FEBRUARY 16,2015

DEAR MS. KNACHAL AND MEMBERS OF THE VIRGINIABOARD OF AUDIOLOGYT AND SPEECH PATHOLOGY:

MY NAME IS JEFFREY POWELL AND I AM THE FOUNDER AND SENIOR PARTNER OF EASTERN VA EAR,NOSE AND THROAT SPECIALISTS. I HAVE BEEN IN TIDEWATER,VA FOR 31 YRS. WE HAVE 8 PROVIDERS, 5 AUDIOLOGISTS AND A CLINICAL AND CLERICAL STAFF OF 80 IN 3  OFFICES IN THE TIDEWATER AREA OF SOUJTHEASTERN VA.  THE PURPOSE OF THIS LETTER IS MY DEEP CONCERN OVER  THE POTENTIAL CHANGE IN CM FOR AUDIOLOGISTS IN THE STATE OF VA. ALL OF OUR AUDIOLOGISTS ARE DOCTORAL LEVEL EXCEPT FOR OUR MOST RECENT HIRE. THEY ARE ALL HIGHLY COMPETENT IS ALL PHASES OF CLINICAL AUDIOLOGY, ESPECIALLY CM. I DO A LOT OF COMPLEX CHRONIC EAR SURGERY,AS DO MY PARTNERS AND WE RELY HEAVILY ON THE CLINICAL EXPERTISE OF OUR AUDIOLOGISTS. THEY ARE ALL HIGHLY SKILLED IN CM,FOREIGN BODY REMOVAL,EAC CLEANING ETC. THERE IS A VERY CLOSE 1:1 RELATIONSHIP BETWEEN THE MDS' AND THE AUDIOLOGISTS. 

AFTER REVIEWING THE DOCUMENTS FROM YOUR WEBSITE, I STRONGLY FEEL THAT ANY LEGAL LIMITATION PLACED ON AUDIOLOGISTS FOR CM WILL DO SIGNIFICANT HARM AND CONFUSION TO  ANY SMOOTH WORKING CLIN ICAL SETTING IN ANY OFFICE/CLINIC/HOSPITAL. THOSE OTOLARYNGOLOGISTS WHO EMPLOY THEIR OWN AUDIOLOGISTS HAVE, FOR  THE VAST MAJORITY OF PRACTIONERS, AN EXCELLENT EDUCATIONAL PROCESS AND  CLINICAL WORK SETTING THAT WILL INSURE PROPER AND APPROPRIATE CM.  I FEEL THAT THIS NEW LAW WILL SEVERELY COMPRIMISE AND CONFUSE AN ALREADY OUTSTANDING AND ESTABLISHED CLINICAL WORKING RELATIONSHIP. ONE MUST REALIZE THE THE MD WOULD DO NOTHING TO JEPORDIZE HIS/HER PATIENT AND HIS TRUSTED AUDIOLOGIST. IT IS A TEAM CONCEPT THAT HAS WORKED FOR DECADES AND IS "NOT" IN NEED OF ANY CHANGE. I COULD ALSO GET INTO THE MEDICAL-LEGAL ISSUES BUT SUFFICE IT TO SAY FROM ONE WHO DOES A LOT OF INSURANCE CLAIM REVIEWS AND LEGAL CASE  ANALYSES, I CAN SAY WITH A REASONABLE DEGREE OF MEDICAL CERTAINTY THAT THE CURRENT STATUS OF CM WITH AUDIOLOGISTS SEEMS QUITE REASONABLE AND SENSIBLE.  I REALIZE I CAN ONLY SPEAK FOR MY STATE OF VA. (PAST PRESIDENT OF THE VA SOC OF OTO/H&N SURGERY AND OF THE TIDEWATER OTOLARYNGOLOGY& OPTHALMOLOGY SOC.). 

I SINCERELY HOPE THAT YOU AND THE BOARD MEMBERS FIND MY COMMENTS USEFUL AND HELPFUL. WE ARE VERY COMMITTED AND DEVOTED TO OUR AUDIOLOGISTS AND THE MANY FACETS OF OUR CLINICAL PRACTICE THAT THEY ARE SO VITAL FOR (ADVANCED CHRONIC EAR SURGERY, STAPEDECTOMY, HEARING AID ANALYSIS AND FITTING, AUDITORY INTEGRATION DISORDERS, NEWBORN ABR SCREENINGS, PUBLIC SERVICE LECTURES FOR YOUNG AND OLD ALIKE, COMPLEX MEDICAL-LEGAL CASES, NOISE-INDUCED HEARING LOSS AND TINNITUS...ANALYSIS AND IF NEEDED PARTICIPATION IN THE LEGAL ARENA WITH THE OTOLARYNGOLOGIST.

LASTLY, IF YOU LOOK AT ALL THE CLINICAL PEOPLE WHO ARE INVOLVED IN CM, (ESPECIALLY NON-ENT PERSONEL), AUDIOLOGISTS FAR AND AWAY ARE NEAR THE TOP OF COMPETENT AND COMPASSIONATE PROVIDERS. I STRONGLY SUPPORT ALL AUDIOLOGISTS NATIONWIDE AND IF I CAN BE OF ANY ASSISTANCE IN THIS MATTER I WOULD MORE THAT HAPPY TO HELP OUT.

RESPECTFULLY SUBMITTED:

JEFFRFEY P. POWELL,MD,DDS,FACS.

CLINICAL ASSOCIATE PROFESSOR DEPT OF OTOLARYNGOLOGY/HEAD & NECK SURGERY and  FAMILY MEDICINE

EASTERN VIRGINIA MEDICAL SCHOOL, NORFOLK,VA.  (757) 547-9714