The Au.D. degree is a general practice degree that enables audiologists to have a broad scope of practice (SOP).  It is this general broad SOP that is specified in licensing laws.  Specialty practice and certification should have absolutely nothing to do with entry-level licensure.  Certification should only be accomplished and acquired after post-licensure training and advanced education.  Licensing boards and licensing laws should never use a narrow specialty certification as a measure to shortcut a determination of whether or not an applicant is eligible to receive an entry-level license for a broad scope of practice.  That determination should be made by an applicant satisfying the state's degree requirements and acceptable national examination scores established by the board.  State licensing regulates entry-level qualifications -- not specialty qualifications.  States are sovereign -- they should not be encumbered by any professional organization in any legislative language, e.g., ASHA or AAA, nor by certification language, e.g., CCC-A or ABA certification designations. 

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

VA 18VAC30-21-60 Comment Letter 

Dear Members of the Board,

My name is Allison Croushorn and I am a practicing audiologist at Fauquier ENT Consultants in Warrenton, Virginia. I am writing to express my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure.

ABA certification is a nationally recognized credential that reflects education, examination, and professional requirements specific to audiology. When ABA certification was removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists. Restoring this pathway will help ensure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards.

Recognizing multiple pathways is important for supporting workforce mobility and ensuring patient access to hearing and balance care across the Commonwealth. As someone who is new to the profession, I can see how this will directly negatively impact audiologists who are new to and currently working in the profession. This certification allows for an additional licensure pathway and recognition of Au.Ds who go above the required education needs and take pride in their career.  I believe this change will benefit both professionals and patients.

Thank you for your work to modernize and clarify audiology licensure regulations in Virginia. I appreciate the opportunity to comment on this amendment and encourage the Board to move forward with recognizing ABA certification as an accepted pathway to licensure.

Sincerely,

Allison Croushorn

Fauquier ENT Consultants

Warrenton, VA

Acroushorn1@gmail.com

Dear Members of the Board, 

I am Lorraine (Lori) Klein Gardner, a practicing audiologist and former owner of Hear Virginia, located in Richmond Virginia.  I have been a Virginia audiologist licensee for forty-eight years.  I write to expres my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure in the Commonwealth of Virginia.  

ABA certification is a nationally recognized credential that reflects eduycation, examination, and professional requirements specific to audiology.  When ABA certification was mistakenly removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists.  Restoring this pathway will insure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards.

Recognizing MULTIPLE pathways is important for supporting workforce mobility and ensuring patient access to hearing and balance care across the Commonwealth.  As someone who struggled to secure licensed audiologists at my (former) private practice, Hear Virginia, I personally experienced and seen delays in licensure limit career paths of young audiologists AND more importantly, impact (delay) needed patient care.  I believe this change will benefit both professionals and patients.

Thank you for your work to modernize and clarify audiology licensure regulations in Virginia.  I appreciate the opportunity to comment on this amendment and to encouarge the Board to mnove foward with recognizing ABA certification as an accepted pathway to licensure.  

Dear Members of the Board,

My name is Laurel Braverman and I am a practicing audiologist in Manassas, Virginia. I am writing to express my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure.

ABA certification is a nationally recognized credential that reflects education, examination, and professional requirements specific to audiology. When ABA certification was removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists. Restoring this pathway will help ensure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards.

Recognizing multiple pathways is important for supporting workforce mobility and ensuring patient access to hearing and balance care across the Commonwealth. As someone who currently maintains ABA certification and who works with underserved populations in Northern Virginia, I believe this change will benefit both professionals and patients.

Thank you for your work to modernize and clarify audiology licensure regulations in Virginia. I appreciate the opportunity to comment on this amendment and encourage the Board to move forward with recognizing ABA certification as an accepted pathway to licensure.

Sincerely,

Laurel Braverman, AuD
Thomas H. Rhee, MD, PC / Manassas Hearing Center
Manassas, VA
laurelbraverman@gmail.com

Dear Members of the Board,

My name is Amelia Shuster, and I am a clinical audiologist in Fairfax, Virginia. I am writing to express my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure.

ABA certification is a nationally recognized credential that reflects education, examination, and professional requirements specific to audiology. When ABA certification was removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists.  Restoring this pathway will help ensure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards.

Recognizing multiple pathways is important for supporting workforce mobility and ensuring patient access to hearing and balance care across the Commonwealth. Being located in Northern Virginia, our practice frequently hires audiologists who are moving to the area from out of state, or who have recently graduated from a doctoral program.  Having multiple pathways to obtain a Virginia audiology license helps audiologists make the transition to working in Virginia more quickly.  Removing the ABA certification as a pathway for licensure will lead to delays in audiologists being able to see patients, which means decreased productivity for the clinic and longer wait times for patients to receive care.  As someone who has weathered multiple staff turnovers, I believe that recognizing ABA certification will benefit both professionals and patients.

Thank you for your work to modernize and clarify audiology licensure regulations in Virginia. I appreciate the opportunity to comment on this amendment and encourage the Board to move forward with recognizing ABA certification as an accepted pathway to licensure.

Sincerely,
Amelia Shuster, AuD
Otolaryngology Associates
Fairfax, VA

Dear Members of the Board,

My name is Erin Piker and I am an audiology faculty member at James Madison University in Harrisonburg, Virginia. I am writing to express my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure.

ABA certification is a nationally recognized credential that reflects education, examination, and professional requirements specific to audiology. When ABA certification was removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists. Restoring this pathway will help ensure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards.

JMU is the only accredited AuD program in the Commonwealth and many of our students choose to stay in Virginia.  I feel it is important to not place licensure barriers on those wanting to practice in the Commonwealth. I believe this change will benefit both professionals and patients.

Thank you for your work to modernize and clarify audiology licensure regulations in Virginia. I appreciate the opportunity to comment on this amendment and encourage the Board to move forward with recognizing ABA certification as an accepted pathway to licensure.

Sincerely,

Erin G. Piker, AuD, PhD                                                        

Associate Professor  

Program Director of Audiology                                                          

Director, Vestibular Sciences Lab     

James Madison University

Department of Communication Sciences and Disorders

235 MLK Jr. Way, MSC 4304

Harrisonburg, VA   22802                              

540-568-3871                                                                        

February 6^th, 2026

VA Professional and Occupational Licensing Board of Audiology and Speech-Language Pathology

9960 Mayland Drive

Suite 300

Henrico, VA 23233

Re: Amendment of 18VAC30-21-60(A) to include American Board of Audiology certification as an accepted pathway for audiologists applying for licensure

Dear Members of the Board,

The American Academy of Audiology (the Academy) appreciates the opportunity to submit comments in support of amending 18VAC30-21-60(A) to include American Board of Audiology (ABA) certification as an accepted pathway for audiologists applying for licensure. The Academy is the largest professional organization of, by, and for audiologists and is dedicated to advancing quality hearing and balance care through professional development, education, research, and increased public awareness.

The amendment seeks the restoration of ABA certification in the licensure regulations as an alternative pathway to audiology licensure while maintaining rigorous professional standards. When ABA certification was removed from the regulations, the result was not increased flexibility, but rather the elimination of a recognized pathway, leaving applicants with effectively a single certification-based option for licensure. This narrowing of pathways makes it more difficult for qualified audiologists to become licensed in Virginia.

ABA certification is a nationally recognized credential that reflects comprehensive education, examination, and professional requirements specific to the practice of audiology. The ABA certification process is designed exclusively for audiologists and requires demonstration of advanced competencies, making it a highly rigorous and profession-specific credential. In many respects, ABA certification represents a more specialized and stringent standard for the practice of audiology than broader certification pathways that are not exclusively focused on audiology.

Virginia’s regulations already recognize certification as an expedited pathway to licensure, and if the Commonwealth recognizes the CCC, it should likewise recognize ABA certification. Explicitly restoring ABA certification alongside other accepted pathways would preserve applicant choice and accurately reflect the diverse, high-quality training routes within the audiology profession. Explicitly restoring ABA certification alongside other accepted pathways would preserve applicant choice, ensure recognition of a highly rigorous audiology-specific credential, and accurately reflect the diverse, high-quality training routes within the audiology profession.

Thank you for your consideration of this amendment and for your continued work to modernize and clarify audiology licensure in Virginia. The Academy appreciates the opportunity to provide input on this petition and looks forward to continued collaboration with the Board. If you have any questions regarding these comments, please contact Joanne Zurcher, Vice President of Government Relations, at jzurcher@audiology.org.

Sincerely,

David Zapala, PhD

President, American Academy of Audiology

Dear Members of the Board,

My name is Cheryl Wray, and I am a practicing audiologist with an ENT group and owner of a clinic in Courtland which is in southeastern, Virginia. I am writing to express my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure.

ABA certification is a nationally recognized credential that reflects education, examination, and professional requirements specific to audiology. When ABA certification was removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists. Restoring this pathway will help ensure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards.

Recognizing multiple pathways is important for supporting workforce mobility and ensuring patient access to hearing and balance care across the Commonwealth. As someone who works with underserved poplutations drawing in from rural areas, delays in licensure will certainly impact patient care. In this region there is a high shortage of audiologists. Putting further restrictions on their ability to begin work without further impedance is of a high importance. I believe this change will benefit both professionals and patients. The physicians I work for are struggling to find audiology help and unfortunately have had to rely on technicians. This does not help when higher levels of education are needed such as cochlear implants and bone implants. We are desperate and stretched thin as I travel from office to office for these duties.

Thank you for your work to amend and clarify audiology licensure regulations in Virginia. I appreciate the opportunity to comment on this amendment and encourage the Board to move forward with recognizing ABA certification as an accepted pathway to licensure.

Sincerely,

Cheryl Wray, Clinical Audiologist

TPMG ENT – Suffolk, Newport News and Williamsburg, VA

I am encouraging the board to reinstate ABA as an acceptable certification for licensure of audiologists in the Commonwealth of Virginia. As the Clinical Education Coordinator at JMU, I work with many individuals seeking initial licensure in the Commonwealth. I also receive requests from many potential employers seeking to hire audiologists. Omitting a well respected credential will make it harder for some audiologists to obtain licensure in Virginia. This is problematic because there is a significant shortage of audiologists in the state already. Both the ABA and CCC-A should be considered acceptable credentials when applying for licensure in the Commonwealth of Virginia. 

Dear Members of the Board,

My name is Anne Dare and I am a board-certified pediatric audiologist in Norfolk, Virginia. I am writing to express my support for the proposed amendment to 18VAC30-21-60(A) to restore American Board of Audiology (ABA) certification as an accepted pathway for audiology licensure.

ABA certification is a nationally recognized credential that reflects education, examination, and professional requirements specific to audiology. When ABA certification was removed from the regulations, it reduced flexibility and limited licensure options for qualified audiologists, including myself. Restoring this pathway will help ensure that Virginia can attract and retain highly trained audiologists while maintaining strong professional standards. I worked hard for my education and advanced credentials and would like to keep my skills in Virginia. 

Recognizing multiple pathways is important for supporting workforce mobility and ensuring patient access to hearing and balance care across the Commonwealth. As someone who is board certified in pediatric audiology and works with Virginia’s children to access diagnostic services, intervention and supports, this issue is very important to me. Children and individuals with special needs require unique and specialized professionals on their teams. Audiology is no different. Delays in licensure will reduce Virginian children's access to quality and competent care. It is well known that early intervention significantly decreased the long term costs associated with disability. Delays in licensure can delay a child's intervention. I absolutely believe that restoration of ABA certification as an avenue to Virginia licensure will benefit both professionals and patients. 

I qualified for board certification in pediatric audiology more than 12 years ago. This certification requires continued education beyond standard continuing education courses, and beyond the requirements of licensure alone. Maintaining this certification has ensured that I continue to learn as audiology - and pediatrics - evolves. I fear that should ABA not be restored on the pathway to Virginia licensure that southeastern Virginia will suffer drastically as a result. There are few pediatric audiologists in this area and a good portion of them carry ABA credentials. Please do not hurt Virginians. 

Thank you for your work to modernize and clarify audiology licensure regulations in Virginia. I appreciate the opportunity to comment on this amendment and encourage the Board to move forward with recognizing ABA certification as an accepted pathway to licensure.

Sincerely,

Anne Dare, AuD, ABAC, BCPA

Pediatric Audiologist

Macon & Joan Brock Virginia Health Sciences at Old Dominion University

Norfolk, VA

Kelli Moss

Executive Director

Virginia Board of Audiology and Speech Language Pathology

9960 Mayland Drive
Suite 300
Henrico, VA 23233

Via public comment

Re: Proposed Amendment of 18VAC30-21-60(A) to Add ABA Certification to Regulation Offering Expedited Pathway to Audiology Licensure

Dear Ms. Moss,

The Academy of Doctors of Audiology (ADA), a national association representing audiologists in Virginia and throughout the United States, appreciates the opportunity to submit comments regarding potential amendments to 18VAC30-21-60(A). While we understand that the proposed action to re-add American Board of Audiology (ABA) certification as an additional option to expedited audiology licensure, is well intended, there is a better solution.

Virginia regulations compelling either ASHA or ABA certification, as a condition of, or as a pathway to expedited audiology licensure, should be completely abolished. Licensing laws were established to provide important consumer protections and promote a culture of patient safety. They should not be used solely to benefit accrediting bodies and their parent trade associations at the expense of licensees and consumers.

ADA opposes the adoption of provisions reinstating ABA certification as a shortcut to audiology licensing in Virginia. ADA also opposes existing Virginia regulations that unfairly reward ASHA-certified audiologists with an expedited pathway to licensure.

State laws that require an audiologist to be certified by the American Speech-Language-Hearing Association (ASHA) or the American Board of Audiology (ABA), as either a condition for licensure, or as an easier pathway to licensure, coerce audiologists into paying high fees to subsidize the certifying bodies and their parent associations in exchange for a license to practice. This “certification tax” offers absolutely no benefit to the public. On the contrary, it unnecessarily increases the cost of services delivered. ASHA annual certification maintenance fees are $446[1] for non-member audiologists and ABA annual certification fees for non-members of the American Academy of Audiology (AAA), of which it is a wholly owned subsidiary are $225.[2]

State licensing laws governing audiology in Virginia already include rigorous academic and clinical standards, including, “documentation of graduation from a program accredited by the Council on Academic Accreditation of ASHA or an equivalent accrediting body recognized by the board.” If ASHA, and presumably the Accreditation Commission for Audiology Education (ACAE) under the American Academy of Audiology (AAA), are the only two accrediting bodies that meet this requirement, ASHA and AAA presumably are already ensuring that audiologists are licensure-qualified upon graduation from their academic training programs a Doctor of Audiology degree. It is redundant then to incentivize ASHA or AAA certification as an expedited pathway for initial licensure in the Commonwealth.

Both ASHA and ABA certification can be readily obtained by new graduate, entry-level audiologists. Neither certification embodies a meaningful board certification in the traditional sense, and both can be maintained merely by paying an annual fee and obtaining a certain number of continuing education credits, which often mirror what states, including Virginia, already independently require for licensure maintenance.

There are no data to support that Virginia audiologists holding ASHA and/or ABA certification have better clinical outcomes or enhanced performance in any way, compared with audiologists who do not hold those certifications. There is no evidence indicating enhanced clinical competence or improved patient outcomes as a result of carrying either certification.

ASHA unfairly ties its membership and certification by making it totally implausible for practicing clinical audiologists to hold ASHA membership without also purchasing its certification. ASHA’s Code of Ethics reads, “ASHA members who do not hold the Certificate of Clinical Competence may not engage in the provision of clinical services; however, individuals who are in the certification application process may provide clinical services consistent with current local and state laws and regulations and with ASHA certification requirements.”[3] Virginia’s state laws should not perpetuate ASHA’s tying scheme by requiring audiologists to become certified as a condition of or a means to obtain an expedited pathway to licensure.

ADA respectfully requests that regulators eliminate certification entirely from section 18VAC30-21-60(A) and abolish any other Virginia laws that favor certified audiologists and provide them an easier pathway to licensure. Audiology education and training requirements for licensure in Virginia already provide sufficient safeguards to protect consumers and to ensure that audiologists meet minimum standards for education, clinical experience, and ethical practice.

Please contact me anytime if you have any questions or require additional information. Thank you for your thoughtful consideration of this important issue.

Sincerely,

Stephanie

Stephanie Czuhaejwski, MPH, CAE

Executive Director

Email: sczuhajewski@audiologist.org

Mobile: (859) 321-1595