Ms. Knachel and Members of the Virginia Board of Audiology and Speech Language Pathology,

My name is Debra Flechner Ogilvie and I have been a licensed Audiologist in the Commonwealth of Virginia for 20 years.  I have worked mostly in private practices, most recently as a joint Owner in Richmond Hearing Doctors, PLLC.  I am commenting on the Emergency Regulation regarding performance of cerumen management by audiologists [18 VAC 30 - 20].

As many have already stated on this forum, I also believe this regulation is too restrictive and limiting for professional, licensed Audiologists – many of which have already have a Doctoral degree.  The national organizations that regulate the field of Audiology already have cerumen management listed within the scope of practice for Audiologists (http://www.asha.org/policy/sp2004-00192.htm, http://www.audiology.org/publications-resources/document-library/scope-practice, and http://www.audiologist.org/scope-of-practice) and these new regulations limit our practice rather than expand it, it was hoped to do.  “Limited” cerumen management is unnecessary since Audiologists are trained and knowledgeable about the entire outer ear canal where cerumen can develop and needs to be managed.  We are all in agreement that cerumen management is an advanced procedure and this needs to be fully within the scope of practice of an Audiologist – especially a Doctor of Audiology – without limitation on a portion of the ear canal that has no clinical basis.

This list of contraindications listed in Proposed Section 241 Subsection C is the most limiting aspect of the Regulations.  As a well-trained Audiologist (and anyone else going through the continued training as outlined in subsection B), I would know who and when to refer to an Otolaryngologist. Our Audiology License and Codes of Ethics already prevent us from performing procedures from which we are competent, appropriately trained, and/or comfortable performing on a patient and/or which could cause harm to the patient. In the past, physicians have already been referring to Audiologists because they know and trust us as competent professionals to remove cerumen, and refer appropriately. Patients have frequently commented that they prefer coming to Audiologists for the comfort and

Subsection D: Audiologists are doing many other procedures that do not require written consent so why would this? If there is going to a signed consent, it should also include an informed consent waiver for any of the contraindications that may unfortunately stay within the regulation.

While I have many reservations about this Emergency Regulation, I appreciate the work the Board has done on behalf of Audiologists and the citizens of Virginia.