Let's Talk About the CCC

Allow me to begin...

For those of you who have been following my posts via the @therapyinsights IG account, thank you for engaging in all of the discussion around this topic!

My name is Megan Berg. I'm the founder of Therapy Insights and an SLP in Montana. I went back to grad school later in life after a career in science communication and was drawn to the field because it is a meaningful blend of both art and science. I have spent most of my time working with adults in rehabilitation settings. I am someone who can clearly see patterns, identify solutions, and execute plans. I think this is what has made me a good therapist, and for better or worse, the person who is launching this website (along with Jeanette Benigas, PhD, SLP.)

I have been wanting to start Fix SLP for a while now. This project is an offshoot of the SLP Data Initiative. My brain has been processing lots of ideas in the background, with a mess of notes precariously perched in my brain. I have so many jumbled half-finished thoughts scrawled all over pieces of my life with visions in my mind of everything falling smoothly into place so that I could cohesively present them to all of you in a very clear, concise, easy-to-digest format. I wanted to present the shiny ending of the thought processing, not the messy middle. But that's not what happened.

On September 5, I started posting information about the CCC on Instagram. It felt like I had this information inside of me, bursting to get out whether I was ready or not. It was messy. Every time I posted something, I learned something new. The more I learned, the more the picture became clear to me. And I realized that I can't really move forward with this project without all of you being in on the messy middle with me.

And so I've come to the conclusion that Fix SLP will never be this shiny project that I'm able to pass on to all of you with a picture-perfect bow. It's going to be this ongoing sort of collaborative conversation that we have via this blog, our podcast, and social media. We will all be learning as we go, me included. If I ever say anything that's incorrect, I want you to correct me. Providing accurate facts is my goal here, and I will always appreciate it if you come to me to correct something I've said, whether we agree on things or not. This is part of the learning process.

Part of the learning process involves getting some things wrong. I want to correct some things that I got incorrect on the Instagram posts:

  • ACOTE is associated with AOTA.
  • CAPTE is associated with APTA.
  • In addition to Nevada and Virginia, New Jersey also requires the CCC. Similar to Virginia, New Jersey only requires the CCC if you don't work in a school.
  • I initially stated that grad school supervision hours don't count towards the CCC, but later learned that the 400 "clock hours," as they call them, do count (but only if they were supervised by someone with a CCC), so the earliest posts have some false information about this.

Now I am going to summarize the information that was presented via Instagram about the CCC.

The rumors outlined below are very prevalent in our field. It's these rumors that have caused me a lot of confusion and frustration and ultimately what has kept me thinking that I need to continue to pay for the CCC every year. I will break them down by rumor, and then provide the factual information dispelling the rumor.

I also want to point out that currently, you must be in a place of privilege to be able to drop your CCC. Which is kind of ironic, because years ago, it was a place of privilege to be able to obtain the CCC. Only people who are in steady employment with employers who don't require it, people who live in states with licensing boards that don't require it, and/or people who have alternative means of financial stability should they find themselves in a situation where their employer changes unexpectedly or they move states unexpectedly are in a position to opt out of the CCC. So my goal in sharing this information is not to pressure you or guilt you or tell you what to do. It's to provide you with information so that in the coming years, you can continue to re-evaluate your situation and make an informed choice that is right for you.

Rumor #1: The CCC is required to bill insurance.

Update November 10, 2023: We combed through each state Medicaid regulation and discovered which states have requirements for the CCC in order to bill Medicaid. Note that these requirements do not align with federal requirements set by CMS. You can access our spreadsheet of information, including sources, here.


When I started looking into this, I began by reaching out directly to the Centers for Medicare and Medicaid (CMS). I am going to paste the email from them below:


Ms. Berg,

It would be a Conditions of Participation for certified providers like HHAs/SNFs/Hospitals.

I found this from the CFR that is specific to HHAs. There should be the same thing for other certified providers.  Note in the requirements for number 2 are only for STs in a state that doesn't issue licenses to them.  I would not think many states still do not issue ST licenses.

42 CFR 484.115(n) "Condition of participation: Personnel qualifications" lists the requirements for speech pathologists as:
Standard: Speech-language pathologist.  A person who has a master's or doctoral degree in speech-language pathology, and who meets either of the following requirements:

(1) Is licensed as a speech-language pathologist by the state in which the individual furnishes such services; or

(2) In the case of an individual who furnishes services in a state which does not license speech-language pathologists:

(i) Has successfully completed 350 clock hours of supervised clinical practicum (or is in the process of accumulating supervised clinical experience);

(ii) Performed not less than 9 months of supervised full-time speech-language pathology services after obtaining a master's or doctoral degree in speech-language pathology or a related field; and

(iii) Successfully completed a national examination in speech-language pathology approved by the Secretary.


Additionally, OT/PT/STs are not required to have an individual enrollment if they are working for a certified provider.  It can get confusing because the therapists don't realize the outpatient clinic they have worked bills for their services through FISS and paid at whatever OPPS amount is.


I emailed them back and asked to clarify if this applied to home health or all settings, and again, this is a direct quote from the email from CMS:


Good Morning,

The Provider Enrollment (PE) chapter in the IOM indicates a state license is all you would need. - Speech Language Pathologists in Private Practice (Rev. 10800; Issued: 05-20-21; Effective: 06-22-21; Implementation: 06-22-21)

Consistent with 42 CFR § 410.62(c), in order to qualify as an outpatient speech-language pathologist in private practice, an individual must meet the following requirements:
(i) Be legally authorized (if applicable, licensed, certified, or registered) to engage in the private practice of speech-language pathology by the state in which he or she practices, and practice only within the scope of his or her license and/or certification. 


 It's truly not possible for me to call every insurance company and ask if they require the CCC. Believe me, I've tried. You want to know the first thing they ask you? "What's your provider ID?" You literally cannot get past their dial directory without a provider ID. But I can tell you that I called CAQH (Council for Affordable Quality Healthcare, Inc.). A lot of (all?) SLP private practice providers register with them, and this allows them the ability expedite provider approval with multiple insurers. They verbally confirmed over the phone that only a state license is required to register with them, indicating that insurance companies do not care if you have a CCC or not.

Other links:

Rumor #2: The CCC is required to practice as an SLP.


This rumor is probably the most egregious as it stems from misinformation that is given pretty much on the first day of grad school by people in authority. If you are an SLP who has any kind of role in teaching students, I urge you to critically analyze this information and decide for yourself if students should be told that the CCC is required.

The CCC is a product that is sold by a national membership association. It is not a license to practice. Unless a state licensing board requires the CCC (which we'll get to) or your employer also requires the CCC (we will also get to that), you do not need a CCC to be an SLP.

When we look at the historical framework of the field of speech-language pathology, it's understandable how the CCC came to hold so much power. Let's take a brief dive back in time (my undergraduate degree is in history and I love how history shows us why things are the way they are):

  • 1925: ASHA is established.
  • 1925-1952: Free for all! Anyone can be an SLP (although they all called themslves different names).
  • 1952: Certification program started, offering Basic and Advanced certification.
  • 1965–1970: CCC was established to help differentiate certified speech therapists from people without training who were opening practices and calling themselves speech therapists.
  • 2016: Colorado was the last and final state to establish a state licensing board for speech-language pathology and audiology, thus fully regulating the profession and criminalizing anyone who attempts to work as an SLP without a state license.
  • Today: SLPs across America grapple with the idea that certification, while it served a purpose in the 70s, 80s, 90s, and early 00s, is now redundant since all 50 states have licensing boards.

The field of speech-language pathology is truly still in its infancy. We are currently experiencing the growing pains of identifying the difference between a certification product and a legal license to work. The reason the CCC is so intertwined in job requirements and what SLPs think they need in order to practice is because for a long time, it was the only way to actually vet people claiming to be an SLP and the only way that SLPs could demonstrate that they had met any standards.

Things have changed. We now have state licensing boards and while a national general SLP certification can continue to remain an option, it is not required to work as an SLP (with the following two exceptions that we will outline next).

Rumor #3: Employers require the CCC.

I have worked in multiple SLP jobs in Colorado and Montana and have never had to provide proof of holding the CCC. So this one was new to me personally, but I'm learning that a lot of regions (especially school districts) seem to have this requirement in place.

Given the historical framework outlined above, it makes sense that employers have an outdated policy of requiring the CCC. Prior to 2016, it was the only way to ensure that they were getting candidates who had met any kind of standard. Employers need to update their policy to only require state licensure (similar to OTs and PTs), although it is always their right to request any certification (and there are many options available in the field).

The burden of updating employer policies is going to fall on SLPs. ASHA is not going to do this advocacy work because it's not in their best interest. This means that we all need to be educating employers with the following information:

  • Certifications are optional for SLPs (including the Certificate of Clinical Competence, or CCC). State licenses are required.
  • Prior to 2016, the CCC was the only way across the United States to ensure that an SLP had received the proper training and passed an examination to become an SLP. This is probably why the organization implemented this requirement, which is now outdated.
  • In 2016, Colorado was the last and final state to establish an SLP state licensing board.
  • All 50 states now have licensing boards that thoroughly vet all licensees and criminalize anyone who attempts to act as an SLP without meeting the board’s stringent requirements.
  • The CCC is an optional certification that costs hundreds of dollars in annual fees for SLPs to maintain. These fees are accumulated on top of required state license renewal fees.
  • The annual requirements to maintain a state license are the same as or more stringent than those to maintain the CCC, depending on the state.
  • SLPs are not required to hold the CCC to bill Medicare or Medicaid. Please refer to this code of federal regulations (or see rumor #1 listed above for more information).

We partnered with Brooke Richardson, MS, SLP to create a template letter that you can share with your current employer to help them start the process of removing the CCC from their employment requirements. Simply copy, paste, customize, and send to the director. You can find the letter template here.

If you are a school SLP, you might be incentivized to pay for the CCC, as you will get a certain percentage higher salary or maybe a bonus payment. This is because teachers pushed for this type of setup for teachers who go through the process of being board certified. At some point, someone probably advocated that SLPs should have the same option. Since SLPs are frequently put on the teacher pay scale, the CCC was used as an equivalent to National Board for Professional Teaching Standards, which offers National Board Certification for teachers. One could argue that perhaps neither certification actually provides any additional benefit to students, but has become a way for professionals to demand more pay, in which case, are these certifications really doing what they perhaps initially intended to do?

Rumor #4: State licensing boards require the CCC.

We did an initial review of all 50 state licensing boards and plan to do a more thorough review in the coming months. Our initial review indicates that Nevada, Virginia, and New Jersey require the CCC (in Virginia and New Jersey, this only applies if you don't work in the schools).

All other state licensing boards either don't reference the CCC, or use ambiguous language like "CCC or equivalent" or "meet the standards of the CCC." It's time for state licensing boards to update and clarify their language around certification products.

I want to emphasize why it is so dangerous for the field for state licensing boards to reference certifications as part of their standards. Certifications are ultimately products that can be changed at the whim of the people who sell them. This puts state licensing boards legally at the whim of these various for-profit and non-profit companies that sell certifications.

For example, let's say that an SLP (hypothetically) created a medical SLP certification. Let's say (hypothetically) that this SLP charged $8,000 for this certification. Let's say that this SLP marketed their certification as the gold standard for medical SLPs and lobbied licensing boards to consider requiring their certification in order to be licensed as a medical SLP. This is not a far fetched scenario given the current status of things.

It is entirely possible for state licensing boards to ensure that SLPs have adequate training from accredited university graduate programs, pass an official exam, and complete a set amount of supervised hours upon initiation of their first job. It is also possible for state licensing boards to fully regulate and monitor an appropriate amount of continuing education hours required each year (or set number of years). It is entirely possible for a state licensing board to ensure a way for consumers, employers, and colleagues to report ethical violations and to hold SLPs accountable to these violations.

It's so entirely possible in fact, that state licensing boards are already doing it.

For the few state licensing boards that reference the CCC, their language needs to be updated. This not only frees SLPs to truly be able to decide if they want to purchase the optional CCC, but it also protects state licensing boards from being at the whim of a certification product, the standards of which are entirely outside of their control.

State licensing boards are made up of SLPs, audiologists, and the general public. They usually serve some sort of term (1 year, 2 years, maybe 3 years, or some other term) and it is completely voluntary. They meet several times per year and discuss issues. You are free to bring items to the board's attention at any time. You are free to volunteer to be appointed to the board at any time. Brooke Richardson and I worked together to create a letter template you can copy, paste, edit, and send to your licensing board to start the conversation. You can find it here.

Rumor #5: I have to have the CCC to teach and/or supervise students.

Short answer: No.

Long answer:

Whew. Take a deep breath, because we're about to go down the rabbit hole.

Let's start with this: When I began posting that the CCC was optional, a lot of comments came up about state licensure and employer requirements (discussed above), but probably the most alarming comment made over and over was: "I was told in grad school that I had to have the CCC."

Let's talk about why this is such an enormous problem.

First of all, SLPs aren't required to pay for the CCC in order to be an SLP. Yes, there's some confusion right now about a small handful of state licensing boards, and yes, employers have annoying out-of-date policies that are limiting their pool of applicants, but if we're talking about just the nuts and bolts of how the system is set up, the CCC is entirely optional.

It's not ok for university faculty to be telling students that the CCC is required. This is because they are likely working in a university that has been accredited by the Council for Academic Accreditation (CAA). The CAA is the entity within ASHA that has the authority to establish and enforce a set of standards for the accreditation of graduate education programs in audiology and in speech-language pathology. The CAA has the authority to make accreditation decisions.

Therefore, it is illegal for the CAA to require graduate programs to in any way imply or directly communicate that the CCC is required, because that would 100% be a conflict of interest that is illegal.

To put it another way: Let's say that my company, Therapy Insights, decided to create a department that offered accreditation to grad schools. I would be a competitor to the CAA. Grad schools could elect to pay me to go through my process and follow my rules and receive my stamp of approval, which would be accepted by state licensing boards as an official accredited university. (This is all very hypothetical, but stay with me as I paint the picture...)

I could not, in good faith and without an illegal conflict of interest, in any way require faculty to buy my product. And I certainly could not require faculty to tell students that my product is required in order to practice as an SLP. (If it's helpful, imagine that my product is a certification, because lots of companies like to create these and sell them).

So... why is it that in order for SLPs to be qualified to purchase the optional CCC product, SLPs who are supervising students during their 400 clock hours (required by both the CAA and the CCC) need to be supervised by someone who holds the CCC?

So in effect, it's multi-level marketing. I have to pay for the product in order to sell it. Get it?

Grad schools currently operate under the assumption that all of their students will eventually want to purchase the CCC, and so they require anyone who is supervising students during those 400 "clock hours" to have their CCC.

To be clear, this is not a requirement of the CAA. You do not have to pay for the CCC if you want to supervise or teach students in a grad school program accredited by the CAA. You only have to pay for your CCC if you elect to supervise someone who knows that they eventually want to pay for the CCC, too.

Rumor #6: The CCC is the only thing regulating our profession and without it, consumers don't know who to trust.

In the United States, state licensing boards are the gold standard for regulating professions. State licensing boards require a set of stringent standards to be met by any applicant and also protect consumers by providing a way for professionals to be held accountable to reported ethics violations.

Doctors, attorneys, architects, engineers, physical therapists, occupational therapists, (and the list goes on and on) are not required to hold both a national certification and a state license. They are only required to hold a state license. State licensing boards handle all reports of ethical violations for these professions. Consumers are protected and the profession is legally regulated. State licensing boards literally make it illegal for anyone without a state license to act as a speech therapist. This is a power that ASHA (or any other company selling a certification product) will never have.

Interestingly, as I write this, I am visiting some friends in Virginia. One is a doctorate level psychologist and the other is a masters level BCBA. My psychologist friend has never been told or encouraged to pursue any kind of national psychologist certificate, and he finds all certifications to be dubious, as the actual process of providing therapy never really fits into a single mode or approach taught by a single certification product. My BCBA friend tells me that not all states have licensing boards, and so all BCBAs elect to purchase (and renew each year) a certification sold by the company who regulates their professional examination. She believes in the validity of the certification since it is currently the only way for BCBAs to be "legitimate" in the profession. Sound familiar?

(Note that ASHA doesn't run the Praxis. Educational Testing Service (ETS) does. ETS is the world's largest private nonprofit educational testing and assessment organization.)

SLP is an extraordinarily young field. We are going through the growing pains that a lot of other professions have gone through before us once licensing boards were established. We're just doing it with a national membership organization that isn't doing anything to correct any misinformation and is utilizing tactics that uphold the status quo that CCC is "required," even though it's not. Some of these tactics include confusing language around CCC requirements on their website regarding supervisors, removing the option to purchase only the ASHA membership (not the CCC + membership) from their website, and including the CCC under their "Education Requirements" section on their website when describing to consumers what SLPs must do to become an SLP.

Rumor #7: I need the CCC to become/maintain ASHA CE Provider status.

According to the ASHA Requirements for ASHA CE Provider Approval: "If the CE administrator is neither an ASHA member nor a holder of one of the ASHA Certificates of Clinical Competence (i.e., certified by ASHA), the organization must designate a CE Content Consultant who is an ASHA-certified speech-language pathologist; audiologist; speech, language, or hearing scientist; and/or ASHA member. The CE Content Consultant must be involved in all continuing education course planning, implementation, and evaluation."

So in short, to be an ASHA CE Provider, you don't have to have the CCC per se, but you do need to appoint someone who does have the CCC as a consultant, and this person must be involved in all CE course planning, implementation, and evaluation.

I am an ASHA CE Provider and plan to drop this status by the end of 2024. I currently have a series of courses that existing Therapy Insights members can take for ASHA CEUs and I can't re-neg on that promise for the next year. But the more I learn about how the CCC works, and how ASHA CEUs work (more on that in another post), the less I am willing to support this system.

In summary...

This is a lot to take in and a lot to process. It's taken me 8 years of asking questions and piecing things together to write this post. This is why I wanted to start this website. There's so much to communicate that can't fit into a social media post. I want you to be able to find the information you need in one place so that you can bookmark it and come back to it later as needed. I want to be able to write more than 2200 characters and have a conversation that's bigger than a square graphic.

Nothing is going to change overnight. I'm not calling for a complete overhaul of anything. I'm simply inviting SLPs to wake up to the fact that you have options. We live in a country that doesn't always see a problem with silencing women, and we are a field of 96% (mostly white) women who are conditioned to obey authority, be nice, don't ask questions, pay your dues, etc. Part of what is choking our field out from success is the significant lack of any kind of diversity. Diversity of color. Diversity of perspectives. Diversity of life experience. Diversity of opinions. We have a tendency to police each other, to look over our shoulder and see if we're all doing it "right." We constantly feel like imposters. We want desperately to be seen as legitimate, like we belong here. And so it makes sense that certifications have such a stronghold in our field. Certifications offer the enticing illusion of the feeling that we will for once and for all, belong.


You belong here.

This is your space.

You have a voice.

You have options.

We don't need to burn it down. We don't need to start over. We don't need to revolt. We don't need to march. All we need to do is simply use our voices and say, "No, thank you."

(Or at least know that you can consent and say, "Yes, I want this," rather than feeling like you're having to take it either way.)

Please use the contact form to reach out to me any time. I read every email and promise to respond, even if we don't agree. This conversation is so important, and I am here for it.


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