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.
