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