Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Audiology and Speech-Language Pathology
 
chapter
Regulations Governing the Practice of Audiology and Speech-Language Pathology [18 VAC 30 ‑ 21]
Back to List of Comments
1/16/26  12:52 pm
Commenter: Larry Engelmann, M.S., Au.D.

Amendment of 18VAC30-21-60(A) to include American Board of Audiology certification as an accepted pa
 

The Au.D. degree is a general practice degree that enables audiologists to have a broad scope of practice (SOP).  It is this general broad SOP that is specified in licensing laws.  Specialty practice and certification should have absolutely nothing to do with entry-level licensure.  Certification should only be accomplished and acquired after post-licensure training and advanced education.  Licensing boards and licensing laws should never use a narrow specialty certification as a measure to shortcut a determination of whether or not an applicant is eligible to receive an entry-level license for a broad scope of practice.  That determination should be made by an applicant satisfying the state's degree requirements and acceptable national examination scores established by the board.  State licensing regulates entry-level qualifications -- not specialty qualifications.  States are sovereign -- they should not be encumbered by any professional organization in any legislative language, e.g., ASHA or AAA, nor by certification language, e.g., CCC-A or ABA certification designations. 

CommentID: 238926