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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3/10/12  10:13 pm
Commenter: Larry Engelmann, Au.D.; Audiology Clinic, Inc.

Audiologist’s exemption from Hearing Aid Licensure

I am a licensed audiologist in Oklahoma and a member of the Oklahoma State Health Department’s Hearing Aid Dealers and Fitters Advisory Council.  Sometime around 1978, the dual licensure issue for audiologists was resolved by an Oklahoma Attorney General’s opinion.  The language used in the Audiology Act and the Hearing Aid Dealers and Fitters Regulations seen below simply and appropriately exempts one another from their respective licensing requirements:


Oklahoma Speech-Language and Audiology Act: Section 1604.

B.  The Speech-Language Pathology and Audiology Licensing Act shall not be construed to prevent:

1. A  person  licensed  under  any  other  law  of  this  state  from engaging in the profession or occupation for which such person is licensed, provided such person does not represent himself or herself to be a speech-language pathologist or audiologist;

4. The activities and services of a hearing-aid dealer or fitter so long as the activities and services of such dealer or fitter are limited to the selection, adaptation, distribution or sale of hearing aids, and the testing, instruction, and counseling pertaining thereto, as long as such hearing-aid dealer or fitter does not represent himself or herself to be an audiologist;


Oklahoma Hearing Aid Dealers & Fitters Regulations: Section 310:25 - 1-3


(b):  Nothing in this act may be construed as preventing or restricting a person licensed by this state as an audiologist or physician from practicing the profession for which licensed.


For any profession – mandated duplication of licensure is professionally unnecessary and a fiscally unreasonable burden on individuals when they are expected to conform to two licensing laws whereby both laws allow for the individuals to exercise the same, or similar, duties conducted by both professions.  Audiologists and hearing aid dealers are trained to test for the purposes of fitting hearing aids, trained to fit hearing aids, and trained to counsel the recipients of these services.  In some states, audiologists are required to hold an audiologist and a hearing aid dealer’s license.  Yet, to my knowledge, there are no state laws in the United States that require hearing aid dealers to become licensed audiologists or take any part of an audiologist’s licensing examination.  It would be an entirely different scenario if an audiologist wanted to conduct speech-language therapy on a patient.  Then, it would be reasonable and necessary for the audiologist to also become a licensed speech-language pathologist.


Consumer protection, and appropriate consumer recourse, is provided by the nature of each profession’s respective licensing laws. Redundant dual licensure adds no benefit to the consumer.  Other professions recognize this, for example:


a) Physicians are neither required to become a licensed physician’s assistant (PA) nor are physicians required to take any part of the PA’s licensing examination.

b) Dentists are neither required to become a licensed dental hygienist (DH) nor are dentists required to take any part of the DH’s licensing examination.  And, so it should follow that;

c) Audiologists should neither be required to be a licensed hearing aid dealer (HAD) nor should audiologists be required to take any part of the HAD’s licensing examination.


Respectfully submitted,


Larry Engelmann, Au.D.

Oklahoma City, Oklahoma

CommentID: 23481