The VSHAS supports proposed changes to the hearing aid specialist temporary permit process.  We also encourage  aceptance of new Dept of Labor apprenticeship for hearing aid specialist as another option to enter this career. Teresa Robinson, Vice President VSHAS

Having held audiology and hearing aid specialist licenses in Virginia for 40+ years, and currently the director and a clinical provider at 2 practices with 7 audiologists who are also licensed as hearing aid specialists, I welcome the opportunity to comment on the “Amendment to Expand Training Options for Applicants” for the Hearing Specialist license.

I fully support the need for amending the training period for these specialists. 

1) I agree:  The evidence from board exam statistics demonstrates the failure rate is too high for non-college or non-university-trained applicants, probably due to too little time spent in training prior to the exam and also lack of thoroughness of training prior to examination.    

2) I agree: The additional option of obtaining hearing aid fitter training through an independent formal apprenticeship with the Department of Labor and Industry would appear to be a more standardize method for assuring competency and should hopefully reduce the exam failure rate.  (18VAC80-20-30 A.4.c.) 

3) I agree: The change to 18-months maximum one-time Temporary Permit period, (instead of the current 12-months with a possible 6-month extension) is desirable because it will reduce the Board’s clerical time and expense in constant renewing of Temporary permits. (18VAC80-20-40 A1)

4.) I DO NOT agree: That ALL “temporary permit holders should not be eligible for the examination until they have completed their ninth month of training under their temporary permit.”   (18VAC80-20-40 A.3. Temporary Permit)

Perhaps the intent of the drafters of this document was to require that only those temporary permit holders who were being trained under a sponsor would not be eligible until 9 months of training was completed as stated in:(18VAC80-20-40 C.5. Temporary Permit).  However, the paragraph A.3 as mentioned above seems to require that ALL Temporary Permit Holders would have to wait 9 months before taking the examination. (i.e. those with sponsors, those with university training, and those with DOL apprenticeship completion). 

I am not sure whether the 9-months is appropriate for those qualifying by (18VAC80-20-30 A.4.c.) apprenticeship program, but I am sure that the 9-month delay between application for a temporary permit and applying to take the exam is NOT necessary for those permit holders who have qualified through “courses completed (and documented) at an accredited college or university” demonstrating “required experience and training” included in this law A.3 a. – p. 

Therefore, I submit that this draft be re-worded in (18VAC80-20-30 -.TEMPORARY PERMIT SECTION A.3.  to exempt the above-mentioned “college and university-trained” applicants from the 9-month examination delay after receipt of Temporary Permit.

Over the years, when we have found the need for additional audiologist/ hearing aid fitter staff, we have always required that these audiology interns (with 3 years of graduate audiology/hearing aid didactic and practicum training) immediately apply for the hearing aid specialist board temporary licensure, and then immediately apply to take the next available written and practicum Hearing Aid Board exams. I would not want intern to wait to experience this exam and be delayed in receiving their full licensure until 9 months into their 12-month internship year. 

5.)  One additional small note:  There needs to be an “or” inserted at the end of (18VAC80-2030- Basic qualifications’’’ -A. 4. b.) to indicate that either a. or b. “or” c. is the required training.  Not a. or (b and c.).  as it appears at first glance in reading without the “or” at the end of b.

Thank you for your consideration.  

Danny W. Gnewikow, Ph.D. Audiologist, CCC & Hearing Aid Specialist