18VAC30-20-171B.

Current:  A provisional license shall expire 12 months from the date of issuance and may be renewed for an additional 12 months by payment of a renewal fee. Renewal of a provisional license beyond 24 months shall be for good cause shown as determined by a committee of the board.

Suggest:  A provisional license shall expire 18 months from the date of issuance and may be not be renewed except under extraordinary circumstances as determined by a committee of the board. Rationale: 

Rational:  Twelve months from initial licensure does not allow sufficient time for applicants to complete the usual fourth year experience, graduate and obtain an official post graduation transcript.  Most fourth year practicum experiences will require a full 12 months of practicum experience.  Thus if a student applies for provisional licensure in order to fulfill the 12 month experience, he/she will not complete the experience and be able to apply for full licensure before the 12 months are completed.  It seems likely that most applicants will require a minimum of one additional month before they will be able to apply for full licensure.  Therefore almost all provisional licensees will be applying for renewal.  A longer provisional licensure time will eliminate the unnecessary paperwork required.  Further, it seems reasonable to expect that after the full 12 month practicum experience, provisional licensees will graduate and want to apply for full licensure, except under extraordinary circumstances.  Therefore a longer initial provisional licensure, without option for renewal except under extraordinary circumstances, will result in less paperwork for everyone and more audiologists applying for full licensure at the appropriate point in their professional career.  In the end this seems best for the profession and for the patients.