one thing that gets you around that don't make it the only exception. State licensure should also be alongside because, as we always say, that's what defines our profession. So we're going to talk a little bit more about this, and we're going to try to put a call to action to if they want to pass the bill. That's one thing, but it should be amended to include our state issued licensure.
Yeah. So this is just my personal stance. We can all agree to disagree or have other opinions or thoughts and ideas. Those are all welcomed here. But the trend, and this is just online, because this is where we see things, is really that SLPs don't have enough respect in the school or in a medical setting. We don't we don't get the respect that we deserve. We don't get the respect that our colleagues have. And my thought process here is we cannot have our cake and eat it too. So we are one of the only professions. We've talked about this over and over and over again that has something like the CCC, and if we want to be respected in the way that our colleagues are respected. We can't scream and shout that we don't want to pay $250 a year. But then ask for the CCC to save us when it's convenient for us. So we need to be all in or all out, and here at fix SLP, we are all out. So the CCC cannot be the thing that allows interstate portability. And when we first took a look at this, we thought, well, maybe they're doing this because they have signed into the interstate compact, and on the surface, that is probably part of this. They do not need a provisional license, really, if they're going to be in the interstate compact, because the interstate compact will allow for people living outside of the state of Texas to practice within the state of Texas through compact privileges. So that's a good thing. Where this becomes a problem is if you move to the state of Texas and it becomes your home state, the interstate compact has nothing to do with portability of the license if you change your home state. So if I'm living in Ohio, where we've signed in, and I want to do some teletherapy in Texas, or take a quick 13 week assignment out there, I can use my compact privileges to go practice in Texas. If they pass, they have not yet. It's legislation pending hasn't passed for the just letting go. They are. They're looking at it. It's pending, but they're not there yet. But in this hypothetical scenario, please continue. Okay, thank you for that correction. So maybe I take a 13 week assignment, and I love it, and I think I'm never leaving. I'm gonna stay here. I'm gonna make this my job. Now I need to apply for a permanent license in the state of Texas. My compact privileges via Ohio as my home state will no longer be good if I move my permanent residence to Texas, and that's where the issue arises. The compact isn't going to help me get a permanent license in Texas. I would need to apply as a new applicant. And so what this is saying is, as a new applicant, I can provide every single thing needed that they're asking for. And I should have to do that really. I can provide everything they're asking for, for the license, or just have my CCC. And again, that's where we propose that that should not be a thing. Yes, it is. It makes it convenient for us, but there are other ways that we can do this without having to lean into that CCC. Every single state has the same requirements, except for Hawaii and North Dakota. And last time I saw North Dakota was working on their problem. North Dakota's difference is that they don't require a nine month supervised experience after graduation. So that's a problem, but I think there was some moves to change that, and then Hawaii does not require continuing education. Hawaii has to get on that. Hawaii needs to deal with that. But other than that, in Washington, DC and every other state, the state requirements are equivalent to, or more difficult than the CCC. So if we want to have portability from state to state, we need to be writing that an equivalent state license would also allow for portability into the state, not the CCC, an equivalent state license. And I would say the word equivalent, because if you're worried about someone from Hawaii coming to Texas, I could support that Hawaii. Get your act together if you don't, if you want to have that portability, do what the rest of us are doing.
But this represents less than 1% and I agree with the adding of the word equivalent, but that's sometimes being the pushback from ashes that, well, there are some states with not, you know, strict, rigorous, you know, standards that is less than 1% of our SLPs, because both North Dakota and Hawaii, they're small states. So trying to hold that up is the rationale is very weak sauce.
Yeah, and let's be honest, a lot of us in this field who went through graduate school on paper, not on the electronic everything that exists Now, a lot of people don't have their signed internship hours. They don't have their signed letter from their graduate program that they matriculated through an accredited institution. They don't have those things. They would also have to retake the Praxis, and Preston has already said that's not a bad thing. When you look at the medical profession or like lawyers. You want to change states, you're retaking the bar. You want to change states? You're retaking your medical examination license. If we want to be held to the same standard, we should probably have to participate in the same type of requirements. Again, we can't have our cake and eat it too. Do we want to be all in, or do we want to be all out? And so, okay, we won't fight having to retake that praxis. We can get around it by being licensed in other states if you've taken that praxis, once you got your license in Maine and now you're moving to Texas, your main license, if we want to have the portability, should be enough, because the main license and the Texas license are equivalent, that should be enough.
And Texas with their licensing board website, which I went to, it's actually very friendly website. It's well designed. It has a part on there for SLPs, who are plus 10 years since attaining their degree. They are, at that point, recognizing state licensure. In fact, they even save, you know, show us current copies of your CEUs. They recognize that some of those things are long gone, like you said. So there's already, I think, a loose friendliness there with the state license and recognizing that within their licensing board. So that's why this bill, it's not a bad bill. It just needs one edition of a few words there that will keep that equivalence in line and not promote a third party certificate sale, and so I that's going to be the call to action that we'll send out, is that, let's just amend this thing that's, you know, pretty simple. It's not a lot of language, and it basically goes hand in glove with what you already are recognizing on your licensing board procedure for people who are 10 plus years out.
And our problem is also, that ASHA had a hand in this.ASHA knows what SLPs are now fighting against and they knew what they were doing when they certainly suggested leaving in the CCC, because "we are the gold standard." I just wrote a response to someone on Facebook last night. There was a public account that put out some visuals on what an SLP is, and it included the CCC. And our fixers got up in those comments. Good for you guys. And the person who owned that account pushed back and said, It's the gold standard. And I wrote back and said, but is it? Is it really the gold standard? So this account, this is, by the way, a Texas SLP, has this account, and I'm not going to put her name or her account name out there, but let me tell you, I went ahead and I pulled up the graphic, and this is super problematic. The graphic says, What are speech language pathologists? Speech language pathologists are licensed medical professionals who assess, diagnose and treat disorders of communication, cognition, voice and swallowing. And then there are four notes about what an SLP has. And note number three is national board certification. And in parentheses, it says CCC, SLP and state licensure. Thing number one that I didn't even put in my comment is that the CCC is not a national board certification. ASHA is not a board ASHA is a membership association like the Rotary Club, like the Key Club, like FFA, Farmers of America, Asher,
Future Farmers of America
Thank you. It is a club, okay? At its core, ASHA is a club. It is not a board. They have a board, but so do all the other clubs. That's how you run a nonprofit. You have to have a board to have a nonprofit. So this is what I said. "We want to highlight why wording like this does real harm. Pushing the CCC SLP as a requirement, or even framing it as essential, misleads both clinicians and employers. The CCC is a certificate, not a license, and state licensure is what grants legal permission to practice. When we blur that line, we reinforce barriers that limit access to care, inflate job requirements unnecessarily and discourage qualified SLPs from the workforce. We've seen firsthand how employers and even state agencies mistakenly interpret messaging like this as law contributing to harmful gatekeeping and workforce shortages. It's not just semantics. It directly impacts job access, patient care and the future of our field. Thanks for being open to the conversation." It was a point to all of that, and mine forget, because now I'm all worked up. Why was I saying that, Preston?
I think that it's just going back to what is equivalent. What are we talking about, right? And this bill to go back to it with SB 905 in Texas, as I said, it's good legislation. It's sponsored by one of the most veteran Texas legislators, a senator there, that's zaferini Judith. She's from the Laredo area. This bill, again, deals with a lot of things, with the hearing aid dispensers, removing the provisional licensure, great, but it exposes within the Texas law that currently the CCC is being used as that exemption for around praxis, you can't have your cake and eat it. You can't take somebody's third party certificate that they're making Bucha of money on and elevate that over our state licenses that may have worked pre 2015 before Colorado cemented their licensure, but we are now a grown up profession that deserves to be seen just like our other allied health professions, and not be gatekeeped and not be sort of beholden to the sale of somebody coming up with an arbitrary certificate and selling it. So do we want to strike it all out of there the mention of the CCC? Yeah, that'd be great. However, I think in this case, let's just be equivalent. Let's ask for equal standing with the state licensure. So that will be in our call to action. It will be put on the fix SLP page with a template, if you're in Texas. There also will be a link for you to find your individual state rep, state senator, we'll try to highlight perhaps some of the committee members, because this has already made it through the Senate committee, it will likely go before a full vote of the Texas State Senate. And given their procedures, I'm going to assume that they have to go back over to the house through a committee there. That's where the focus really needs to be that hey, great, Bill. But you can amend it by adding just a few lines in there, and you can take Texas into the modern era and not be looking back like we're a profession from pre 1984.
So I'd love to say that by the time this episode airs, I will have all of that up on the website. I will not I am out of town, so it's coming. What you can do in the meantime, you can go ahead and check fix slp.com, I will have a bar at the top of the web, website with all of the resource sources that you need in Texas to take action. I will make sure when this drops, that in our stories, we have the link for you to update your email subscription with us by adding your state. So I'm hopeful, after I put this episode live, then my next thing will be to get everything on the website, if I can time it correctly. About 24 hours after this drops, this is going to come out on a Tuesday, sometime on Wednesday, I will probably send an email, maybe Wednesday night or Thursday morning to all Texas newsletter subscribers, letting you know that the resources are live and giving you a link and re explaining all of this again. So if you have not yet updated your email with us, all we need is your state. When I'm ready to send it, I will pull all Texas subscribers who have their state with their email address, and I will send you an email. Or you can just subscribe. So if you want to subscribe, fix slp.com, down at the bottom. If you're not sure if you've ever updated, go ahead put your stuff in again, fix slp.com, down at the bottom, or I'll have a link in stories directly where you can update your state.
The irony is too, we obviously want stakeholders and people within Texas to reach out to their reps, because that's where you'll get the best response. However, as I said, there is an irony here that this bill would likely impact, or at least the the way they're going to pare this down, with this current incongruity will impact people who want to move to Texas. Perhaps you've considered relocating, or you have family there, and you could imagine needing a Texas State license to practice in your profession, I would go ahead and reach out as well if you feel like you fall into that group, because that's who it's going to impact. And if you decide someday, hey, I don't want to carry the certificate anymore, but I also don't want to be dinged with a Praxis test because I have a license that I've maintained, maybe you can get in on this argument as well.
What Preston said, I just want to highlight again, that just so everyone's very, very clear, this does not impact initial licensure. For people in Texas who are going through the process nine months after graduation, you're going through, you're taking, you're taking your practice, you're doing all the things you have the documentation to go ahead and get your state license without the CCC, new applicants, young applicants, you're going to have all this stuff. You don't you still don't have to get the CCC if you don't want to. This applies to people moving to Texas who are already licensed in another state. So Texas is not changing anything to require the CCC for practice. What they've done is worked with ASHA to write this bill that Preston said mainly deals with hearing aid dispensers, and many states are doing that right now. But what ASHA has encouraged them, I am quite certain is to leave in the CCC equivalent. So probably what happened was they knew that they're probably trying to push forward to become part of the interstate compact. They've recognized that with that interstate compact, they are not going to need this provisional license. So let's just strike it and let's just layer that into this bill for hearing aid dispensers, because it's going to pass. So it's less work for us, one less bill we have to put for it. You know, people always have agendas too, so there might have been some other things going on, but with ashes help, they're not going to say and state equivalent, they're going to tell old Judy, God bless her. We're the authority. We are the gold standard. You should at least have the CCC for portability from state to state if you're going to get rid of your provisional license. And there's no way they would suggest the state license, because they are always going to represent themselves as the authority, because financially, they have something to gain. They're never going to stand down. But what I love is they say we don't lobby for the CCC. We don't push for the CCC. We have it recorded. We just played it for you. Video and audio. You can go to our Tiktok @fix.SLP, it'll probably end up on Instagram too. Go take a look at Judy reading that bill, saying that ASHA helped put this forward. ASHA had everything to do with requiring the CCC for a new applicant in Texas. Everything. Maybe that wasn't lobbying. Maybe they weren't paying for lobbyists, but they're paying some staff member to advise Texas and help them on what this bill should say.
Well, and just to be clear, Jeanette, it is already in there, so what they're doing is taking out that provisional process and just leaving the CCC standing alone for that exemption. And so that's that's the issue is that when ASHA has its interventions, it's always to keep that foot in the door for the sale of that certificate. It's never saying, Look, we recognize that this is a modernized profession. Put state licensure there alongside us, but we certainly want to continue to be, if you want to call yourself the gold standard, we certainly want to continue to be a sphere of influence within the stakeholder within our profession. That's fine, but anytime that they're there, it's never to broaden the field. It's to put everybody back through their gates, because they make money coming and going on that every year. So that's the problem. It's you can have all the great motivations in the world, but when you are still trying to make that sale, you're just you feel a little bit dirty.
Mmm-hmm. So I don't think we need to go on and on. We knew this would be a short episode today. I'm going to sum this up then Preston, you can jump in if I miss anything. But overall, this bill, while it mostly deals with hearing aid dispensers, removes the provisional license for SLPs from Texas, which is fine, because likely they will be entering the interstate compact, so people will still be able to practice with compact privileges. But where it becomes problematic is if someone moves to Texas, makes that their home state, they now need to get a permanent license. There are two ways to do it, and again, this hasn't been passed, but this is what they are proposing. One, either have your CCC, or two provide all of the things that you need for a state license, which typically a new grad would have, but a dino like me and Preston maybe don't have, and it would also require retaking the Praxis if it has been less than five years since taking it.
Yeah, if you look at their current licensure page, I think there are a lot of things that they would go ahead and take to honor that however, that Praxis is going to be the issue in there. And again, I've got no issue. If they want to have folks take a Praxis across the board, that's their call. But if you are opting out for an exemption strictly based on that certificate, that's the issue is that it elevates their product and basically incentivizes the sale. And you know it it's just one of those many tentacles that are out there to keep this thing breathing and living and thriving, whereas our state licenses are really at our core. That's what defines us.
It keeps the fear alive is what it does.
Yeah, yeah.
it keeps people thinking, what if I have to move someday? I'm a military family. I know I'm gonna have to move. I live outside of Texas. What if we cross state lines someday? What if? What if? What if I have a couple bullet points, it threatens autonomy for SLPs. It's a threat to state autonomy, so it's undermining Texas's authority to set their own standards. They're deferring to ASHA driven criteria for folks moving into their state. It creates barriers for us qualified professionals, again, who want to move there. It's risking excluding experienced state licensed SLPs who choose not to maintain ASHA membership or certification despite being fully qualified under Texas state law to practice. There's a barrier there. It increased cost and flexibility for SLPs through that gatekeeping mechanism that Preston just talked about, there would be unnecessary financial burdens to either maintain the certification, just in case that fear, what if? What if? What if, or to have to pay to meet their requirements. So it contradicts this effort towards broader licensure mobility, which is sort of what the Compact is trying to do. What I have to wonder is, was there stakeholder engagement? Because there was no public comment. These things in the past have gone through without issue. ASHA could get this language through without issue? But people are watching now, and someone caught this. Maybe there was a public comment period, but a fixer caught this after Judy gave her little spiel there. So now it's time for that stakeholder engagement. We are stakeholders, all of us. So like Preston said, If you think you could ever move to Texas, and that could be any one of us really get in, get into our call to action. Start contacting very quickly state representatives. Tell them why this is a problem. Ask them not to vote it until there's a modification. Preston and I will work on a letter, some bullet points, scripts, that kind of thing and and let's do this. You guys, we have changed Medicaid law. We have changed some things that ASHA has done, whether they want to admit it or not, we have seen significant change since this grassroots advocacy firm hit the ground running. Let's do it again. You guys are amazing. Let's do it again. There's nothing better than posting about a celebration. I want nothing more than to see this bill modified for the benefit of all SLPs and the benefit of SLP, autonomy.
Jeanette, it's great seeing you. We're gonna put a wrap on it today, and I will put those templates forward. Keep a look on the website, and this is an issue. Hopefully we can make another small change on.
Mmm-hmmm. And I can say because I know we already have it in the can. Next week, you're going to hear from Meredith Harold from the informed jobs and the informed SLP, giving us some updates on how many jobs actually require the CCC right now according to their database, and really talking about packages and pay for what SLPs make, what they should be making, and a lot of the problems that the folks over at informed jobs have identified. So we will see you guys next week. Thanks for fixing it!
