“Can I Even Supervise Without the CCC?” Yes—But They Don’t Want You to Know That.

You're not alone if you've ever been told you must hold the CCC to supervise students or new graduates. It's one of the most widespread—and misunderstood—claims in our field. And it's exactly the kind of myth that keeps us paying into a system that's long overdue for an overhaul.

So, what's the truth?

SLP supervisors are not universally required to hold the CCC to supervise graduate students or new graduates.

Image caption: The CCC system isn't built to support the field. It's built to support the revenue stream.

The only reason it ever becomes “required” is if a student eventually wants to pay ASHA for their CCC. That's it. If they want those three fancy letters, they need a supervisor who is already paying the annual fee. But if they don't? No federal or state law says you must have CCCs to be a competent, effective supervisor.

And ASHA isn't being transparent about that.

In 2022, ASHA reported that running the CCC program cost about $2.4 million. That same year, the organization made $42.5 million in CCC-related fees. Do the math: that's over $40 million in pure profit.

As of 2025, that certification renewal fee has climbed to $250/year, and who still goes unpaid? The supervisors. New graduate mentors, student externship supervisors, and seasoned professionals shaping the next generation of SLPs… all volunteer their time and pay for the privilege.

This isn’t professional development. It’s a pay-to-play system.

  • You supervise for free.
  • You pay $250/year to do it if the student wants the CCC.
  • Your experience is treated as a product, not a qualification.

That’s not advancement. That’s exploitation.

What happens if we stop holding it up?

The CCC is not the law. It's a product. And the only reason it keeps showing up in supervision policies is because we've allowed institutions—universities, employers, and yes, ASHA—to convince us it's mandatory. It isn't. But let's unpack what's really pulling the strings.

The CFCC: ASHA's Certification Gatekeeper

The Council for Clinical Certification in Audiology and Speech-Language Pathology (CFCC) is a semi-autonomous body within ASHA that:

  • Defines the standards to obtain the CCC.
  • Grants and revokes CCC certification.
  • Decides who can supervise Clinical Fellows if they are pursuing the CCC.
  • Oversees maintenance requirements for those who hold the CCC.

In short, the CFCC only controls things for people choosing to pursue the CCC. If a new graduate doesn't want it? Their rules don't apply.

The CAA: The Accreditation Body That Doesn’t Require the CCC

The Council on Academic Accreditation (CAA) accredits graduate programs in SLP and audiology. It is also semi-autonomous within ASHA—but here's the key:

The CAA does not require that supervisors of graduate students hold the CCC.

Let’s say that again for the people in the back:

CAA accreditation does not depend on CCC-holding supervisors.

Why doesn’t the CAA require the CCC?

Because it would violate antitrust law.

The Sherman Act and the Federal Trade Commission (FTC) prohibit policies that create unfair restraints on trade or artificially limit who can work. If the CAA required the CCC, it would lock state-licensed professionals out of the ability to supervise without cause—which is legally questionable at best and downright anti-competitive at worst.

So they don't, and they never have.

So, where is the “requirement” really coming from?

Universities. Plain and simple.

Universities are the ones choosing to write the CCC into their program policies. They are not required to. The CAA doesn’t tell them to. ASHA doesn’t mandate it. It is a local, internal decision, which means it can be changed.

Image caption: Systems change when we stop upholding them out of habit, fear, or convenience.

Universities are just as responsible—if not more—for sustaining this mess.

They’ve created unnecessary restrictions that:

  • Exclude qualified, licensed SLPs from supervising,
  • Limit placement opportunities for students,
  • And prop up ASHA’s financial model under the illusion of “standards.”

It’s time to call it what it is: a policy failure, not a professional requirement.

Let's talk about the pressure on students and new graduates.

Here's the truth: most students and new grads aren't choosing the CCC—they're being told they have to get it or strongly advised in ways that leave little room for questions.

  • "You’ll need the CCC to get a job."
  • "You won’t be able to bill insurance without it."
  • "It’s required to move across states."

None of these things are universally true. In fact, most states don’t require the CCC to get licensed, and most insurance and Medicaid programs don’t require it either. But few students ever hear that.

Instead, they’re pushed—quietly or forcefully—into paying for a product they were never given a fair chance to evaluate.

That’s not informed consent. That’s gatekeeping wrapped in a cap and gown.

And it’s unethical.

Universities should empower students with accurate, unbiased information about all professional pathways, not funneling them toward one certification option that happens to financially benefit the organization accrediting their program.

💬 We don’t let pharmaceutical reps into classrooms to influence treatment plans—why are we letting ASHA’s business interests dictate professional guidance?

If universities are genuinely committed to educating ethical, autonomous clinicians, they must:

  • Clearly explain that the CCC is optional.
  • Break down the total cost over a career (tens of thousands of dollars).
  • Discuss alternative options, including licensure-only pathways.
  • Stop using fear of the unknown as a tool to drive compliance.

Students deserve to choose their future. Not buy it under pressure.

What can I say if I want to supervise without the CCC?

Here’s a professional, clear message you can send to any university program coordinator:

"I hold a valid state license to practice speech-language pathology and meet all supervision requirements under state law. Since the Council on Academic Accreditation (CAA) does not require CCC certification for supervision—and the program’s accreditation is not impacted by supervisor CCC status—I’d like to clarify whether your requirement is based on university policy. If so, I’d respectfully ask that the policy be reconsidered to allow qualified, licensed SLPs like myself to support student training and supervision."

Simple. Professional. Accurate. And incredibly important.

Bottom line?

The CCC is only “required” if we keep pretending it is.

Let’s stop paying to participate in our own gatekeeping. Let’s demand systems that value supervisors, center clinical skill—not membership status—and give students access to the diverse, experienced mentors they deserve.

We don’t need a membership card to be excellent SLPs. It’s long past time we stopped letting a $250 product determine who is “qualified” to supervise.

Keep Fixin' It!
Jeanette Benigas, PhD 
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