January 27, 2025

VA Professional and Occupational Licensing Board of Audiology and Speech-Language Pathology, 9960 Mayland Drive, Suite 300,Henrico, VA 23233

I am an audiologist, practicing in Prince William County, and I ask that you amend the requirements for our licensure as stated below.  

Submitted Via Online Townhall & Emailed to Executive Director Kelli Moss (kelli.moss@dhp.virginia.gov)

Re: Requesting Amendments to Proposed Rule Changes to 18 VAC 30-21

Dear Members of the Board,

The American Academy of Audiology (the Academy) appreciates the opportunity to submit comments on proposed rule changes to 18 VAC 30-21.  The Academy is the largest organization of, by, and for audiologists. We are dedicated to the provision of quality hearing and balance care services through professional development, education, research, and increased public awareness of hearing and balance disorders.

We commend the board's efforts to streamline licensure processes and improve accessibility for audiologists. However, we respectfully suggest amendments to further clarify and strengthen the proposed regulations. Our recommendations address our concerns on the removal of the ABA certification, the ambiguity of ACAE accreditation, and providing additional guidance on CEUs. These adjustments would improve the rules, ensuring they better serve audiologists in Virginia.

ABA Certification Language Removal

The removal of ABA certification language from 18VAC30-21-50, “Qualifications for Initial Licensure,” creates inconsistency in the regulations and potential confusion for applicants. While we understand that ABA certification remains a viable option, its exclusion unfairly disadvantages ABA-certified audiologists compared to ASHA’s CCC, which is retained in the regulations. Furthermore, 18VAC30-21-110, “Inactive Licensure,” explicitly includes ABA certification, highlighting a discrepancy that undermines regulatory consistency. To ensure fairness and clarity throughout the licensure process, we strongly urge the inclusion of ABA certification in the initial licensure qualifications. If the board decides not to incorporate ABA certification language, we respectfully request the removal of ASHA certification language to maintain equitable treatment of professional certifications.

ACAE Accreditation

The Academy advocates for the explicit inclusion of ACAE accreditation in the regulations to provide greater clarity and certainty for applicants from ACAE-accredited programs. Although the board’s existing guidance document acknowledges ACAE as board-approved, embedding this recognition directly in the regulations would eliminate any potential ambiguity. This change aligns with the proposed rule’s intent to streamline licensure processes and reduce barriers for qualified professionals. By increasing transparency, this amendment would not only encourage more qualified applicants but also help expand Virginia’s audiology workforce more efficiently.

CEU Guidance Document

We recognize the intent behind removing CEU program language to reduce redundancy; however, this change could create confusion about acceptable continuing education programs. To address this, we respectfully request the Board draft a guidance document that outlines approved CEU programs and publish it to the website’s guidance section. Such a resource would be a proactive step to support professionals in meeting continuing education requirements confidently.

Amendment Language Recommendations

The Academy respectfully submits the following recommended language, which is in red, for your consideration:

18VAC30-21-60. Qualifications for initial licensure.

A. The board may grant an initial license to an applicant for licensure in audiology or speech-language pathology who:

1. Holds a current and unrestricted Certificate of Clinical Competence issued by ASHA, a current unrestricted certification issued by the ABA; or

2. Holds a current and unrestricted certification issued by the ABA or any other accrediting body recognized by the board and provides documentation of having passed the qualifying examination from an accrediting body recognized by the board; or 3. Provides documentation of (i) graduation from an audiology program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body as recognized by the board; and (ii) having passed the qualifying examination from an accrediting body recognized by the board. Submits evidence of the following:

a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA, Accreditation Commission for Audiology Education (ACAE),or an equivalent accrediting body recognized by the board;

Or another alternative language recommendation:

18VAC30-21-60. Qualifications for initial licensure.

A. The board may grant an initial license to an applicant for licensure in audiology or speech-language pathology who:

1. Holds a current and unrestricted Certificate of Clinical Competence issued by ASHA; or

2. 1. Holds a current and unrestricted certification issued by the ABA or any other accrediting body recognized by the board and provides documentation of having passed the qualifying examination from an accrediting body recognized by the board; or 3. Provides documentation of (i) graduation from an audiology program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body as recognized by the board; and (ii) having passed the qualifying examination from an accrediting body recognized by the board. Submits evidence of the following:

a. Documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA, Accreditation Commission for Audiology Education (ACAE), or an equivalent accrediting body recognized by the board;

Conclusion

The American Academy of Audiology commend the board’s efforts to improve licensure processes and accessibility for audiologists. By addressing our concerns regarding ABA certification, ACAE accreditation, and CEU guidance, we are confident that these adjustments will improve the licensure process to better support audiologists. We appreciate the board’s consideration of these recommendations and are committed to working collaboratively to improve the regulatory framework for the benefit of audiologists and the patients they serve. Thank you for your time and attention to this important matter. If you have any questions about any of the information included in this letter, please contact Joanne Zurcher, Vice President of Government Relations and Policy, at jzurcher@audiology.org

Sincerely,

Patricia Gaffney, AUD

President, American Academy of Audiology