Dear Mr. Ferguson
Thank you for the opportunity for public comment regarding the rules and regulations of the Board of Hearing Aid Specialists. I am writing to you today to call for the immediate removal of the Hearing Aid Specialist Examination requirement for Virginia licensed Audiologists as a part of the application for the Virginia Hearing Aid Specialist license.
I recognize that the Board of Hearing Aid Specialists' primary goal is to maintain the health, safety, and welfare of the public, and I commend that effort. I do however find it very troubling (and confusing) that the board believes that requiring licensed Audiologists to take part in a written and practical examination, despite a doctoral level education in the field of Audiology, is the best, and most practical way to ensure the health, safety, and welfare of the public.
As a rational person I would think that four years of graduate level education, requiring the completion of 100 credit hours (and at Virginia's only school for Audiology, James Madison University, the completion of a dissertation) would be sufficient reason for exemption from the examination requirement for hearing aid dispensing licensure. What better training is there for hearing aid dispensing? Medial school? According to current state legislation physicians that are licensed in Virginia, who are at a minimum eligible for certification by the American Board of Otolaryngology, are exempt from the examination when applying for a license. I do not see why this exemption cannot apply to Audiologists licensed in the state of Virginia.
To question the education deemed adequate for accreditation of an Audiology program by a national organization, the Council for Academic Accreditation, seems wrong given the strict requirements for accreditation (see http://www.asha.org/uploadedFiles/academic/accreditation/AccreditationStds0307.pdf#search=%22audiology%22 for specific requirements). If students are learning from licensed Audiologists in an accredited program, and graduate from that program with an advanced degree in Audiology, why is that not sufficient to prove competency in Hearing Aid dispensing? Additionally, the curriculum of programs is frequently based on resources set forth by the professional associations, such as ASHA. The Guidelines for Graduate Education in Amplification set forth by ASHA go above and beyond the requirements set forth by the Board of Hearing Aid Specialists, therefore students should be well prepared for the selection, fitting, and dispensing of hearing aids. ~If anything I would suggest a requirement that students apply for a temporary permit of some sort under their state licensed supervisor~
To require licensed Audiologists, that graduated from an accredited program in Audiology, to take a time consuming, and outdated examination is a waste of recourses for all those involved. For this reason I propose the removal of the examination requirement for licensed Audiologists when applying for a license to be a Hearing Aid Specialist in Virginia.
Thank you for your time, and serious consideration of this, and other proposals.
Thoughtfully,
Justine Angilletta
3rd year AuD Student
James Madison University