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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3/6/12  10:30 am
Commenter: Melissa D. Albright, Au.D.

Licensed Doctors of Audiology should be exempt from the hearing aid examination

The Au.D. professional degree provides education, training, required adherence to a specific code of ethics, and appreciation for our fiduciary responsibility to the public that should exempt licensed audiologists from a costly and time consuming examination that demonstrates no knowledge not already proven by the granting of the degree and the state license.

CommentID: 23439

3/7/12  8:44 pm
Commenter: sandy burkes-campbell Maico Audiological Services, Newport News, Chesapeake

Proposed changes to hearing aid dispensing license

REquiring audiologists to obtain a hearing aid dealers license is unecessary.  I have owned an audiology practice in Virginia since 1995  and when I hire a new audiologist they must leave work for two days to go to Richmond and take exams on something they already know how to do!.  This puts a tremendous hardship on our staff and places a financial burden on my practice.  It does not harm the public in any way to waive the hearing aid dealers license for audiologists.  We have years of post graduate training in treating patients with hearing loss (incuding fitting hearing instruments.)  I am in favor of dropping this license which places an unfair financial burden on my practice.


Sandy Burkes Campbell

Maico Audiological Services



CommentID: 23455

3/8/12  3:44 pm
Commenter: Mavis W. Garrett, Au.D., CCC-A

Hearing aid licensure is duplication

Certified audiologists licensed in the Commonwealth of Virginia to perform professional audiological services are credentialed by virtue of extensive educational background and verification of knowledge of diagnosis and rehabilitation of the ear. This includes education both formal and practical. Besides being a duplification of licensure, it is time consuming as well as financially unnecessary. I find it fiscally irresponsible for Virginia to require redundant examination.

CommentID: 23462

3/9/12  1:33 pm
Commenter: Donna Marie Mallory, Au.D, CCC-A Culpeper Hearing Center

Licensed Virginia Audiologists should be exempt from taking the HA Dispenser Examination

An audiologist is a specialist in the auditory system, and is trained to diagnose hearing pathology, and treat non-medically caused hearing loss, among other things.  The use of hearing aids and assistive listening devices is the best course of management to treat hearing loss.  At James Madison University, the only Virginia university that offers the Au.D. degree, the curriculum covers two semester courses specifically in hearing aids and provides many hours of practical training in hearing aid selection, fitting, and follow up for students enrolled in the program.  All graduate programs in the US are accredited by the same agency, so standards for obtaining an Au.D. degree are consistent in this country.  Audiologists literally have hundreds of hands on experience and direct supervised training in fitting hearing devices.

Currently in Virginia, an Audiologist must take the examination to obtain a license to dispense hearing aids, and this is redundant based on our educational level, training, and testing required to obtain a Virginia Audiology license.  As audiologists, we are also required to obtain 30 hours of continuing education every two years, something that Hearing Aids Specialists are not required to do, so our profession is clearly qualified to fit hearing devices and stay current with the rapidly changing technology.  Audiologists should clearly be exempt from taking another examination to obtain a HAS license.

More than half the states in the US now allow audiologists to either practice under one state license, or allow exemption from taking an examination for a HA Specialty license.  Taking the examination for newly licensed audiologists in Virginia can present a hardship due to resources to get to Richmond; the limited availability of examination offering,  financial loss of revenue for the employer and audiologists,cost of travel and/or hotel stay,  and loss of time out of the office for patient care.

The proposed exemption in the Virginia HA Specialists code is reflective of the growth and change in the profession of Audiology. 

Thank you.

CommentID: 23463

3/9/12  2:12 pm
Commenter: Dr. Maria Morrison

Doctors of Audiology should be exempt for examination
The Au.D. professional degree provides education, training, required adherence to a specific code of ethics, and appreciation for our fiduciary responsibility to the public that should exempt licensed audiologists from a costly and time consuming examination that demonstrates no knowledge not already proven by the granting of the degree and the state license. Many states do not require Audiolgosits to take both exams.
CommentID: 23464

3/9/12  2:20 pm
Commenter: Theresa H. Bartlett, Au.D., Virginia Hearing Consultants, LLC

Audiologists taking the Hearing Aid Examination

It has never made any sense to me why Audiologists are required to take a hearing aid examination.  As an Audiologist, I am required to hold an undergraduate and graduate degree in Audiology.  As of this year, all Audiologists graduating from programs will hold a Doctorate Level Degree, which at this time I currently hold myself.  The level of education is not matched by that of the Hearing Instruments Specialists community.  The training and the background found within the Audiology community and institutions far exceeds that of the Hearing Aid Specialist community.

This exact discussion is becoming a point of contention in several states.  I believe that North Carolina just passed legislation that Doctorate Level Audiologists do not need to take the examination.  This makes a lot sense all things considered.  The question arises as to whether or not this change in policy could affect the safety of the public.  In no way would this change in policy affect the public.  Audiologists will not change their evaluation or referral process in any way just because they are no longer required to take a hearing aid examination.

CommentID: 23465

3/9/12  2:35 pm
Commenter: Kristen Kramer, AuD, CCC-A

Audiologists should not need duplicate Hearing Aid Dispenser Certification

The educational background and clinical experience obtained while completing a Doctor of Audiology degree includes all the necessary training to dispense hearing aids as well as to perfom the additional functions specific to being an Audiologist.  I personally work in the State of MO which several years ago opted to no longer require Audiologists to have a dual license as an Audiologist and Hearing Aid Dispenser.   I support this legislation.

CommentID: 23466

3/9/12  2:37 pm
Commenter: Lori Gardner, Au.D., Audiologist, Hear Virginia

Exam Exemption for Licensed Au.D. audiologists

I support exemption of doctoral audiologists (Au.D.) audiologists from the required hearing aid specialist examination.  It is a hardship to require audiologists to travel to Richmond on two different occasions to complete written and practical examinations which test abilities that the Au.D. audiologist obtained during their four year academic and clinical training. 

CommentID: 23467

3/9/12  3:00 pm
Commenter: Advanced Hearing Aids & Audiology, LLC

Waiver for audiologists

As an audiologist who has practiced in Maryland and Virginia for 27 years, I feel that it is unnecessary for audiologists to take the hearing aid dealers examination.  I did not have to take an examination in Maryland in order to dispense hearing aids.  I would also like to express my support by acknowleding that other states have long abandoned the need for either two licenses and/or minimally an audiologist having to take an exam for a dispensing license.  


Sharon Wicker, AuD, FAAA, CCC-A

Doctor of Audiology

29 Fairfax St SE, Leesburg, VA 20175  703-777-6424


CommentID: 23468

3/9/12  3:13 pm
Commenter: Sally Elder-Christensen, AuD/CCC-A; Maico Audiological Services

Unnecessary for Audiologists to obtain dispenser's license!

Audiologists who hold master's degrees or clinical doctorate degrees are fully trained to diagnose and treat hearing disorders and are the ONLY ones fully trained to treat and diagnose all areas of audiology. In our training we have met all requirements of both ASHA and AAA no matter which state of training. Each state in the US recognize this training and with copies of our PRAXIS scores and college courses, one can obtain a license to practice audiology in ANY state. So for VA to have a mandated dispenser's license for audiologists reflects not only a lack of understanding of our extensive, complete training but also a lack of respect for the unique contributions we make to our community/patients via out training. Other states have recognized this and have corrected such as unfair and unnecessary law. The Commonwealth of VA must recognize this and correct it too.  

CommentID: 23469

3/9/12  3:26 pm
Commenter: Thomas E. Borton, Ph.D., Doctors Hearing Clinic, Montgomery, Alabama

Amendments to Hearing Aid Specialists Regulations

In Alabama, our legislature eliminated the requirement that audiologists hold a hearing aid specialist license years ago princikpally for 3 reasons:

1. Audiologists in the U. S. must hold a doctoral degree (4-year graduate degree) in the field, and their knowledge and experience requirements far exceed those of hearing aid specialists. Requiring them to hold a license requiring lesser qualifications is illogical.

2. The expense born by audiolgists in applying for a hearing aid specialist license, and the cost of maintaining them in a dual licensure mode is redundant and unnecessary.

3. Research surveys showed that Alabamians were confused about who they were consulting about their hearing loss. Since licensing laws in Alabama are principally designed to protect citizens, eliminating redundant state regulation helped the public better understand the difference between these two groups of practitioners so that Alabamians could better utilize professional hearing services.

Thomas E. Borton, Ph.D.
Doctors Hearing Clinic
Montgomery, Alabama

CommentID: 23470

3/9/12  3:34 pm
Commenter: Danica Billingsly, Au.D.

Audiology training far surpasses the minimal Hearing Aid License requirements

I taught for several years in an audiology doctoral program (the Au.D. is audiology's equivalent of the O.D. for optometry).  My specialty was hearing aids.  My students learned more about hearing aids in their first 3 months of graduate study than is required of licensed dispensers, and they still had 3-1/2 years of study left, including 2000 clock hours of patient contact and two more classes on amplification.  

Before Illinois closed the requirement for dual licensure for audiologists as hearing aid dispensers in 2003, I had to take the hearing aid dispensing examination.  I was dismayed at that time to see what little depth of knowledge was required, and found the exam to be overly simplified wherein it penalized the greater knowledge base of an academically trained audiologist.  Many of my peers in other dual licensure states have noted the same, and the general report across the US in dual states is that the "fail rate" reported for audiologists on dispensing exams is likely due to exactly that problem.  That is, instead of answering a simple, "it's broken," an audiologist is likely to respond, "given this model of instrument, the gain should be at least 45 decibels but this cursory exam sounds in the neighborhood of 10 decibels, so the instrument is weak internally - possibly from a bad receiver - and should be sent for repair".  Believe it or not, that second answer has been counted as wrong, even though it is factually correct.  

Audiologists - by nature of their academic credential and subsequent state licensure in our profession - are already qualified to dispense hearing aids without any further licensure being necessary.  Illinois has solved the financial aspect by having our license fees remain the same as they would be in dual license, with the additional sum being routed to the hearing aid licensure board.  In this way, regulation of the hearing instrument consumer protection acts remains funded, without unnecessary and overburdensome legislative restriction of the practice of a profession.

CommentID: 23471

3/9/12  3:57 pm
Commenter: David Taylor, MA, Ears to You

Hearing aid specialist exam and license for audiologists

Hearing aid dispensing is at the very center of the scope of practice for audiologists, whether MA, MS, or AuD. I've taken the hearing aid specialist exam in three states (CA, IA, and VA) and in all three, the practical and theoretical aspects covered by the exam were addressed in the first half of the first semester of my first graduate-level hearing aid course. ENT physicians in the state of Virginia can apply for and receive a hearing aid dispensing license without taking the exam (I've seen one do it) even though they do not typically get any training or practice in hearing aid dispensing. A hearing aid specialist exam should not be required for audiologists. The privilege an audiologist has of dispensing hearing aids in Virginia should fall under the audiology license.

Submitted respectfully,

David A. Taylor, MA

CommentID: 23472

3/9/12  3:58 pm
Commenter: Robert Scharber, Au.D. F-AAA East Valley Hearing Center,Inc.

Audiologist Waiver of HA Exam

I am the chairperson for the Dept.of Health Services Advisory Committee for Special Licensing in Arizona. Our state has moved forward on seperate licences for Audiologists and hearing aid dispensers. Audiologists that dispense are licensed based on graduating from an accredited institution and do not have to take the hearing aid exam to dispense.  It was passed several years ago and has worked well in Arizona.  In fact, Audiologists and hearing aid dealers support each other on many issues.  

CommentID: 23473

3/9/12  4:35 pm
Commenter: Dr. Leslie Lesner, Lesner Hearing Center

Audiologists more than qualified to dispense hearing instruments

Audiologists  have a Master's degree or a Doctorate in Audiology which is the study of applied hearing sciences and include many many hours of study and hands-on professional experience in hearing aid evaluation, dispensing hearing instruments and follow-up care. Our education and licensing requirements far exceed those of a hearing aid dispenser whose high school education fulfills their requirements for licensure. The requirement that audiologists take the hearing aid dispenser's exam should be dropped.

I recall taking the exam in Richmond. After the exam, I overheard several potential hearing aid dispensers lamenting the content of the exam. They were shocked that certain topics were on the exam. ("I didn't know I'd have to know SRT!) I was sick to think that someone who did not know the most BASIC item of a hearing test was going to be selling hearing aids to unsuspecting consumers.

I would posit that for a person to come within a mile of a hearing impaired person they get the education and training that Audiologists need for their licenses, not the reverse.


Thank you.

Leslie Lesner, AuD.

Lesner Hearing Center

Alexandria, VA






CommentID: 23474

3/9/12  4:47 pm
Commenter: Justine Weaver, University of Virginia student

proposed changes in the Hearing Aid Speciality Code - Audiologists should be exempt from the exam

Since the Board of HAS is considering changes, I would like to support the proposal that licensed audiologists should be exempt from taking an examination fo obtain a hearing aid specialist license.  The professional education of audiologists has changed dramatically since the code was written, and now all graduate programs in the US are Doctoral level.  The increased coursework and hands on experience that Audiologists now have to fit hearing aids and provide care for hearing aid patients is above and beyond what a non- audiologist needs to obtain a license.  Currently, ENT physicians are exempt from taking an exam to obtain a licence without any coursework or practicum in hearing aid dispensing. 

In my opinion, if any profession should be exempt from taking an examination, it should be licensed audiologists.  A revised code should support this. 

CommentID: 23475

3/9/12  5:08 pm
Commenter: Dr. Bettie Borton

VA regs for licensed audiologists


Alabama does not require that doctoral level audiologists hold hearing aid dealers' license. This matter was resolved decades ago in our state. The state Attorney General's office rendered an opinion that such duplicity in licensure was not needed. The requirements of the AuD degree far exceed those of the hearing aid dealers' license, thus the AuD audiologist should not need to stand for licensure exam to dispense hearing instruments.



CommentID: 23476

3/9/12  7:45 pm
Commenter: Susan Chadwick, Au.D., CCC-A Board Certified in Audiology

Unnecessary licensure duplication

I have been a licensed hearing aid specialist in the Commonwealth of Virginia for over twenty years, and a licensed audiologist for over thirty.  I was fitting hearing instruments to active duty and retired military personnel at Walter Reed Army Medical Center long before non-federal government audiologists dispensed ampification.  When I left federal service, Masters level audiologists were routiney fitting hearing instruments, yet Virginia required written and practical examinations for all of us, regardless of how much dispensing experience we had, not to mention our advanced graduate level training.  The move to exempt audiologists in Virginia from an examination process designed, in my opinion, for what is generally a technician position, is long overdue.  Audiology programs nationwide require extensive classroom and practical education/training in this key area of audiology.  For our Commonwealth to continue to require its audiologists to take off from work, travel (in some cases) great distances, and complete an examination process designed for those who do not necessarily have a college degree is, in my opinion, a waste of their time, the Board of Hearing Aid Specialists time, and the the tax dollars of Virgina. I applaude all those who are endeavoring to move Virginia' s health provision system forward with this long overdue initiative.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              his text and enter your comments here. You are limited to approximately 3000 words.

CommentID: 23477

3/10/12  5:43 pm
Commenter: Don Schum, Ph.D., Oticon, Inc.

Proposed changes to Virginia HAS code

I support changing the current Virginia hearing aid specialist code to allow licensed audiologists to be exempt from taking all parts of the current examination to obtain a license as a Hearing Aid Specialist.   Within the last fifteen years, the educational requirements to obtain a graduate degree in Audiology have changed; specifically, now a four year doctoral program is standard in all US Audiology programs.  Educational requirements include specific courses on hearing aids, assistive devices and aural rehabilation.  Audiologists have academic credits and literally hundreds if not thousands of hours of practical experience treating hearing impaired patients with appropriate hearing devices.

Allowing a licensed audiologist exemption from the examination takes nothing away from licensing non-audiologists.  Taking the HAS examination is redundant to the training and evaluations that are inherent in the preperation and continuing education of licensed audiologists.

CommentID: 23478

3/10/12  7:15 pm
Commenter: Beth

Audiologists should not be required to hold hearing aid license

Florida has not required Audiologists to hold a hearing aid license in addition to Audiology license for many years now.  With the extent of our education and training this is not necessary.

CommentID: 23479

3/10/12  10:13 pm
Commenter: Larry Engelmann, Au.D.; Audiology Clinic, Inc.

Audiologist’s exemption from Hearing Aid Licensure

I am a licensed audiologist in Oklahoma and a member of the Oklahoma State Health Department’s Hearing Aid Dealers and Fitters Advisory Council.  Sometime around 1978, the dual licensure issue for audiologists was resolved by an Oklahoma Attorney General’s opinion.  The language used in the Audiology Act and the Hearing Aid Dealers and Fitters Regulations seen below simply and appropriately exempts one another from their respective licensing requirements:


Oklahoma Speech-Language and Audiology Act: Section 1604.

B.  The Speech-Language Pathology and Audiology Licensing Act shall not be construed to prevent:

1. A  person  licensed  under  any  other  law  of  this  state  from engaging in the profession or occupation for which such person is licensed, provided such person does not represent himself or herself to be a speech-language pathologist or audiologist;

4. The activities and services of a hearing-aid dealer or fitter so long as the activities and services of such dealer or fitter are limited to the selection, adaptation, distribution or sale of hearing aids, and the testing, instruction, and counseling pertaining thereto, as long as such hearing-aid dealer or fitter does not represent himself or herself to be an audiologist;


Oklahoma Hearing Aid Dealers & Fitters Regulations: Section 310:25 - 1-3


(b):  Nothing in this act may be construed as preventing or restricting a person licensed by this state as an audiologist or physician from practicing the profession for which licensed.


For any profession – mandated duplication of licensure is professionally unnecessary and a fiscally unreasonable burden on individuals when they are expected to conform to two licensing laws whereby both laws allow for the individuals to exercise the same, or similar, duties conducted by both professions.  Audiologists and hearing aid dealers are trained to test for the purposes of fitting hearing aids, trained to fit hearing aids, and trained to counsel the recipients of these services.  In some states, audiologists are required to hold an audiologist and a hearing aid dealer’s license.  Yet, to my knowledge, there are no state laws in the United States that require hearing aid dealers to become licensed audiologists or take any part of an audiologist’s licensing examination.  It would be an entirely different scenario if an audiologist wanted to conduct speech-language therapy on a patient.  Then, it would be reasonable and necessary for the audiologist to also become a licensed speech-language pathologist.


Consumer protection, and appropriate consumer recourse, is provided by the nature of each profession’s respective licensing laws. Redundant dual licensure adds no benefit to the consumer.  Other professions recognize this, for example:


a) Physicians are neither required to become a licensed physician’s assistant (PA) nor are physicians required to take any part of the PA’s licensing examination.

b) Dentists are neither required to become a licensed dental hygienist (DH) nor are dentists required to take any part of the DH’s licensing examination.  And, so it should follow that;

c) Audiologists should neither be required to be a licensed hearing aid dealer (HAD) nor should audiologists be required to take any part of the HAD’s licensing examination.


Respectfully submitted,


Larry Engelmann, Au.D.

Oklahoma City, Oklahoma

CommentID: 23481

3/10/12  11:29 pm
Commenter: Linda Carr-Kraft, M.A, CCC-A, FAAA

Audiologists should be exempt from the Virginia Hearing Aid Dealer's licensure

Audiologists are required to successfully complete both a graduate and undergraduate degree; in addition, they must also complete a clinical fellowhip year under the supersvision of licensed audiologist  to be certified by the American Speech-Language and Hearing Association .  They are extensively trained in the anatomy and physiology of the auditory system, the diagnosis and management of hearing loss and hearing aid technology.  Requiring them to take this exam is redundant to their education and experience.     

CommentID: 23482

3/11/12  8:14 am
Commenter: Kay Alley, M.S., CCC-SLP

Au.D. professionals should be exempt from examination

Audiologists who have received the Au.D. earned their credentials by verifying that they already have the knowledge required for all duties covered under their profession, including dispensing of hearing aids.  They do not need to take another exam, nor incur any further costs nor time involved with such exam, to prove their abilities in this area.  Please pass legislation to make a step toward common sense in this area.

CommentID: 23483

3/11/12  1:07 pm
Commenter: Pat Kricos, University of Florida

Rigorous education and training of Doctors of Audiologuy

Please provide full support for exemption of doctoral audiologists from the required hearing aid specialist examination.  As a professor for over 30 years, I can assure you that Doctor of Audiology (AuD) students receive rigorous education and training in all aspects of hearing aid fittings. Qualifications for the AuD degree at the University of Florida are similar to those of many other states, including Virginia, and these qualifications are stringent. In addition to a number of other courses regarding balance and hearing loss, the University of Florida AuD program requieres four (4) courses in amplification (hearing aids), one hearing aid analysis course, and four (4) counseling and audiologic rehabilitation courses, all of which prepare students for fitting of hearing aids. AuD students receive numerous written and practical comprehensive studies throughout their program. Requiring highly-trained and well-educated  AuD audiologists to take a State hearing aid specialist examination is not necessary in any respect. Thank you for the opportunity to comment.

CommentID: 23484

3/11/12  4:01 pm
Commenter: Therese C. Walden, Au.D., Walter Reed Medical Center

Amendment to remove requirement for dual licensure for Audiologists


An audiologist is a specialist in the auditory system, and is trained to diagnose hearing pathology, and treat non-medical causes for hearing loss. The prescription of hearing aids and assistive listening devices is the best course of management to treat hearing loss. All academic doctoral programs across the nation educate students in courses specific to the prescription, fitting and follow-up associated with hearing aid and assistive devices treatment for hearing loss. Many programs require multiple, advanced courses with many hours of practicum to support the didactic training.


Audiologists are autonomous hearing healthcare professionals who meet demanding graduation standards as well as licensing standards to practice their full scope of practice. Additionally, the rigorous continuing education requirement of audiologists in the state of Virginia, under the audiology license, also ensures that those who dispense hearing aids within their practice setting will receive contemporary ongoing education that will ensure efficacious and safe patient care is provided to the citizens of Virginia. 


The current regulation that requires audiologists practicing with an audiology license in Virginia to also obtain a hearing aid dispensing license is no longer applicable as the audiology license covers consumer safety in terms of state-of-the-art practice by the audiologist. Dual licensure for an audiologist is outdated and redundant and places an unfair burden on the audiology professional to meet the same standard with 2 separate licenses. I appreciate the opportunity to comment and encourage the Board to fully support the amendment to remove the need for dual licensure for fully qualified audiologists.
CommentID: 23485

3/11/12  6:51 pm
Commenter: Kimberly Barry, Au.D.

No need for hearing aid license

Georgia does not have a requirement for audiologists to hold a hearing aid dealer license. This issue was resolved many years ago. 

CommentID: 23486

3/11/12  10:55 pm
Commenter: Patricia Gaffney, AuD- Nova Southeastern University

Audiologists do not need a separate license

Dear Board Members- thank you for allowing public comment.  On the table is hearing instrument examinations and separate licensure for audiologists.  Coming from a university that is accredited to teach audiologists under two audiology accrediting bodies, audiologists are trained to dispense hearing instruments.  Audiology students receive knowledge about candidacy, necessary medical referrals under FDA and state requirements, technology, counseling, and rehabilitation in the area of hearing instruments in didactic and clinical training.  It is well within the scope of practice and education to fit hearing instruments and should be incorporated into the audiology license without the need for a separate dispensing license.  

      The most important thing is public protection and welfare.   A dispensing license in addition to an audiology license does not protect the public any more than a comprehensive audiology license which includes dispensing.  In actuality, it makes it more expensive for excellent private practice audiologists to afford to practice in your state as well as becoming a detriment to attracting new audiologists to your state.  In the coming years more and more people will be at the age of needing hearing aids and to keep obstacles in the way of  serving the needs of your constiuents.  Many states have a single comprehensive license for audiologists, including my state of Florida, without negative impact on the welfare of the public.


Thank you.


CommentID: 23488

3/11/12  11:41 pm
Commenter: Marcia Raggio, Ph.D.

hearing aid licensing waiver

By virtue of their advanced training and clinical doctoral degree, it is completely reasonable that audiologists should not have to take yet another test to prove their competency in hearing aid dispensing.  In California, we no longer are required to have a second, hearing aid dispensing license, due to the comprehensive training that audiologists receive in their doctoral programs.  

CommentID: 23489

3/12/12  6:14 am
Commenter: Dr. Deborah Dempesy AuD, Dempesy Audiology LLC dba All Ears Hearing Center


Please note that audiologists in the Commmmonwealth of Massachusetts , are exempt from the Hearing Instrument Specialist ( or Hearing Dealers) regulations. Audiologists have in most states been exempt from the Hearing Dealers licesing laws.

Audiolgoists are trained to an exceptionally high degree of academic and clinical training that far exceeds that of Hearing Aid Dealers. A minimum of 6 or 8 years academic training is required as well as 2000 hours of supervised clinical experience needed to obtain a degree as an audiologist.

I am in oppposition to this bill that Audiolgoists and Doctors of Audiology be required to obtain a duplicate degree in order to dispense hearing devices.


Deborah Dempesy AuD, FAAA , CCC-A Doctor of Audiology Lic #56 (audiology Lic)

Plymouth Massachusetts , Board Member of the Mass Academy of Audiology

CommentID: 23490

3/12/12  8:07 am
Commenter: Wendy Pulliam, SHAV

HA specialist regulation changes

I support the bill and audiologists being exempt from the exam due to extensive qualifications already in the field.  Audiologist have years of schooling that make them extremely qualified compared to that of a hearing aide dealer.

CommentID: 23491

3/12/12  8:25 am
Commenter: Carrie Mills

Waiver for audiologists and HA specialist examination
I  am writing in support of audiologists allowed to waiver taking the HA specialist examination in the state of VA.  Audiologists now have a doctorate level degree and there is no need for this examination. 
CommentID: 23492

3/12/12  8:58 am
Commenter: Shantell D. Lewis, AuD

hearing aid examination exemption

It is in my strongest opinion, that Audiologists should not have to take the hearing aid licensure examination in the state of Virginia.  As a doctorate level audiologist, I have practiced in another state prior to Viriginia where such an examination was not a requirement because it was understood that audiologists had the knowledge of hearing aid dispensing, fitting, etc as a result of completing higher learning (graduate school), completing a national certification and having hours of hands on experience prior to completing fittings on their own and obtaining a license.

It is in my opinion that the exam is needed for individuals that are dispensing hearing aids (hearing aid dealers) that are NOT audiologists. In fact, there needs to be MORE regulations in tact for these individuals to include updating their regulations on dispensing because there are a number of hearing aid dispensers that take this exam numerous times and still lack the require knowledge to fit hearing aids appropriately. (but they have a licence)

CommentID: 23493

3/12/12  9:24 am
Commenter: Erin L. Miller, Au.D.

Audiologists Exemption from Dual Licensure

I would like to express my support for Virginia audiologists holding a single license to provide a comprehensive array of professional services related to the prevention, audiologic identification, assessment, diagnosis and treatment of individuals with impairment of auditory and vestibular function.The audiology license in the state of Virginia should regulate the entire scope of practice for audiologists, including the fitting and dispensing of hearing instruments, thus negating the need for this second license.

Virginia is one of the last 14 states in the country that requires this outdated requirement for audiology professionals.  Audiologists receive extensive coursework and clinical training in order to appropriately manage patients with hearing loss, including the fitting of hearing instruments.

I hope that Virginia will recognize that the audiology license should include within its scope the treatment of individuals with hearing loss, including the fitting and dispensing of hearing instruments, and they will eliminate the need for a second license to fit hearing aids.



CommentID: 23494

3/12/12  9:44 am
Commenter: George R. Cook, AuD, CCC-A Occupational Audiologist

Hearing Aid Dispensing for Audiologist without state examination

I do not believe anything is gained by examining degreed, credentialed, and licensed audiologist. In fact nationwide, there is such a shortage of dispensing audiologist to meet the demand of selling manufacturers' hearing aids that other states (California) have resorted to certifying optometrist and chiropractors as hearing aid dealers. Virginia certainly does not want this. In the public interest, all obstacles for audiologist to dispense hearing aids should be removed. To become an audiologist today, it takes 8 years of higher education. Audiologist must become "Doctor of Audiology, AuD) before they can be certified and licensed.

CommentID: 23495

3/12/12  10:54 am
Commenter: Carolyn Smaka, Au.D.

Licensed audiologists in VA should be exempt from redundant hearing aid dispensing examination

All audiology academic programs in the U.S. require rigorous coursework and practical experience with the selection and fitting of hearing aids, and audiologists must also meet rigorous standards to obtain and maintain an audiology state license.  Therefore, most states do not require audiologists to take a separate exam to obtain a hearing aid license.  The requirement for a separate hearing aid license exam for audiologists creates needless bureaucracy and may in fact, harm the public by creating an unnecessary barrier (cost, travel, time) for audiologists who move to the state or our newly graduated.  Both the aging of the population as well as the identification of hearing loss in newborns through hearing screening have created a significant increase in the demand for audiology services.  To best address this need, Virginia should implement common sense measures that support and enable audiologists to practice within their area of expertise, one being the elimination of the redundant requirement for audiologists to take a separate exam to dispense hearing aids when it is already covered in the VA audiology state license.  Thank you for your consideration of this action which would eliminate redundancy and bureaucracy, and best serve the residents of Virginia.

CommentID: 23496

3/12/12  11:27 am
Commenter: Reed Norwood, AuD

Dual Licensure for Audiologists dispensing hearing aids

Licensed audiologists in Tennessee are no longer required to hold licensure as a hearing instrument dispenser.  Doctors of audiology are the only hearing care specialists who receive significant amounts of study and practicum specific to the art and science of hearing aid dispensing as a component to      (re)habilitation of hearing loss in their academic preparation.  Indeed, hearing instrument dispensers and physicians have little or no requirements for formal academic training in hearing aids from an accredited university in order to qualify for state licensure.

In reality, hearing aid dispensing is part of the scope of practice of Audiology.  I encourage the State of Virginia to allow audiologists to fully practice their profession without the burden of dual licensure.

Reed Norwood, AuD


CommentID: 23497

3/12/12  11:52 am
Commenter: Kara Gray, Au.D., Naval Health Clinic Quantico

Proposed changes to VA HAS Regulations

I would like to express my support of exempting audiologists from the Virginia HA Dispensing Examination.  Today's minimum requirements to become a licensed and certified audiologist are quite rigorous and typically include 8 years of post-secondary education, 4 of which are dedicated to earning a Doctorate of Audiology (Au.D.) degree.  The knowledge and experience affiliated with an audiologist's education make requiring an audiologist to take an additional HA dispensing examination redundant, outdated, fiscally irresponsible, and simply unnecessary. 

A single audiology license should be sufficent to provide all audiology services, including the fitting and dispensing of hearing aids, within the established scope of practice of the profession.  I appreciate the opportunity to show my support of this important proposed ammendment to current regulations. 

CommentID: 23498

3/12/12  12:00 pm
Commenter: Todd Gibson, Au.D.

Hearing Aid Dispensing and Licensure Law in Virginia.

Please amend your statutes to reflect the higher level of education and training that is now required and achieved by audiologists.  Au.D. or doctors of audiology should be exempted from a separate hearing aid licensing law.  This has been the case in South Carolina for a number of years. 

CommentID: 23499

3/12/12  12:03 pm
Commenter: Kathleen Vivaldi, Au.D.

Licensed Audiologists should not have to take the HAD exam.

An Audiologist, by nature of their extensive study and residency, should not have to take the HAD licensure exam to hold dual certification both as am Audiologist and as a hearing aid dispenser.  It is by the advanced training that the Audiologist has the knowledge and credentials to dispense.  The dual certification adds nothing to the skill set the Audioliogist already posseses and it does not provide any addtional benefit to the population served.

CommentID: 23500

3/12/12  12:38 pm
Commenter: Nancy N. Green, Au.D., FL Licensed Audiologist

Audiologist Exempt From Dual Licensure Requirement

The State of Florida long ago ended the dual licensure requirement for audiologists in part because the costs for administering two programs to license the same single licensee who performs the same actions on the same member of the public is a waste of public funds while providing no additional public protection. 

CommentID: 23501

3/12/12  12:39 pm
Commenter: Linda A Burba Au.D

Audiology exam

Audiologists should not need to repeat or duplication of exam. As in most other states, it's handled as a professional regulatory license. If this is the case then physicians should not be exempt. Audiologists hold a minimum of a masters degree and in most cases a Doctorate degree in hearing and balance disorders. 

CommentID: 23502

3/12/12  1:02 pm
Commenter: Rupa Balachandran, PhD., President, California Academy of Audiology

Regulations for Hearing Aid specialists 2012

Doctors of Auidology are professionals whose scope of practice is defined as the diagnosis and treatment of hearing losss. The training includes extensive theoretical and and practical training in the diagnosis of hearing loss, and the selection, fitting and verification of hearing aids.  Currently a national accrediation process ensures the quality of the programs and the thoroughness of the training.  Requiring a Doctor of Audiology to  go through another examination to fit hearing aids is highly redundant and creates a lot of unnecessary processes.  

CommentID: 23503

3/12/12  2:18 pm
Commenter: Christine Eubanks, Ph.D. CCC-A, FAAA VCU Department of Audiology

Audiologist exemption from HAS exam

The majority of hearing aids in the US are dispensed by audiologists.

It is largely audiologists who establish contemporary practice models and standards for evaluating and fitting hearing aids (including those used by Hearing Aid Specialists).  Audiologists’ extensive education and training is in the application of principles and procedures for identification of hearing disorders, as well as their remediation.  The doctorate is the requirement for new graduates, and audiologists are required to obtain 30 hours of continuing education every two years.  Audiologists are highly qualified to dispense hearing aids, and should be exempt from having to travel to Richmond to take additional examinations to obtain a HAS license.

CommentID: 23504

3/12/12  2:46 pm
Commenter: Abigail Poyser, Au.D., Phonak

Audiologists to be exempt from hearing aid license examination

Doctors of audiology spend 4 years in a rigirous academic program to obtain their degrees. These programs consist of both academic and clinic work, and the resulting degree allows them to identify and treat hearing loss.

Audiologists are already required to be licensed in the Commonwealth of Virginia. The requirements for this licensure encompass any and all requirements for the dispensing license. This results in paying unncessary fees, and also requires a trip to Richmond to take the examination, which can be a burden for those who do not live nearby (or do not have a car, as is common for those of us in Northern Virginia).

The dispensing license should not be required for certified and licensed audiologists, and I fully support the recommendation to remove the dispensing license requirement. Thank you for your consideration.

CommentID: 23505

3/12/12  3:55 pm
Commenter: Kim Cavitt, AuD, Audiology Resources, Inc.

Audiologists should be exempt from the examination requirements of dual licensure

Audiologists in 36 states, many of which with large population bases, are allowed to dispense hearing aids under the terms of their audiology license and, as such, are not required to obtain a second license or complete a second qualifying examination.  This requirement for duplicate licensure can put an undue hardship on audiologists and can make employement in Virginia less attractive to the most sought after audiologists.  This requirement for iual licensure should be repealed.

CommentID: 23506

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)








CommentID: 23507

3/12/12  5:15 pm

Redundant & Archaic

After 8 years of rigorous study, 1 year of full-time clinical practice, passing her dissertation/project, meeting and exceeding the requirements of the academy I can't believe that you want her to take a test to fit and program hearing aids! What's taking the state of VA to do the right & sensible thing?

CommentID: 23508

3/12/12  5:40 pm
Commenter: Mary Ann C. Gaskin, AuD

AuD licensure

 A neighbor state, Delaware, no longers require Audiologist to hold dual licensure. This went into effect on 8/1/2011. This change was a results of changes to our licensure making the AuD, the entry level professional degree. The legislators were confident the the audiologist has sufficient training during their academic education and hands on extenship.  Masters degree audiologst were grandfathered in with this law. Public safety was our professional responsibility. Our education and for many Board certified Audiologist are taking mandatory ethics courses. This is not a component of the hearing aid exam.




CommentID: 23509

3/12/12  6:23 pm
Commenter: MIchael Smith, MD Hearing

Virginia Audilogists

Virginia needs to abandon this law of having two licenses for audiology and hearing aid specialist, it's redundant non-effective.

CommentID: 23510

3/13/12  6:33 am
Commenter: Maegan Mapes Au.D.

HA dispensing exam
absolutely Audiologists should be exempt from this examination. All of the examinations they take to get their degree is enough!!
CommentID: 23512