ASHA Opposes Utah Plan to Replace Licensure With Certification

October 29, 2025

Utah's Office of Professional Licensure Review (OPLR) has recommended downgrading the regulation of audiologists, speech-language pathologists (SLPs), and hearing instrument specialists from state licensure to "mandatory certification." This recommendation was sent to the Utah Legislature's Business and Labor Interim Committee and represents the first step toward legislation that could permanently weaken professional oversight and patient protections.

As of October 29, 2025, a bill has not yet been introduced.

ASHA strongly opposes this proposed change. Our primary concern is that it would undermine Utah's current safeguards, compromise professional standards, and-most critically-put patient safety at risk.

Key Concerns With the Proposal

On October 8, 2025, ASHA submitted written testimony [PDF] to Utah policymakers outlining several major concerns.

Replacing Licensure With Certification

Audiologists and SLPs are highly trained health care professionals-doctoral-level for audiologists and master's-level for SLPs-whose work involves complex, high-risk patient care, including surgical monitoring, cochlear implant programming, swallowing disorder intervention, and ventilator/airway management. ASHA maintains that licensure, not certification, is the most effective regulatory framework for managing these risks.

Weakening Continuing Education and Oversight

While professional certifications like ASHA's Certificate of Clinical Competence (CCC) recognize an individual's qualifications and competence, state credentialing for practice through certification-as proposed in Utah-would remove key licensure safeguards, including consistent oversight, renewal, and continuing education requirements. The OPLR proposal-which allows up to 500 hours of annual practice without additional competency verification-falls short of protecting consumers. Continuing education ensures that practitioners stay current with evolving research, technology, and patient care standards.

Eliminating Professional Board Oversight

The proposal would abolish the Utah Speech-Language Pathology and Audiology Board, replacing it with ad hoc technical consultation. Without a formal board, there would be no consistent oversight or mechanism to ensure accountability and consumer protection.

Impacting Access and Reimbursement

Many payers, including Medicaid and private insurers, rely on licensure as the credentialing standard. Shifting from licensure to certification could create uncertainty about provider eligibility and reimbursement, potentially disrupting access to services-especially in rural or underserved areas. Additionally, changing from licensure to mandatory certification could create confusion among consumers, practitioners, and interstate mobility frameworks.

In light of these concerns, ASHA urges the OPLR and Utah legislature to maintain the current licensure model for audiologists and SLPs to safeguard public health, continuity of care, and the integrity of these professions.

ASHA's Advocacy and Member Engagement

ASHA has been intensely engaged on this issue since August, working closely with Utah's audiologists, SLPs, and the Utah Speech-Language Hearing Association to coordinate a unified grassroots advocacy effort.

• Over 1,100 members in Utah have already taken action through ASHA's grassroots campaign.
• At this month's interim committee hearing, audiologists, SLPs, and hearing instrument specialists voiced strong opposition to the proposal.
• While virtual attendees, including ASHA staff, were not given the opportunity to provide oral testimony, ASHA submitted written testimony [PDF] opposing the changes.
• ASHA continues to meet with stakeholders-including other national organizations-to present a unified front and ensure coordinated advocacy moving forward.

Why This Matters

Licensure is not just an administrative formality; it ensures that the professionals treating hearing, communication, and swallowing disorders meet established standards of education, training, and ethics. Without licensure, Utah risks reduced consumer protection, confusion for patients and payers, and potential loss of insurance reimbursement for providers. If Utah eliminates licensure, other states could follow, threatening the quality of care, patient safety, and professional integrity nationwide.

ASHA is committed to vigorously advocating against any effort that diminishes professional regulation or the quality of care for the public.

Questions?

Please email [email protected].