Virginia Regulatory Town Hall View Comments

Department of Professional and Occupational Regulation

Board for Hearing Aid Specialists and Opticians

Hearing Aid Specialists Regulations [18 VAC 80 ‑ 20]

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10/12/11 4:12 pm

Commenter: Danny W. Gnewikow, Ph.D., Audiologist - Audiology Hearing Aid Associates

Periodic Review of regulations for Board of Hearing Aid Specialists

AUDIOLOGY HEARING AID ASSOCIATES

Danny W. Gnewikow, Ph.D., Audiologist, CCC

743 MAIN STREET ? P O BOX 1478 ? DANVILLE VA 24543-1478 ? PHONE : (434) 799-6288

2095 LANGHORNE ROAD, SUITE A?LYNCHBURG VA 24501-1403?PHONE: (434) 528-4245

October 12, 2011

William H. Ferguson, II, Executive Director

Commonwealth of Virginia

Virginia Board for Hearing Aid Specialists

Department of Professional and Occupational Regulation

9960 Mayland Drive, Suite 400

Richmond, VA 23233

Subject: Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20, and public participation guidelines, 18 VAC 80-11.

Public Comment: Remove the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist’s license because:

i) The examination requirement for licensed audiologists does not provide further protection of public health, safety, or welfare.

ii) The hearing aid examination requirement for licensed audiologists imposes a negative economic impact on small business owners of audiology practices.

Dear Mr. Ferguson:

The examination requirement for initial licensure of audiologists by the Virginia Hearing Aid Specialist Board becomes more archaic and redundant with each passing year in light of the expertise already required by current university audiology programs.

(i) The hearing aid specialist examination requirement for licensed audiologists does not provide further protection of public health, safety, or welfare.

In 1974, having just received my Ph.D. in audiology from Vanderbilt University, I moved to Virginia and established a private audiology practice in Danville VA (and later in 1980 a second practice in Lynchburg). I have been licensed in Virginia as both an audiologist since 1974 and as a hearing aid specialist since 1976. During my 37 years of practice, I have been the preceptor for 13 audiologists from 11 different universities throughout the U.S. as these audiologists completed their CFY or doctoral externship and subsequently applied for their audiology licensure and hearing aid specialist license. I have been fortunate to have retained the majority of these audiologists, and my current staff now consists of myself and 7 licensed audiologists, all of whom also hold hearing aid specialist licensure as well.

Over the years there has been a steady transition to more specialized hearing aid training within university audiology programs. In the earlier years in some universities, (when only a Master’s degree was required for audiology practice) much of the graduate student’s amplification knowledge was academically based, with somewhat less emphasis on practical experience with hearing aids.

Presently, in contrast, the overall academic hours of the university graduate audiology curriculum have generally doubled due to advances in hearing aid complexity and the transition of audiology to a doctoral profession approximately 10 years ago. Current audiology curriculum is comprised roughly of 50% assessment protocol for hearing/balance disorder diagnoses and 50% amplification instruction. In addition to course hours, most doctoral audiology programs now require a minimum of 500 practicum hours during the first 3 years of a 4 year degree. Therefore, even a beginning 4th year audiology extern in his/her last year of graduate studies, while under the supervision of an outside preceptor, is well equipped for hearing aid fitting and troubleshooting.

· The Hearing Aid Specialist Board regulations do not require the otolaryngology physician to take any section of the hearing aid specialist’s exam. Although the otolaryngologist is an expert in the surgical and medical remediation of diseases of the ear, their practical training in hearing aid fitting is far less than the training of a doctoral audiologist. In fact, much of the ENT’s training related to hearing aids is generally provided by doctoral audiologists on the faculty of the medical school.

· The current Hearing Aid Specialist Board’s regulations stipulate the audiologist with a 4 year graduate doctoral degree must take the entire written exam and some of the practicum exam. All current exam requirements are justified in the case of a “non-audiologist” applicant who may be as young as 18 years of age, and who may have only met the minimal educational requirement of a high school education or a GED high school equivalency. The minimal training of the “non-audiologist” is in stark contrast to the graduate-trained audiologist.

(ii) The hearing aid examination requirement for licensed audiologists imposes a negative economic impact on small business owners of audiology practices.

· Previously, the practicum and written Board’s examinations were administered all in 1 day. Recently the testing has been spread over 2 days and, to make it worse, the testing is now done in 2 different months. The 2-day schedule requires applicants who are not from the "near-Richmond" area, to travel significant distances across the Commonwealth the day prior to testing, obtain accommodations so that they can be at the test site by 8 a.m. the following day, usually not finishing the exam until 5 p.m. to leave for home. The applicants must then repeat this process for the 2^nd portion of the exam one month later. Finally, notification of “pass” or “fail” is received about 4-6 weeks after the second examination. The expense to these applicants in time, gas, accommodations, and up to 4 days of lost wages and lost time with patients is significant.

· It is also costly for the Board in paying for exam administrators for 2 days instead of one. If the Hearing Aid Specialist Board has so many applicants for the exam that they can no longer administer the test on 1 day, then the removal of the unnecessary exam requirement for audiologists would reduce the examination load on the Board, making the Board more efficient and allowing more time for testing of those applicants with no formal educational training, resulting in a cost-reduction to the Commonwealth and to the applicants.

· It should be emphasized that all audiologists who are licensed also as hearing aid specialists would still be required to pay their licensure fees as well as to be subject to all the regulations of the Hearing Aid Board.

Public comments submitted respectfully by staff audiologists and hearing aid specialists of:

Audiology Hearing Aid Associates, Danville and Lynchburg, Virginia.

Danny W. Gnewikow, Ph.D., Audiologist, CCC (1974); Hearing Aid Specialist (1976)

Nancy V. Bradsher, Au.D., Audiologist, CCC (1992); Hearing Aid Specialist (1993)

Monique L. Hall, Au.D., Audiologist, CCC (1995); Hearing Aid Specialist (1995)

Lauren B. Stone, Au.D., Audiologist, CCC (1998); Hearing Aid Specialist (1998)

Kelly M. Camarda, M.Ed., Audiologist, CCC (2001); Hearing Aid Specialist (2001)

Amber S. Wolsiefer, Au.D. Audiologist, CCC (2007); Hearing Aid Specialist (2007)

Kara E. Martin, Au.D., Audiologist, CCC (2009); Hearing Aid Specialist (2009)

Brenda M. Dickman, Au.D., Audiologist CCC (2010); Hearing Aid Specialist (2010)

CommentID: 20997

10/17/11 10:33 am

Commenter: Stephen M. Krehbiel,NBC-HIS Beltone Hearing Aid Center.

Periodic Review of Regulations and Public Participation Guidelines.

The guidelines for all Hearing aid dealers and fitters needs to be retained as is to protect public health, safety and welfare for all those individuals who would benefit from our services upto and including Doctors, Audiologists and anyone licenced to dispense hearing instruments in private practice businesses.

CommentID: 21021

10/26/11 8:01 pm

Commenter: Kristie Meehan, James Madison University Audiology Student

Hearing Aid Dispensing License

Currently in Virginia Audiologists are subject to the same dispensing license and exam as hearing aid dealers/specialists. As a current student in the field, it seems the need for me to come out of my Au.D. program and take another exam to prove that I am qualified to practice and dispense hearing aids is not only unnecessary, but questions the Au.D. program and education that I have received. Why is it necessary for Au.D. students to go through 4 years of study only to come out and have to take the same exam that a person without audiologic training? In my opinion, the 4 years of graduate level schooling received should sufficiently prepare future Audiologists and they should not be subjected to the same licensure exam as people that have not received that 4 years of training.

CommentID: 21126

10/27/11 2:06 pm

Commenter: Brenda M. Ryals

Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20

October 26, 2011

William H Ferguson, Executive Director

Commonwealth of Virginia

Department of Professional and Occupational Regulation

Board of Hearing Aid Specialists

9960 Mayland Drive, Suite 400

Richmond, VA 23233

Subject: Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20, and public participation guidelines, 18 VAC 80-11

Public Comment: Removes the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist license.

Dear Mr. Ferguson,

As a faculty member of James Madison University Department of Communication Sciences and Disorders (housing Virginia’s only accredited training program in Audiology) I respectfully suggest that Virginia licensed audiologists should be exempt from the Hearing Aid Specialist Examination requirement, both written and practical, as a part of obtaining a Virginia hearing aid specialist license.

The national requirements for graduate training in Audiology been established for all 71 Audiology programs in the United States, the District of Columbia and Puerto Rico by the Council on Academic Accreditation (CAA; www.asha.org/academic/accreditation/CAA_overview.htm). CAA has established a rigorous set of standards by which all Audiology programs are judged and to which a program must demonstrate compliance in order to be accredited. The current standards are outcomes-based, meaning that students must demonstrate both knowledge and practical skills in all areas across the entire breadth and depth of the scope of practice for audiologists. Naturally, one of these essential areas is in hearing aid evaluation, fitting and management.

Audiologists undergo 4 years of graduate training in order to receive the professional doctorate (Au.D.). JMU requires a total of ~100 graduate semester credit hours to complete the training program. A minimum of two courses (7 semester credit hours) are specifically dedicated to evaluation and fitting of hearing aids. In addition, the management of hearing aids and other hearing devices is treated in several courses as related to special populations (pediatrics, geriatrics, cochlear implants, etc) and students also accrue many hours of supervised practical training at the graduate level in hearing aid technology, selection, fitting, verification, and follow up so as maximize the benefit of amplification and patient satisfaction. This program of study is typical in accredited training programs across the country. Successful completion of this graduate training is incorporated into the requirements for licensure as an audiologist in the state of Virginia.

Audiologists must also take a national examination which covers a number of knowledge areas including that of hearing aids. Audiologists are also required to satisfy continuing education requirements of Audiology licensure. None of these are requirements for Hearing Aid Specialists.

Quite simply, the level and extent of educational training for audiologists in amplification skills and issues far exceeds those of any other health-care profession and most certainly qualifies Audiologists to be exempt from taking the Virginia Hearing Aid Specialist examination. This examination is redundant for Audiologists as the level of skill and knowledge required for Audiology licensure far surpasses that required for Hearing Aid Specialists.

For all of these reasons citizens of the Commonwealth of Virginia and members of the Department of Professional and Occupational Regulation can have confidence in knowing that licensed Audiologists have been sufficiently trained and have demonstrated expertise in areas related to amplification far exceeding that demonstrated in the written and practical examination required to obtain a license as a Hearing Aid Specialist in Virginia.

In summary:

· The training and state licensure requirements for Audiologists in the state of Virginia exceed the level of knowledge and skill evaluated on the written and practical examination for hearing aid specialist making this examination redundant, inefficient and unnecessary for Virginia licensed audiologists.

· By waiving the written and practical examination for licensed audiologists the DPOR and Board of Hearing Aid Specialists streamlines the process and allows more time for efficient and expeditious testing of applicants without graduate training in audiology.

· Because all audiologists who are licensed also as Hearing Aid Specialists would still be required to pay their licensure fees as well as be subject to all the regulations of the Hearing Aid Board no revenue is lost and regulation is maintained within the Board.

I sincerely appreciate the opportunity for public comment.

Signed:

Brenda M. Ryals, Ph.D., CCC-A, (licensed Audiologist in Virginia since 1974; licensed Hearing Aid Specialist in Virginia since 1984)

CommentID: 21127

10/31/11 1:30 pm

Commenter: Paloma Robinson, Au.D. / Professional Hearing Services

Removing examination requirements for audiologists appyling for Hearing Aid Specialist licenses

William H Ferguson, Executive Director

Commonwealth of Virginia

Department of Professional and Occupational Regulation

Board of Hearing Aid Specialists

9960 Mayland Drive, Suite 400

Richmond, VA 23233

Subject: Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20, and public participation guidelines, 18 VAC 80-11

Public

Comment: Remove the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist license.

Dear Mr. Ferguson,

I am a Doctor of Audiology. During my graduate training for my Au.D., I took 2 diagnostic testing courses, 2 amplification courses, 1 acoustics and instrumentations course, 1 pschoacoustics course, 1 anatomy course, 1 communication technology course, several counseling courses and aural rehabilitation courses in addition to the extra research, professional issues and other courses pertinent to my field of study. We learned the in and outs of hearing aid circuitry, programming, verification and validation. I had 3 internship placements and a full year of what would equate to a “residency” in the medical field. I took and passed candidacy exams in my graduate program. I’ve been certified by ASHA as clinically competent in Audiology and I have passed a Praxis exam.

These courses and requirements are a standard that have been established by accrediting bodies to ensure that training for all Doctors of Audiology is thorough, comprehensive and all encompassing and to make certain all curriculums in this field meet and exceed certain expectations of knowledge and skill.

I take issue with having to take yet another “exam” to prove that I have the expertise in the field for which I hold a doctorate. Additionally, the fact that an Otolaryngology physician can receive a hearing aid specialist license without any testing at all is baffling. In my opinion we are more qualified and educated in the picking, fitting, adjusting, verifying and counseling of these devices than most if not all ENT physicians, whose medical expertise is essential in our work but does not replace our knowledge.

In addition, because both portions of the test are taken on separate days a month apart, additional burden is placed on small business with loss of revenue and additional costs for accommodations and travel expenses since many practicing audiologists live outside the Richmond area and must travel the night before to arrive at the 8 am exam.

In short, I believe that Audiologists should be exempt from both portions of this exam. We have been thoroughly trained in the proper fitting techniques as well as the ethics side of our field. This examination is redundant for Audiologists as the level of skill and knowledge required for Audiology licensure far surpasses that required for Hearing Aid Specialists.

Thank you for your attention.

Paloma Robinson, Au.D., CCC-A, FAAA

Professional Hearing Services

8314 Traford Lane, Springfield, VA 22152

CommentID: 21142

10/31/11 3:22 pm

Commenter: Lauren Paroly, Au.D. / Professional Hearing Services

Removing examination requirements for audiologists appyling for Hearing Aid Specialist licenses

William H. Ferguson, II, Executive Director

Board for Hearing Aid Specialists

Department of Professional and Occupational Regulation

9960 Mayland Drive, Suite 400

Richmond, VA 23233

Subject: Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20, and public participation guidelines, 18 VAC 80-11.

Comment: Remove the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist license.

Dear Mr. Ferguson:

I am writing this letter to express my opinions regarding the regulations of the Board for Hearing Aid Specialists in the Commonwealth of Virginia, whereby I strongly believe that the regulations for a mandatory examination for licensed audiologists in the Commonwealth should be terminated.

As a recent graduate of a 4-year Doctor of Audiology program, I am frustrated by the need to continue with further testing to receive my hearing aid specialist license. I understand that while few states still require this, most states do not. The states that have removed that requirement from their laws have a clear understanding that a licensed audiologist has been educated, and subsequently licensed, through extensive training to safely and effectively perform all tasks necessary to fit and dispense hearing aids. For the purpose of licensed audiologists, I believe that the licensing examination is unnecessary, time consuming, and poorly organized.

While in graduate school, I was required to complete104 credit hours of training, including 9 credit hours of education on the selection, verification and validation of amplification, hearing aid modification, and signal processing schemes along with learning about real-world hearing aid fitting experiences. Along with extensive training in the anatomy and physiology of the ear and hearing system, I am fully trained in taking a safe, accurate, and useable earmold impression. Not only had I learned about hearing aid technology, fitting hearing aids, as well as taking earmold impressions, but while I was in graduate school, I was required to complete 34 credit hours of on- and off-campus clinical placements, which included 3-years of part-time work (approximately 3 days/week) and 12-months of full-time work in an audiology setting where I was required to perform hearing evaluations, take earmold impressions, and select, fit and troubleshoot hearing aids. This time amounted to over 2000 hours of supervised training and hands-on experience in these areas.

Additionally, in order for me to sit for the hearing aid dispensing examination, I will be required to take off 2 full days of work as well as stay in a hotel for 2 overnight stays. This is a large inconvenience for myself as well as my employer, as this is lost patient time.

I am also quite disappointed in the quality of the practical test as well as what I have seen and heard to be on the written examination. It is embarrassing that based upon this examination, a hearing instrument specialist is considered qualified to take earmold impressions as well as dispense and troubleshoot hearing aids. The earmold impression is taken on a rubber ear, which is highly unrealistic and the hearing aids are quite old and not regularly seen in a typical hearing aid practice/clinic. Also, the examinee is never required to troubleshoot the problem, rather just say what they would do to remedy the hearing aid problem. This does not test one’s ability to effectively solve the problem. Additionally, as seen in the practice questions for the written examination, one question asks what should be done in the event of collapsed canals when testing an individual’s hearing. According to the answer key, the correct answer would be to place a tube in the ear canal to ensure that the canal remains open during testing. While that was a necessity in the past, today, insert earphones are the gold standard for audiometric testing which would eliminate most problems associated with collapsed canals.

In saying this, I do not believe that it is necessary for licensed audiologists, especially Doctor’s of Audiology, to be required to sit for a 2-day (practical and written) hearing aid specialist licensure examination. Rather than the Board pay for examination administrators for 2 days (due to the high number of test takers) instead of one (as previously administered), they should consider removing the unnecessary requirement for already qualified audiologists to take the examination, which would allow the Board to potentially move the testing to one day. This money would be better spent on updating the examination, making testing requirements stricter, and allowing more time to test those applicants with no formal educational training.

I understand that one portion of the examination is a written examination that tests the examinee’s knowledge of the laws and regulations of the Board for Hearing Aid Specialists in the Commonwealth of Virginia. With that understood, I feel that all licensed audiologists who are also hearing aid specialists should be subject to all regulations of the Hearing Aid Dispensing Board, therefore, this information is pertinent and important to all individuals who are fitting hearing aids in the Commonwealth of Virginia. However, the methodology in how this portion is administered should be revised. Some recommendations for licensed audiologists include, seminars on the laws and regulations in local areas (i.e., Northern Virginia, Norfolk, Roanoke, etc.) or online, including an examination at the conclusion of the seminar.

Please consider these comments in your review of the mandatory requirements for licensed audiologists in the Commonwealth of Virginia. Thank you in advance for your consideration.

Lauren Paroly, Au.D., CCC-A, FAAA

Professional Hearing Services

6231 Leesburg Pike, Suite 512, Falls Church, VA 22044

CommentID: 21144

10/31/11 4:34 pm

Commenter: Andrea Cossettini, AuD; Professional Hearing Services

Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20

William H Ferguson, Executive Director

Commonwealth of Virginia

Department of Professional and Occupational Regulation

Board of Hearing Aid Specialists

9960 Mayland Drive, Suite 400

Richmond, VA 23233

Subject: Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20, and public participation guidelines, 18 VAC 80-11.

Dear Mr. Ferguson,

As a licensed audiologist and hearing instrument specialist in the Commonwealth of Virginia, I would like to add my comments in support of the elimination of hearing instrument specialist examination requirements for licensed audiologists.

Several comments posted previously have referenced the academic and clinical requirements to obtain a Doctor of Audiology (AuD) degree from an accredited degree-granting program. The Council on Academic Accreditation (CAA) has established national guidelines that must be followed for the degree-granting program to maintain accreditation and retain state licensure eligibility for its graduates. (See portions of the accreditation manual at: http://www.asha.org/academic/accreditation/accredmanual/section3/). It should be clear from these comments that knowledge-based training and clinical experience for a recently graduated Doctor of Audiology far outstrip the training and education required of non-audiologist hearing instrument specialists. Additionally, audiology licenses require that continued training and education units are earned yearly, which serves to maintain and expand the skill levels for audiologists many years after graduation.

The hearing instrument specialist license in the Commonwealth of Virginia has no continuing education requirements for any licensee, nor does the exam cover a similar breadth or depth of subjects when compared to the requirements for licensure in audiology. It is therefore redundant to require an audiologist licensed in the Commonwealth of Virginia to submit to examination for a hearing instrument specialist license.

Exempting audiologists from examination requirements related to hearing instrument specialist licensing would allow for more extensive, thorough, and timely examination of hearing instrument specialist candidates for licensure. Audiologists who also dispense hearing aids will in no way suffer from this exemption, and will not sacrifice any degree of training, education, or clinical practice standards by such an examination exemption. Nor will such a change in regulation have any perceptible impact on the health and wellness of the population seeking audiologic services, as again the training and education requirements for licensure to practice audiology already far exceed those required for hearing instrument specialist licensure.

Eliminating licensed audiologists from the practical and written portions of the Hearing Instrument Specialist licensure exam should benefit the Commonwealth in that testing could be condensed into a single day, where practical examinations and written tests can be administered concomitantly. The test administration savings could then be put toward modernizing and updating both the practical and knowledge-based portions of the hearing instrument specialist exams, which include questions on technology which has been discontinued for several years, but does not include questions on the most commonly fit, current, digital amplification technology available.

I believe the requirement for licensed audiologists in the Commonwealth of Virginia to sit for both the practical and written portions of the hearing instrument specialist license to be unnecessarily time consuming, costly, and also redundant given the current level of education required to earn a Doctor of Audiology degree and become licensed as a practicing audiologist. Thank you for the opportunity to comment on the existing regulations. I hope the Board will continue to view these comments and take into consideration the views of audiologists in the Commonwealth of Virginia.

Sincerely,

Andrea Cossettini, AuD, CCC-A, FAAA

Clinical Audiologist

Professional Hearing Services

150 Elden St #235

Herndon, VA 20170

CommentID: 21145

10/31/11 4:46 pm

Commenter: Justine Angilletta, James Madison University

Removal of the examination requirement for Virginia licensed audiologists

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

3^rd year AuD Student

James Madison University

CommentID: 21146