Concerning changes to the provisional audiology license as submitted on 7/2/07 by Brenda M. Ryals, Ph.D., Audiologist, James Madison University, I am in complete agreement. 

Suggestion 1

18VAC30-20-170B.1

The recommended changes are needed in order to accurately reflect the accreditation process. 

Suggestion 2

18VAC30-20-171A.2

The specifications for the provisional licensure tenure should not state that the provisional licensee “has successfully completed all the coursework…”.  Instead, it should stipulate that all “didactic classroom experience has been completed”.  Throughout the country many university audiology doctoral programs require some off-campus research or online coursework concurrent with the practicum experience during the externship year.   It should be noted that audiology practices in Virginia hire graduate students not only from Virginia schools, but from throughout the United States.

Suggestion 3

18VAC30-20-171B

It is imperative that the initial period for the provisional license be extended beyond the currently specified 12-month period.  Normally, a fourth year doctoral audiology student applying for an externship would receive his/her provisional audiology license in Virginia a few weeks prior to beginning employment.  Since most universities and the American Speech-Language Hearing Association (ASHA) require that the fourth year externship entail a 12-month practicum period, the current 12-month provisional licensure period would no doubt necessitate the Board’s issuing an extension in EVERY case for EVERY provisional licensee.  The paperwork required to renew a 12-month provisional license is grossly inefficient, costly, and unnecessarily time-consuming for the Board as well as the audiologist, and the audiology practice to which they are employed.  In addition, following the practicum, it will take at least another month or two for the Board to receive confirmation from the graduate school of the completion of doctoral credentials, and for the Board to issue the permanent audiology license.

Therefore, the recommendation made by Dr. Ryals that the initial provisional licensure period of 12 months be extended to 18 months is logical to avoid undue paperwork on the part of the Board, the newly licensed audiologist, and Virginia audiology practices.  Further extension beyond the 18-month period would be necessary only under rare extenuating circumstances.