TL;DR Fix SLP 2023

Want to get caught up with everything that has happened since we launched in September 2023? You've come to the right place!

A Conversation Ripe for the Having

The Fix SLP platform was launched by Megan Berg, MA, SLP and Jeanette Benigas, PhD, SLP on September 25, 2023. As of today, the last day of 2023, Fix SLP has attracted over 10,200 followers on Instagram and over 3,800 followers on Facebook for a combined following of approximately 14,000 SLPs. It is clear that SLPs are ready to have this conversation.

The CCC: Our First Topic

We have selected the CCC as our first topic because it represents a systemic problem in our field. We believe that SLPs have externalized their power to a national association that is behaving more like a regulatory body and less like an optional membership association that is working to advocate for its members. Because of this externalization of power, many of the most pressing issues in our field remain completely unaddressed. We believe that all of the problems in our field are completely solvable, but only if and when SLPs see that we ourselves have the capacity to address these problems when we unite together, particularly at the local level. It's at this level where legislation can be passed to address workloads, training requirements, caseload caps, pay transparency, and more.

We don't have time to wait on a national association to fix things for us. They have stated over and over that they don't really have the power or capacity to influence issues at the state level anyway. So we are here to fix SLP ourselves.

Here are the main issues that we see with the CCC:

• ASHA does not differentiate revenue based on membership dues ($26/year) and CCC fees ($199/year). ASHA does publicize that "Standards and Ethics" (including the work of regulating the CCC) consumes about 8% of their budget. This math doesn't calculate. If ASHA wants to charge $225/year for both membership and certification, and certification only costs 8% of their budget, then $225 x 8% = $18. Why is ASHA artificially deflating the cost of the membership (which according to their public budget analysis, consumes the bulk of their revenue) and artificially inflating the cost of their certification?
• The CCC is an ineffective method of regulation. The CCC was first established to try to regulate the field, but in reality, because ASHA has no legal authority to criminalize those who attempt to impersonate an SLP without proper credentials, the CCC is an ineffective method of regulation. This is why Florida (through its state association, FLASHA) worked to push legislation in 1969 that would establish a state licensing board. State licensing boards have the power to shut down businesses and criminalize people practicing without a license, including fines, imprisonment, or both. Unfortunately, it wasn't until 2016 that Colorado was the last state to establish a licensing board. Because it took so long, the CCC was used in lieu of a state license for many Medicaid programs.
• For people who say that we need both a certification and a license, we say no. The standards of the CCC are redundant to the standards of the CAA. The degree should be enough to prepare an SLP for an entry-level job. If anything, the CCC is a one-time training milestone that indicates that an SLP has completed a grad school degree, passed a national exam, and completed 9 months of supervised work. Our question is: Why do SLPs need to be taxed $199/year to continue to prove that they accomplished these training milestones? How is paying $199/year and completing 10 hours of professional development ensuring competency across the full scope of SLP year after year?
• The CCC falsely promises competency across the entire scope of SLP as long as the person has $199 in the bank every year to give to ASHA. An SLP can spend 10 years in a skilled nursing facility and then get a job doing home-based early intervention without anyone ensuring that they have the proper training or supervision. Likewise, an SLP could take 20 years off from actively working as an SLP and as long as they pay $199/year and complete 10 hours of professional development/year, they can re-enter the field with zero confirmation that their competency is still intact. Paying money ≠ competency. The CCC is, in our opinion, doing damage to the field of SLP and is not protecting consumers from incompetency. As the field has tremendously expanded in scope over the last 50 years, the CAA has not kept up. SLPs are saying over and over: "I was not prepared to do my job." And while yes, there's some truth to the fact that a grad school program is only a foundation of knowledge, there is also some truth to the fact that the foundational education as defined by the CAA is no longer effective at preparing SLPs for the current scope of the practice.
• ASHA spends dues on actively lobbying regulatory bodies to require their "optional" CCC, thus rendering the CCC anything but optional. View their long list of certification lobbying efforts here.
• The CCC is falsely advertised as required in most grad school programs. ASHA has a monopoly on grad school accreditation since their Council on Academic Accreditation (CAA) is currently the only program available to accredit masters level SLP training programs. (Note that the CAA has nothing to do with accrediting undergrad CSD, SLPD, or PhD programs). Therefore, many of the standards of the CCC are redundant/parallel to the standards of the CAA. Additionally, because ASHA is so heavily involved in university programming and has the power to completely shut down training programs, there is a pervasive culture of promoting the CCC product among CAA-accredited universities- to the extent that most SLPs perceive the CCC as required in order to practice (it's not).
• ASHA omits options and information from their renewal checkout page. ASHA does not separate the membership fee from the CCC fee on their renewal webpage. This makes it look like they are one and the same thing and there is no information clearly and readily available informing SLPs that they have the option to become certified non-members at any point in their affiliation with ASHA. ASHA has a history of being sued for tying membership to certification. While they no longer require membership in order to purchase the CCC, they do require the CCC in order to purchase membership.
• The CCC is perceived to be required in order to supervise when in reality it is not. The only reason that someone would need the CCC to supervise is if the student they are supervising eventually wants to pay for the CCC in the future. Nowhere in the CAA guidelines does it say that graduate supervisors need to hold the CCC. University programs need to start informing students that in order to capture enough clinical supervisors for placements, they are unable to secure SLPs who all are willing to pay for the CCC just so they can perform unpaid supervision labor. Students then can make the choice if they're ok with being supervised by a licensed SLP (rather than a CCC-SLP).

You Should... Talk to ASHA, Volunteer for ASHA, Talk to the Member at Large, etc

We would love nothing more than to talk to ASHA. While the ASHA board of directors member at large was initially open to discussing this topic, she has since opted to disengage from the conversation. Over 140 SLPs wrote letters to the ASHA board of directors via their In Touch form before their October 2023 meeting. What was their response? Here it is verbatim from their meeting minutes: "InTouch Forms and member feedback are summarized monthly and reviewed with the BOD at Audiology and Speech-Language Pathology Subcommittee meetings and at each BOD meeting. InTouch Forms received from members since the last BOD meeting, along with a cumulative summary of the messages, were shared prior to the meeting. ASHA Chief Staff Officer for Communications Selena A. Ramkeesoon answered BOD members’ questions regarding topics covered in the InTouch forms. Emerging issues and trends that require consideration by the BOD or select Committees, Boards, or Councils were also reviewed." Since these meetings are not public and we as members do not have access to any transcripts or any more transparent information about what exactly was discussed, we have no idea what ASHA's response is to our concerns.

We personally have made the choice to not volunteer for ASHA as the practices, policies, and perspectives of the organization do not align with our values. However, we are not anti-ASHA. ASHA can continue to operate. We are against any national association using member dues to lobby that their certification product be required to practice, then conflating membership with certification, and then boasting about their amazing "voluntary" association membership retention rates.

A Comparison with AOTA and APTA

Membership rate of the American Physical Therapy Association (APTA): Approximately 23% of physical therapy practitioners choose to be a member of APTA. APTA does not sell a certification product. They do not use member funds to lobby that association with their organization be required by any regulatory body.

Membership rate of the American Occupational Therapy Association (AOTA): Approximately 28% of occupational therapy practitioners choose to be a member of AOTA. AOTA does not sell a certification product. They do not use member funds to lobby that association with their organization be required by any regulatory body.

How does the membership rate of ASHA compare? The U.S. Bureau of Labor Statistics reports that as of May 2022, there were 162,760 SLPs practicing in the U.S. The ASHA 2022 Member Profile reports that ASHA represents 199,942 SLPs (98.7% pay for the CCC). These numbers indicate that there are more people paying for the ASHA CCC than there are practicing SLPs in the United States. While we cannot state that ASHA boasts a membership of 100%, we can ascertain that it is very close to this number.

Ok... so can I drop the CCC?

We get this question a lot. It's a simple question that deserves a simple answer. Unfortunately, because of the way that ASHA has used member dues to lobby to make their certification required, it's more complicated than that. Here we will do our best to outline your options. If you have questions, please use the contact form to ask. You can also reach ASHA with questions you have.

1. First of all, NO. THE CCC IS NOT REQUIRED FOR MEDICARE. Medicare is federally legislated and only requires a state license. View the law here.
2. Do you bill Medicaid AND live in... Idaho, Nevada, Nebraska, Kansas, New Mexico, Minnesota, West Virginia, Kentucky, Michigan, North Carolina, or Washington DC? The CCC is required by state legislation to bill Medicaid in these states. Want to get it changed? Join our Pumble community (link under Quick Links- we have to refresh the link often, so it's best to find it there!) to meet other SLPs in your state who are working to make it happen!
3. Do you live in Nevada? If so, you have to have the CCC to get a state license.
4. Do you live in Virginia? Do you NOT work in the schools? Then you have to have the CCC to get a state license. If you work in the schools, you don't need the CCC.
5. Do you supervise students? Are those students 100% sure that they want to pay for the CCC someday? Then yes, you need the CCC. If your students don't want the CCC, then you're fine.
6. Do you want to volunteer for ASHA? Volunteering your precious time and energy on their committees likely means you'll need to pay for their certification.
7. Does your employer require it? If so, why? Are they open to a conversation? Explain to them that this is a voluntary certification and you do not have the funds to pay for it. Ask them if they are willing to cover the cost if they are requiring it. Need some good talking points or prefer to write a letter? Check out our form letter here- copy/paste it, edit it, and share! Does your employer still have questions? Have them email us!
8. Are you going to be moving to any of the states listed in #1 or #2 soon? Then best not to drop the CCC yet.
9. Are you likely going to be needing to find a new job soon? We recommend keeping the CCC until this all gets more untangled.
10. Are you a new grad? We recommend completing the CFY and paying for the CCC. You then have 5 years before your Praxis score expires. If you end up dropping the CCC during years 2, 3, or 4, then you can reinstate with a fee and use your original Praxis score to do so.
11. What if I drop the CCC and unexpectedly need it again later? You need to pay a fee, show a Praxis score valid from the last 5 years, and show evidence of 10 hours of professional development/year from the last three years. You do not need to backpay for unpaid years, go back to grad school, or anything like that.

Ultimately, it's a personal decision of whether or not to continue paying for the CCC. But we are here to argue just that: That it should be a PERSONAL CHOICE, not a coercive tactic to keep an "optional" membership association's budget intact without having to do the work to earn the trust and respect of their members by acting with accountability, integrity, and transparency.

And to anyone at ASHA reading this, we maintain an open invitation to talk with us on our podcast at any time.

Cheers to 2024, everyone!

-Megan and Jeanette