My name is Paul D. Kuster, Au.D. I have been a practicing audiologist since 1996 and have been a Doctoral level audiologist since 2004. I have been a member of ASHA and AAA and continually licensed first in West Virginia and now in the Commonwealth of Virginia for all of that time. For my entire career, cerumen management has been a daily reality and stated privilege under the Scope of Practice of both of my credentialing organizations. My specialty and the focus of my career and business is the dispensing of hearing aids. I cannot conceive any way that I could practice without the ability to freely access the ear canal, and using my nearly two decades of experience and clinical, professional judgment, manage my patient’s cerumen - in my own office, at the moment they are there with me, to the limits of my ability to do so, and, if in my professional judgment, refer to medical specialist’s conditions that require medical intervention. To have mandated referral to other healthcare professionals for simple and common conditions is in no way efficient patient care, nor in anyone's best interest. I have to date written many missives and have had lengthy conversations with regional and nationally recognized leaders in the field of Audiology regarding the proposed regulations, and every one of them has found the language to be unnecessarily restrictive. I have been unable to find any evidence that audiologists are harming patients through negligent practice. My professional liability insurance is cheaper than the professional dues required to keep my affiliations, a sure sign that we as a profession are being careful to do no harm. The comment board is replete with the information needed for the Board to make its decision. I have been working closely with Dr. Leah Ball, a longtime acquaintance and similarly situated colleague and so will not go on and list all of my issues. I will simply state that I am in complete agreement with Dr. Ball’s recommendations, to wit: Amend or revise the emergency regulations as soon as possible, amend the definition of “limited cerumen management”, and delete the list of preexisting contraindications. I am comfortable that I can manage cerumen in a safe and professional manner and am certain that I can recognize both my limitations and any pathology that would endanger my patients’ health. I appreciate the respect and diligence of the Board members in addressing my concerns.

Paul D. Kuster, Au.D.

Doctor of Audiology

CCC-A, F-AAA