18VAC30-20-170 B.1.

Current:  Holds a master's or a doctoral degree from  college or university whose audiology and speech-language program is regionally accredited by the American Speech-Language-Hearing Association or an equivalent accrediting body; and

Suggest:  Holds a master’s or a doctoral degree from a college or university whose audiology and speech-language program is accredited by the Council on Academic Accreditation of the American Speech-Language-Hearing Association or an equivalent accrediting body; and

Rationale:  Regional accreditation is awarded to university or colleges NOT programs.  For example, Virginia university or colleges receive regional accreditation by the Southern Association of Colleges and  Schools (SACS).  Programs are accredited by organizations (such as the CAA, the ABA, etc) or other bodies usually recognized by the US Dept. of Ed.  (Reference Feeman and Richie, Audiology Today 2007 volume 19(3) pp. 48-49)

18VAC30-20-171A.2.

Current:  Has successfully completed all the coursework required for the doctoral degree, as documented by the audiology program;

Suggest:  Has successfully completed all of the didactic coursework required for the doctoral degree as documented by the audiology program;

Rationale:  All students who will apply for provisional licensure (regardless of University affiliation) will necessarily be enrolled in a “course” which will cover the practicum experience for which they require licensure.  This “course” allows them to be enrolled in the University but is not a course which is taught in the classroom (not didactic).  Many students who will apply for provisional licensure will be enrolled in coursework related to their dissertation, thesis, or other research requirement.  This course will be required for graduation, but will not be taught in the classroom (not didactic).  Thus students applying for provisional licensure should have completed all of the courses taught in the classroom (didactic) but not all of the courses (practicum, research, thesis, and dissertation) which are required for the doctoral degree.

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.

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.