On behalf of the Association of Virginia Audiologists (AVA), we respectfully urge the Board to reinstate language recently omitted to include: (i) unrestricted American Board of Audiology (ABA) certification with a passing score on a qualifying national examination, and (ii) recognition of the Accreditation Commission for Audiology Education (ACAE) as an approved accrediting body for audiology education programs. Recognition of ABA certification as a path toward licensure and recognition of the ACAE accrediting body were included in prior versions, but were recently omitted from section 18VAC30-21-60, Qualifications for Initial Licensure.
The American Board of Audiology (ABA) is a nationally recognized certifying body for professional audiologists. Individuals who obtain ABA certification demonstrate a commitment to ethical practice, rigorous professional standards, and ongoing professional development. ABA certification is voluntary; however, for many years it has been recognized as a valid and appropriate qualification for state licensure purposes, alongside other national credentials.
The Accreditation Commission for Audiology Education (ACAE) has developed and adopted educational standards, policies, and procedures consistent with guidelines established by the Council for Higher Education Accreditation (CHEA) and the United States Department of Education. ACAE is the only accrediting body focused exclusively on audiology doctoral programs, and each accredited program must meet 40 rigorous accreditation standards.
While these entities were omitted from the current regulations, the Certificate of Clinical Competence in Audiology (CCC-A) and Council on Academic Accreditation (CAA) accreditation remain recognized. Limiting licensure pathways to a single certification and a single accrediting body is inequitable and fails to recognize that audiologists are offered multiple nationally accepted paths to voluntary certification and professional education.
The Association of Virginia Audiologists recognizes both the CCC-A and the ABA as voluntary credentials and considers both the CAA and ACAE to be high-quality accrediting organizations. Members of our organization may hold certification from one or both certifying bodies. Restricting state licensure recognition to a single certification pathway creates an undue and unnecessary hardship for otherwise qualified audiologists who elected to pursue ABA certification and who meet all professional standards for practice.
For these reasons, AVA respectfully requests that the Board reinstate recognition of ABA certification and ACAE accreditation as qualifying pathways for initial licensure, consistent with prior regulations and principles of fairness, professional parity, and public protection.

Respectfully submitted,

Association of Virginia Audiologists, Board of Directors
Kristin Koch, Au.D., President
Nathan Michalak, Au.D., President-Elect
Melissa Garber, Au.D., Member at Large
Jennifer Poston, Ph.D., Vice President of Advocacy
Allison Croushorn, Au.D., Vice President of Membership
Casey Vandervelde, Au.D., Vice President of Communications
Jamilah Odeh, Au.D., Vice President of Continuing Education
Kim Imajo, Au.D., Treasurer
Crystal Amantea, Au.D., Secretary