1. 18VAC80-20-10 Definition:  B.  The definition of audiologists should not be removed from section B, especially now that there is so much confusion within the "insurance community" between allowable services which can be rendered by a licensed hearing aid specialist as compared with those allowable services provided by licensed audiologists for diagnostic hearing and balance testing.  Multiple insurance companies who do not understand the distinction between audiologists and HAS are now stating that advanced diagnostic audiology testing must be done through their "contracted" hearing aid fitter provider TPR (Third Party Payor) companies, many of which are not staffed with licensed audiologists.  If the word "audiologist" is listed in Section A, it should be defined in Section B, especially when the word "audiologist" is also mentioned in the revised 18VAC80-20-270 f. e. defining disciplinary action.  
2. It has always been our understanding that a "non-audiologist HAS" is not permitted by law to perform any audiological testing services other than air/bone audiometry, speech threshold, and speech discrimination.  Additionally, it has been our understanding that such basic HAS testing is not billable to the patient or their insurance.  The purpose of the HAS audiometry testing is only for the fitting of a hearing aid and NOT for diagnostic purposes.  
   1.  I believe it is evident that the Board has recognized this limitation of HAS services in 18VAC80-20-30 h. g. where the words "and related tests" have been struck through.
3. 18VAC80-20-40 Temporary Permit: In section 1, there should be some written accommodation for audiology graduate students in their internship year/period to be allowed to take the examination if they request this during this time without waiting until the standard minimum 6 month's training time as specified in former Section C, now Section E. 5. 
4. Lastly, myself and my staff of 7 audiologists are quite pleased with all of the extensive revisions that have been made in these HAS Board Regulations, and we applaud you for your thoughtful and extensive re-examination as it relates to current hearing aid practices and revised Federal Regulations.

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

Hearing Aid Specialist License #2101-000232

Audiology License # 2201-000057