Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Hearing Aid Specialists and Opticians
Hearing Aid Specialists Regulations [18 VAC 80 ‑ 20]
Action Amendments to Board for Hearing Aid Specialists Regulations 2012
Comment Period Ended on 3/14/2012
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3/14/12  10:31 pm
Commenter: Dr. Susan L. Herr, Audiologist Centers For Hearing Care Liberty, OH

Audiologst exemption from unnecessary duplication of license for hearing aids

To Whom It May Concern;

I am writing on behalf of my fellow audiologists in the Commonwealth Of Virginia. Audiologists by the nature of their degree and the training required to obtain their post graduate degree are more than adequately qualified to dispense hearing aids.  The notion that a professional with a Doctoral degree or a Master's Degree in Audiolgy needs to take a test to be able to perform hearing aid dispensing is ridiculous at best and showing ignorance on the part of the licensure board at its worst.

The professional scope of practice of the Academy of Doctors of Audiology (ADA), American Academy of Audiology (AAA) and the American Speech Language-Heairng Aid Association (ASHA) all stipulate the dispening and fitting of hearing aids is within the scope of practice for audiologists.  The knowledge base and skill set of any audiologist far exceeds the minimal requirements that VA applies to other individuals who dispense hearing aids.

To insist that an Audiologist take a test that cannot duplicate 6 to 8 years of professional education to perform a service that is already in theri professional scope of practice shows a lack of ignorance about the difference between an audiologist and a mere hearing aid dispenser.  If an audiologist was incapable of dispensing hearing aids then the school that granted their Doctoral degree or Master's Degree would not have granted the degree in the first place.

If the Board is trying to hold onto the duplication fee of required by holding two licenses and paying multiple fees for exams and dual licensure, then this too is short sighted.  Licensure laws are designed for consumer protection.  Is the VA State Speech Language-Pathology and Audiology board ineffective in maintining control over who is competent to be an audiologist?  The need to have two licenses and meet two sets of criteria to perform the same job seems redundant.

In the State of OH Audiologists are exempt from having to take an exam to demonstrate they are competent to dispense hearing aids. The State of OH long ago recognized that by the nature of the training required to become an Audiologist qualifies an Audiologist to dispense hearing aids.  The professional scope of practice lined out by ADA, AAA and ASHA all include hearing aid dispensing under the Audiology Scope of Practice.  Audiologists adhere to the professional code of ethics established by these groups.

Please take the steps necessary to update the current antiquated VA state regulations that unfairly and unnecessarily require Audiologists to duplicate training and exams that were requierd to obtain their audiology degree. Does the state of VA require other licensed professionals to meet lesser standards and have dual licensure for other medical fields such as requiring a medical physician to also obtain a license to be a physician's assistant, or a dentist to also obtain a license to be a dental assistant?  Audiologists should not need to have a duplicate license to dispense hearing aid, nor should they be required to take an exam for dispensing hearing aids.


Dr. Susan L. Herr, F.A.A.A.  Audiologist Centers For Hearing Care Liberty, OH

CommentID: 23540