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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10/27/11  2:06 pm
Commenter: Brenda M. Ryals

Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20


October 26, 2011
William H Ferguson, Executive Director
Commonwealth of Virginia
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
Public Comment: Removes the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist license.
Dear Mr. Ferguson,
As a faculty member of James Madison University Department of Communication Sciences and Disorders (housing Virginia’s only accredited training program in Audiology) I respectfully suggest that Virginia licensed audiologists should be exempt from the Hearing Aid Specialist Examination requirement, both written and practical, as a part of obtaining a Virginia hearing aid specialist license.
The national requirements for graduate training in Audiology been established for all 71 Audiology programs in the United States, the District of Columbia and Puerto Rico by the Council on Academic Accreditation (CAA;   CAA has established a rigorous set of standards by which all Audiology programs are judged and to which a program must demonstrate compliance in order to be accredited.  The current standards are outcomes-based, meaning that students must demonstrate both knowledge and practical skills in all areas across the entire breadth and depth of the scope of practice for audiologists.  Naturally, one of these essential areas is in hearing aid evaluation, fitting and management. 
Audiologists undergo 4 years of graduate training in order to receive the professional doctorate (Au.D.). JMU requires a total of ~100 graduate semester credit hours to complete the training program. A minimum of two courses (7 semester credit hours) are specifically dedicated to evaluation and fitting of hearing aids.  In addition, the management of hearing aids and other hearing devices is treated in several courses as related to special populations (pediatrics, geriatrics, cochlear implants, etc) and students also accrue many hours of supervised practical training at the graduate level in hearing aid technology, selection, fitting, verification, and follow up so as maximize the benefit of amplification and patient satisfaction.  This program of study is typical in accredited training programs across the country. Successful completion of this graduate training is incorporated into the requirements for licensure as an audiologist in the state of Virginia. 
Audiologists must also take a national examination which covers a number of knowledge areas including that of hearing aids.  Audiologists are also required to satisfy continuing education requirements of Audiology licensure.  None of these are requirements for Hearing Aid Specialists.  
Quite simply, the level and extent of educational training for audiologists in amplification skills and issues far exceeds those of any other health-care profession and most certainly qualifies Audiologists to be exempt from taking the Virginia Hearing Aid Specialist examination.  This examination is redundant for Audiologists as the level of skill and knowledge required for Audiology licensure far surpasses that required for Hearing Aid Specialists.
For all of these reasons citizens of the Commonwealth of Virginia and members of the Department of Professional and Occupational Regulation can have confidence in knowing that licensed Audiologists have been sufficiently trained and have demonstrated expertise in areas related to amplification far exceeding that demonstrated in the written and practical examination required to obtain a license as a Hearing Aid Specialist in Virginia.
In summary:
·                     The training and state licensure requirements for Audiologists in the state of Virginia exceed the level of knowledge and skill evaluated on the written and practical examination for hearing aid specialist making this examination redundant, inefficient and unnecessary for Virginia licensed audiologists.
·                     By waiving the written and practical examination for licensed audiologists the DPOR and Board of Hearing Aid Specialists streamlines the process and allows more time for efficient and expeditious testing of applicants without graduate training in audiology.
·                     Because all audiologists who are licensed also as Hearing Aid Specialists would still be required to pay their licensure fees as well as be subject to all the regulations of the Hearing Aid Board no revenue is lost and regulation is maintained within the Board.
I sincerely appreciate the opportunity for public comment.
Brenda M. Ryals, Ph.D., CCC-A, (licensed Audiologist in Virginia since 1974; licensed Hearing Aid Specialist in Virginia since 1984)
CommentID: 21127