My name is Kim Fisher and I am an owner of Richmond Hearing Doctors, PLLC.  I have been a licensed audiologist in Virginia since 2000 and have practiced audiology at VCU Health System and in private practice.  I primarily work with hearing aid patients and come across cerumen on a daily basis.  In order to provide effective and efficient hearing health care, it is necessary to provide cerumen management.  Audiologists are highly trained and skilled practitioners who can safely remove cerumen or identify when a referral to a physician is warranted.  The emergency  regulations are excessively restrictive and will result in unnecessary, multiple office visits for patients, not to mention a delay in care when they are seeking out a simple hearing evaluation and/or hearing aid maintenance.

Like many of my colleagues have already stated, I am frustrated with the limitations put on audiolgists in the Commonwealth.  I travel to retirement communities to provide convenient hearing health care to patients who are unable to easily leave their facility for appointments and the majority of these patients have contraindications listed on the emergency regulations.  It certainly isn't uncommon for me to see patients with diabetes, no hearing in one ear or find less than 25% of the tympanic membrane visible.  Instead of safely and effectively removing the cerumen myself, arrangements must be made to transport the patient to a physician who may or may not provide cerumen management or may not have the proper tools to effectively remove cerumen.  It is not only unrealistic to transport all of these patients to an otolaryngologist's office, it certainly is not cost-effective.

As an audiolgist, I spend my day in the ear canal taking deep impressions, inserting and removing the Lyric (an extended wear device) and performing immittance measurements to determine the status of middle ear and tympanic membrane function.  It doesn't make sense to restrict my ability to remove cerumen from only the outer 1/3 of the canal when I need access to the entire ear canal to perform other procedures.  It is unnecessary to list any contraindications that prevent me from using my training to identify when a referral is warranted.

I urge you to revise the regulations as soon as possible.  Thank you for your time and consideration.

Kim Fisher, M.A., FAAA