February 23, 2015

Dear Ms. Knachel:

The American Speech-Language-Hearing Association (ASHA) is the national professional, scientific, and credentialing association for more than 173,000 members and affiliates who are audiologists; speech-language pathologists; speech, language, and hearing scientists; audiology and speech-language pathology support personnel; and students. Over 3,880 members reside in Virginia.

On behalf of ASHA’s members, I am writing to provide comment on the proposed audiology rules and regulations governing cerumen management. As the leading national organization for the certification and advancement of audiologists and speech-language pathologists (SLPs), we have significant concerns regarding the limitation of audiologists to complete cerumen management.

Cerumen management results in the removal of debris from the external auditory canal to facilitate the performance of other audiologic procedures and/or to improve hearing sensitivity. Audiologists are the leading providers of hearing management and are working within their scope of practice to perform cerumen management without limitations.

ASHA has policy documents and related references in regard to external auditory canal examination and cerumen management. These references include a document describing ASHA’s Scope of Practice Clinical Practice Algorithms and Statements. These service delivery guidelines can be accessed on ASHA’s website at www.asha.org/policy/g11999-00013.htm, www.asha.org/policy, and www.asha.org/policy/sp2004-00192.htm.

ASHA’s preferred practice patterns include external auditory canal examination and cerumen management. An external auditory canal examination should be performed on all patients in preparation for other audiologic procedures with cerumen removal to be performed by mechanical removal, irrigation or suction, and appropriate referrals made for further management as required.

ASHA has been receiving comments and concerns from its members in the Commonwealth of Virginia regarding the proposed rules and regulations limiting the practice of cerumen management for audiologists who are already highly qualified to provide cerumen management services in Virginia.

We sincerely appreciate the Board’s efforts to make cerumen management services safe for the consumer. However, decreasing the scope of practice for audiologists eliminates key skills that are the cornerstone of the profession and puts patients at risk for receiving services from less qualified providers. Audiologists, acting within their scope of practice, should be able to use their professional judgment to determine when an additional referral is appropriate and when procedures should or should not be performed.

We ask that you eliminate limitations and allow licensed audiologist to treat and make referrals for cerumen management, when appropriate.

Thank you for the opportunity to provide comments. Should you have any questions, please contact Cheris Frailey, ASHA’s director of state education and legislative advocacy, at cfrailey@asha.org, or Janet Deppe, ASHA’s director of state advocacy, at jdeppe@asha.org.

Sincerely,

Judith L. Page, PhD, CCC-SLP

2015 ASHA President