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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3/12/12  4:22 pm
Commenter: Danny W.Gnewikow, Ph.D., Audiologist; Audiology Hearing Aid Associates

Audiologists should be exempt from Hearing Aid Specialist Board examination.






   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.    

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 and hearing aid specialist licenses.  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 the advances in hearing aid complexity and the transition of audiology to a doctoral profession approximately 10 years ago. Current 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 (provisional audiologist), while under the supervision of an outside preceptor, is well equipped for hearing aid fitting and troubleshooting.  


 1.    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 or even the provisional audiologist.  In fact, much of the ENT’s training related to hearing aids is generally provided by doctoral level Ph.D, and Au.D. audiologists on the faculty of medical schools.



o   This bill’s exemption from Hearing Aid Specialist Board examination should apply to all licensed audiologists:  both full and provisional.   Reasoning:  Most audiologists who begin full-time audiology and hearing aid specialists practice in Virginia begin such during their fourth year (internship year) of their audiology graduate program and therefore also obtain their hearing aid license at the same interim that they are obtaining their provisional audiology license prior to employment.  In our practice, in addition to James Madison University, we have hired audiologists from other graduate programs throughout the United States.  The requirement of the Hearing Aid Board examination and the travel necessary to obtain this license prior to employment is an extreme hardship on professional students seeking to relocate for permanent audiology practice in Virginia.  Our Code of Virginia should not discourage qualified professionals moving to our Commonwealth.


2.    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. 



3.    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 or the United States the day prior to testing, obtain accommodations so that they can be at the test site by 8:00 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, airfare, accommodations, and up to 4 days of lost wages or missed classroom time is significant.  It is also costly for the Board in paying for exam administrators for 2 days instead of one.




If the Hearing Aid 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.



4.    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. 



o   This bill for revision of § 54.1-1501 Code of Virginia to exempt audiologists from the Hearing Aid Board examination requirement is in no way  exempting audiologists from licensure under the Hearing Aid Specialists Board.  In fact, we are fully supportive of maintaining audiologists to be separately licensed both as audiologists and hearing aid specialists if they wish to dispense hearing aid devices.


 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)








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