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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10/31/11  3:22 pm
Commenter: Lauren Paroly, Au.D. / Professional Hearing Services

Removing examination requirements for audiologists appyling for Hearing Aid Specialist licenses


William H. Ferguson, II, Executive Director
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. 
Comment: Remove the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist license.
Dear Mr. Ferguson:
I am writing this letter to express my opinions regarding the regulations of the Board for Hearing Aid Specialists in the Commonwealth of Virginia, whereby I strongly believe that the regulations for a mandatory examination for licensed audiologists in the Commonwealth should be terminated.
As a recent graduate of a 4-year Doctor of Audiology program, I am frustrated by the need to continue with further testing to receive my hearing aid specialist license. I understand that while few states still require this, most states do not. The states that have removed that requirement from their laws have a clear understanding that a licensed audiologist has been educated, and subsequently licensed, through extensive training to safely and effectively perform all tasks necessary to fit and dispense hearing aids. For the purpose of licensed audiologists, I believe that the licensing examination is unnecessary, time consuming, and poorly organized.
While in graduate school, I was required to complete104 credit hours of training, including 9 credit hours of education on the selection, verification and validation of amplification, hearing aid modification, and signal processing schemes along with learning about real-world hearing aid fitting experiences. Along with extensive training in the anatomy and physiology of the ear and hearing system, I am fully trained in taking a safe, accurate, and useable earmold impression. Not only had I learned about hearing aid technology, fitting hearing aids, as well as taking earmold impressions, but while I was in graduate school, I was required to complete 34 credit hours of on- and off-campus clinical placements, which included 3-years of part-time work (approximately 3 days/week) and 12-months of full-time work in an audiology setting where I was required to perform hearing evaluations, take earmold impressions, and select, fit and troubleshoot hearing aids. This time amounted to over 2000 hours of supervised training and hands-on experience in these areas.
Additionally, in order for me to sit for the hearing aid dispensing examination, I will be required to take off 2 full days of work as well as stay in a hotel for 2 overnight stays. This is a large inconvenience for myself as well as my employer, as this is lost patient time. 
I am also quite disappointed in the quality of the practical test as well as what I have seen and heard to be on the written examination. It is embarrassing that based upon this examination, a hearing instrument specialist is considered qualified to take earmold impressions as well as dispense and troubleshoot hearing aids. The earmold impression is taken on a rubber ear, which is highly unrealistic and the hearing aids are quite old and not regularly seen in a typical hearing aid practice/clinic. Also, the examinee is never required to troubleshoot the problem, rather just say what they would do to remedy the hearing aid problem. This does not test one’s ability to effectively solve the problem. Additionally, as seen in the practice questions for the written examination, one question asks what should be done in the event of collapsed canals when testing an individual’s hearing. According to the answer key, the correct answer would be to place a tube in the ear canal to ensure that the canal remains open during testing. While that was a necessity in the past, today, insert earphones are the gold standard for audiometric testing which would eliminate most problems associated with collapsed canals.
In saying this, I do not believe that it is necessary for licensed audiologists, especially Doctor’s of Audiology, to be required to sit for a 2-day (practical and written) hearing aid specialist licensure examination. Rather than the Board pay for examination administrators for 2 days (due to the high number of test takers) instead of one (as previously administered), they should consider removing the unnecessary requirement for already qualified audiologists to take the examination, which would allow the Board to potentially move the testing to one day. This money would be better spent on updating the examination, making testing requirements stricter, and allowing more time to test those applicants with no formal educational training.
I understand that one portion of the examination is a written examination that tests the examinee’s knowledge of the laws and regulations of the Board for Hearing Aid Specialists in the Commonwealth of Virginia. With that understood, I feel that all licensed audiologists who are also hearing aid specialists should be subject to all regulations of the Hearing Aid Dispensing Board, therefore, this information is pertinent and important to all individuals who are fitting hearing aids in the Commonwealth of Virginia. However, the methodology in how this portion is administered should be revised. Some recommendations for licensed audiologists include, seminars on the laws and regulations in local areas (i.e., Northern Virginia, Norfolk, Roanoke, etc.) or online, including an examination at the conclusion of the seminar.
Please consider these comments in your review of the mandatory requirements for licensed audiologists in the Commonwealth of Virginia. Thank you in advance for your consideration.
Lauren Paroly, Au.D., CCC-A, FAAA
Professional Hearing Services
6231 Leesburg Pike, Suite 512, Falls Church, VA 22044


CommentID: 21144