#3: Call to Action: Engage with the ASHA BOD

Ok, SLPs, it’s time to take action!

The ASHA Board of Directors (BOD) meets October 18-22, 2023. We have a chance to send in our letters before their next meeting. ASHA BOD SLP Member-At-Large, Dr. Treasyri Williams-Wood is taking our story to the board and will be a guest on our podcast the week of October 23, 2023. BOD members are provided with a copy of every single letter that is sent in via this form and will discuss the letters at this upcoming meeting.

Here is our call to action!

ACTION STEP #1: By October, 15, write a letter to the ASHA BOD.

  • Tell your story. Please don’t copy and paste what we wrote because this is an ineffective strategy. BOD members want to hear YOUR story and why YOU are passionate about this issue.
  • Be respectful. ASHA BOD member positions are 100% volunteer and are unpaid. They serve 3 year terms and the humans you’re writing to likely have nothing to do with creating the systems that we’re all so upset about. It’s possible that they agree with you, so look for common ground.
  • Include exact numbers and cite your information. Instead of saying, “I pay too much money to be an SLP.” Say: “I pay $X for my ASHA membership and CCC, I pay $X for my state license fee, I pay $X for my department of ed certification, I pay $X for my XYZ certification, and I’m paid $X/hour,” etc. Be specific. Instead of saying, “Every job I’ve had required the CCC.” Say: “I worked for X, Y, Z, L, M, N, and Q, and they required that I had the CCC to work for them.”
  • Paint a vision! What do you want to see for the future of SLP? What action would you like the board to take?
  • Focus on the common enemy: the current dysfunctional system that has backed all of us into a corner (including ASHA).

CLICK HERE: Submit your letter to the ASHA BOD online

ACTION STEP #2: Let us know you wrote the letter!

  • Email us at team@fixslp.com (no need to include the letter, just let us know you sent one!)
  • DM us on Instagram.
  • Our goal is to get to 500 letters by October 15, 2023. Let’s do it!

Please read this before writing your letter to the BOD:

Here’s a crash course in the current system that SLPs are working with. The more we know about how things work, the more we can be part of the process of changing things for the better!

ASHA is a non-profit membership organization. Currently, it is struggling under the weight of all of its other roles that were created by people at various times in the last 60 or so years. Those roles include:

  • Running the Council for Academic Accreditation (which outlines what university programs are required to do in order to ensure that new graduates are ready for entry-level positions).
  • Selling and regulating their Certificate of Clinical Competence (CCC) certification product (which is not technically required for SLPs to practice).
  • Operating the Board of Ethics, which is currently tied to both the CCC product and ASHA membership (it should just be tied to the profession itself, similar to APTA’s Code of Ethics).
  • Selling a continuing education (CE) stamp of approval and acting as both CE approver and CE provider.

The Board of Directors is currently made up of 17 members. These are voluntary positions and are unpaid. Board members donate their time to attend board meetings, read letters from association members, and try to make decisions about how ASHA is run, including policies and regulations, based on what members want.

There is a relatively new position on the board called Member-At-Large. There is 1 SLP and 1 audiologist Member-At-Large. Their role is to communicate concerns from members to the board. As of right now (October 2023), the SLP Member-At-Large is Dr. Treasyri Williams-Wood.

Any SLP or audiologist can reach out to the Member-At-Large by contacting her directly. Any member can also reach the entire board with a letter. People do this every day. Lots of people write in to ask the BOD to do more to make the requirements of being an SLP more stringent, including ensuring that the CCC is required everywhere. They have had the loudest voices so far.

For anyone who aligns with the core mission of Fix SLP, you probably agree with the conclusion that the CCC is not doing SLPs or our field any favors. And so we need to get organized and be clear about what our argument is.

Here are the basic fundamental arguments we are making. For SLPs writing a letter to the ASHA BOD, you may utilize these points as inspiration for what you write in your letter. What you write should come from you, your personal experience, and your unique perspective. Copying/pasting isn’t helpful (it starts to just become spam to the BOD), but definitely use the spirit of these points if they are something you agree with.

The CCC is redundant and unnecessary.

The CCC does not offer anything above and beyond what the Council for Academic Accreditation (CAA) and state licensing boards are already doing. It is an unnecessary and redundant cost for SLPs.

Since 2016, all 50 states and D.C. require state licenses in order to practice as a speech-language pathologist. All state licensing requirements meet or exceed the requirements of the CCC. If SLPs meet the requirements of any accredited grad school program and maintain their state license, there is no need for the CCC.

The CCC served a purpose prior to the installation of state licensing boards. It was a stop-gap solution to try to regulate the field. But the CCC will never have the legal authority that state licensing boards have. SLPs’ preference is for state licensing boards to regulate the field and for ASHA to act solely as a membership association advocating for SLPs. Removing the CCC would free up ASHA to fully engage in this advocacy role.

The CCC is a conflict of interest that limits ASHA’s ability to advocate for SLPs.

The CCC puts ASHA in an impossible bind. Because it is a product that they are selling, ASHA is not in a position to adequately address or resolve ethics complaints brought to the board that are about other companies that sell products due to anti-trust regulation.

There have been multiple times where an ASHA member / CCC-SLP who owns a company that sells products to SLPs has acted in a way that has violated the ASHA Code of Ethics, but when ASHA attempts to process any reports of ethical violations, they receive legal counsel that they cannot comment on the matter due to anti-trust rules.

By removing the CCC, ASHA would be freed up to truly advocate for SLPs and hold unethical companies accountable when they are doing damage to SLPs and doing damage to the field as a whole. ASHA would no longer be selling a product and could fully embody their role as advocate and help SLPs put a stop to unethical business tactics that are bringing our entire professional community down.

The CCC is not evidence-based.

There have been (to our knowledge) a sum total of zero studies that investigate if the standards put forth by the CCC (which are heavily influenced by the standards of the CAA) actually demonstrate that anyone who holds the CCC (or even graduates from an accredited university) is competent to address the full scope of speech-language pathology at an entry-level SLP job.

The CCC (and the CAA) has not kept up with enormous changes in the scope of the field, particularly in dysphagia. It is not actually protecting consumers or regulating the field because there is zero evidence to show that any SLP who has the CCC is able to competently do the job. For example, many SLPs aren’t trained in MBSS unless they seek out specialty courses, mentorship, or certifications, but the American College of Radiology recommends that SLPs performing and interpreting MBS studies hold the CCC. This is a dangerous recommendation for both consumers and radiologists because the CCC does not guarantee MBSS skills at all.

The CAA and state licensing boards need to establish and use evidence-based information to redesign and regulate competency standards.

The CCC limits SLPs professionally.

Due to the lobbying efforts of ASHA, the CCC is all but required to practice as an SLP. The vast majority of employers require the CCC in order to apply for a job. Outdated Medicaid provider policies reference the CCC in order to be able to bill insurance, though federal CMS regulations only require SLPs to hold a state license (not the CCC). Again, because the CCC is not evidence-based, and because it is redundant on top of CAA standards and state licensing, this forces SLPs to pay for the CCC in order to simply get a job as an SLP.

In Bogus v. ASHA in the 1970s, an SLP, Dale Bogus, attempted to bring a lawsuit against ASHA for requiring her to pay for ASHA membership in order to obtain the CCC. The district court found no evidence that Mrs. Bogus had either sought jobs requiring a CCC or been offered employment contingent upon her holding a CCC. Thus, the district court inferred that plaintiff had no professional necessity for a CCC and that her dues-paying association with ASHA was entirely voluntary. Her case was dismissed. Talk to any SLP today, 50 years later, and you will hear story after story about how they cannot get a job without a CCC, even though they have tens of thousands of dollars of student debt to get the degree and are required to pay state licensing fees in order to practice.

ASHA cannot be both a membership association and sell a certification product. They cannot use member fees to lobby their certification product to be required by insurance and/or employers. This is a direct conflict of interest.

The CCC, if it stays, needs to be a completely voluntary certification that SLPs have complete freedom of choice to elect to purchase or not.

ASHA’s online certification/membership renewal process uses illegal tactics.

ASHA recently removed the option to purchase only the ASHA membership or only the CCC product as separate products from their website. This is called “tying” and is illegal. This smacks of Bogus v. ASHA (referenced above). Tying a membership fee to a certification product, or “tying,” is illegal and is a violation of the Sherman Act. The American Osteopathic Association recently lost a class action lawsuit to its members for this sort of behavior (Talone v. American Osteopathic Association). We’re not saying that we want a class action lawsuit, but we are saying that this type of “tying” is illegal and hurts SLPs.

SLPs deserve the opportunity to choose if they want to purchase the CCC product and choose if they want to be a member of ASHA. As it stands now, between so many employers requiring the CCC, confusing and outdated insurance manuals requiring the CCC, and the confusing purchase process on ASHA’s website, SLPs currently do not have a choice and feel forced to purchase the CCC and ASHA membership whether they want it or not.

ASHA is alienating its member base by requiring the CCC.

SLPs deserve choices. About 28% of OT practitioners are members of AOTA. About 23% of PTs and PTAs are members of APTA. Approximately 100% of SLPs are members of ASHA, and 98.7% of those members pay for the CCC (ASHA 2022 Member and Affiliate Profile report). This is extremely odd and highlights the fact that SLPs feel that they have no choice but to participate in the optional CCC and the optional ASHA membership in order to have any chance at a career in speech-language pathology.

ASHA would be a stronger national association with more buy-in from members if they didn’t feel coerced to join.

The CCC is unethically tied to supervision requirements.

Many of the requirements of the CCC match the requirements of the CAA, which makes sense since both entities are run by ASHA.

However, because the CCC is a product that ASHA is selling, it becomes a complicated web of conflicts of interest when grad school supervisors are required to hold the CCC if and only if that student eventually wants to apply for and pay for the CCC. What other certification products in our field have the kind of power that they can dictate that faculty must pay for their product in case the student eventually wants to pay for their product as well?

The CCC needs to go away and the time, money, and energy spent trying to regulate a certification product should instead go to researching and establishing evidence-based practices that the CAA can require for grad school programs. This will ensure that SLPs who are entering the field actually have the knowledge, skills, and lifelong learning mindset to truly be competent enough for entry-level jobs, and grow and flourish to be valuable members of clinical spaces.

Our calls to action:

  • Remove the CCC from the profession, while maintaining CAA and state licensing and/or interstate compact safeguards.
  • Alleviate ASHA of its role of selling certification products, freeing up the association to effectively do its job of advocacy and ethics regulation, which is what SLPs want in a membership association.
  • The CAA and licensing boards need to establish and use evidence-based information to design and regulate SLP competency standards.

We believe that things can change and that ASHA is in a position to evolve to free itself from the many conflicts of interest that have been woven over the last 60 years. We are here to have the conversations with ASHA to help achieve this.

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