Comments with regard to BOARD OF AUDIOLOGY AND SPEECH-LANGUAGE PATHOLOGY Emergency Cerumen Management Regulations:

18VAC30-20-241.A.2 Please consider adding the following text to this section:

“Completion of clinical practicum and fellowship requirements for an MA/MS (masters level) program in audiology approved by the American Speech-Language-Hearing Association shall be accepted as fulfillment of this course requirement.”

18VAC30-20-241.B Please consider adding the following text to this section:

“A University transcript showing completion of a doctoral or masters level program in audiology shall be accepted as documentation evidencing satisfactory completion of training in cerumen management.”

An optional, and very practical approach to satisfying this requirement, would be to have a letter from a physician that certifies the audiologist in terms of his or her ability to perform all that is required for safe and effective cerumen management.

18VAC30-20-241.C Comments

Some of the pre-existing contraindications listed in this section impose an unacceptable burden on patients who are home bound or who have significant mobility restrictions. I work alongside Riverside PACE and Riverside House Calls Practice to serve patients who have multiple health problems and who often have restricted mobility. Physicians from these organizations call on me to remove cerumen for people with some of the contraindications on this list. I would be able to serve nearly all of the patients referred to me for cerumen management if you eliminate the following contraindications:

 Diabetes

Stenosis or bony exostosis

 Impaction that totally occludes the ear

Inability to see at least 25% of the tympanic membrane

Cerumen management can be performed by audiologists in a safe and effective manner for patients with these conditions. I have been doing this on the Virginia peninsula for 12 years. My referrals to otolaryngologists are typically for deep-seated cerumen and dead skin occlusions that are not responsive to irrigation.

Thank you for the opportunity to provide comments on these emergency regulations.