Dear Ms. Knachal and Virginia Board of Audiology and Speech Pathology Board Members,

We are writing, on behalf of the Academy of Doctors of Audiology (ADA), its Board and its membership, to comment on the Virginia Emergency Regulations as they pertain to Cerumen Management by audiologists.

While we commend you and your Board on the creation of much needed cerumen removal language, we believe that the proposed language is unnecessarily restrictive, poses a substantive barrier to care for Virginians and will result in other negative unintended consequences. 

ADA suggests broader language, similar to what is contained in its Scope of Practice statement (http://www.audiologist.org/scope-of-practice), which closely resembles the vast majority of licensure laws.  Since most state licensure laws contain language prohibiting licensees from performing any service or procedure for which they are not trained or competent and language prohibiting them from performing any action which could harm to patient, we feel that your current emergency language is overly restrictive and could cause more patient harm (reduced access, reduced affordability, injury by untrained personnel) with less benefit than more broadly written regulation. 

There are many such examples of more broadly written language available at http://www.asha.org/Advocacy/state/State-Cerumen-Management-Requirements/. We strongly encourage you to consider modifying your language to be more consistent with audiology’s current educational status and curriculum, the draft scope of practice language available from all of the national audiology associations, and the language that currently exists in the majority of the other states who address this in the United States.

Thank you for the opportunity to comment and for your consideration of our remarks.  Please feel free to contact our Executive Director, Stephanie Czuhajewski at sczuhajewski@audiologist.org with any additional questions or concerns.

Regards,

The Board and Staff of the Academy of Doctors of Audiology

Kim Cavitt, AuD, ADA President

Rita Chaiken, AuD, ADA President-Elect

Brian Urban, AuD, ADA Past-President

Angela Morris, AuD, Treasurer

Tom Goyne, AuD, Member at Large

Ram Nileshwar, AuD, Member at Large

Paula Schwartz, AuD, Member at Large

Alicia Spoor, AuD, Member at Large

Stephanie Czuhajewski, CAE, Executive Director