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]
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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
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 2nd 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