Submission For The Record of The American Speech-Language-Hearing Association
The American Speech-Language-Hearing Association (ASHA) appreciates the opportunity to submit a statement for the record regarding H.R. 3508, legislation that would allow for the appointment of hearing aid specialists to the Veterans Health Administration. While we understand the desire of Congress to ensure appropriate access to hearing health services, we believe that this legislation will not address the problems associated with long wait times for hearing aids and hearing health care services. Additionally we believe that the legislation could lead to fragmented care. For these reasons, ASHA opposes the legislation as currently written. ASHA is the national professional, scientific, and credentialing association for more than 173,070 audiologists, speech-language pathologists, speech, language, and hearing scientists, audiology and speech-language pathology support personnel, and students.
Unfortunately, as currently written the legislation may not have the desired outcome of decreasing wait times for veterans either seeking to obtain hearing aids or repairs. Hearing health care is more than fitting a veteran with a device. An audiologist must do a full diagnostic hearing evaluation and take into consideration health factors, such as tinnitus and brain injury, when determining appropriate amplification and audiologic rehabilitation for the patient.
Hearing loss and tinnitus are two of the top service-related disabilities of our nation’s veterans, and these disabilities require more complex and comprehensive treatment. Although we acknowledge that hearing aid specialists have the knowledge and skills to dispense hearing aids, many of our veterans, especially those with traumatic brain injury or tinnitus, require the specialized care of an audiologist.
The VA Office of Inspector General (OIG) recently released the finding of an audit of the VA’s hearing health services. The audit found that inadequate staffing to meet increased workloads as well as operations and processes at the Denver Acquisition and Logistics Center (where hearing aids are repaired) attributed to long wait times.
The OIG recommended that the VA develop a plan to implement productivity standards and staffing plans for audiology clinics. They also recommended that the repair center determine appropriate staffing levels for its rehab lab to establish controls to timely track and monitor hearing aid repairs.
The VA should have the ability to review its current policies and develop productivity standards and staffing plans as recommended by the OIG prior to the adoption of any legislation that would require changes to the provision of hearing health care services in the VA.
Additionally, in order to enhance hearing health care services to our veterans ASHA makes the following recommendations to the committee.
- Work with the VA to identify areas of the country where veterans have difficulty accessing hearing health services, and authorize additional funding to hire more audiologists and/or contract to private audiologists to meet the needs of the veterans in those areas.
- Request the VA to review data on wait times and access to hearing health care services and identify best practices by those facilities that have implemented ways to reduce wait times for services and devices and provide this information to lower performing facilities as a means to improve.
- Amend the Non-VA Purchased Care provisions of Title 38 to include audiologists.
- Grant the VA the authority to hire more audiologists.
Legislation Redundant Of Current VA Practices
The VA has the authority to hire hearing aid specialists as technicians that work under the direction of an audiologist. According to the VHA handbook 1170.02, the job description of the health technicians for audiology is to, among other things, increase productivity by reducing wait times and enhancing patient satisfaction; and reducing costs by enabling health technicians to perform tasks that do not require the professional skills of a licensed audiologist. The role of these technicians include performing checks on hearing aids and other amplification devices, performing troubleshooting and minor repairs to hearing aids, ear molds, and other amplification devices, and performing electroacoustic analysis of hearing aids, among other things. These responsibilities, which are already provided in the VA, are what hearing aid specialists are requesting to be recognized for under H.R. 3508.
Additionally, Appendix A of the VA handbook specifically addresses the use of hearing aid specialists and allows for referrals to these individuals when timely referrals to private audiologists and/or other VHA facilities are not feasible or when the medical status of the veteran prevents travel to a VHA facility or a private audiologist.
Given that hearing aid specialists are already permitted to be hired by the VA, we believe that H.R. 3508 adds an unnecessary mandate on the agency to specifically recognize hearing aid specialists for appointment by the Secretary.
Training and Education
Given the complex nature of a veteran’s hearing health care needs, veterans should have timely access to an audiologist. Audiologists are the primary licensed health care professionals who evaluate, diagnose, treat, and manage hearing loss and balance disorders. Audiologists hold a doctoral degree in audiology from a program accredited by the Council on Academic Accreditation in Audiology and Speech-Language Pathology of the American Speech-Language Hearing Association. Under the scope of practice for audiology, these individuals serve the veteran through a broad range of professional activities including evaluating, diagnosing, managing, and treating disorders of hearing, balance, tinnitus, and other disorders associated with the practice of audiology. This includes, determining the appropriateness of amplification devices and systems as well as selecting, evaluating, fitting and programming hearing aids.
Hearing aid specialists are trained in the interpretation of hearing assessment instrumentation, hearing aid electronics, specifications, analysis, modifications, and programming of hearing aids. While some states have gone to a college-level associate degree as a minimum education requirement for hearing aid dispensers, many states still require only a high school diploma or equivalent. There are no national standards or dedicated curriculum that outlines the core competencies of a hearing aid specialist. For example, in addition to the high school diploma or equivalent requirement, in the state of Wisconsin an individual must be 18, while in Minnesota they must be 21. Both licensure requirements require a test for proficiency. For more information and an analysis of each state’s hearing aid specialist (dispenser) requirements for licensure, see www.asha.org/advocacy/state/.
Additionally, we are unaware of any nationally recognized accreditation body for hearing aid specialists. We are aware of the International Institute for Hearing Instruments Studies. This organization is not on the list of recognized accrediting agencies by the U.S. Department of Education or the Council for Higher Education Accreditation (CHEA). This organization is also not listed as a member agency of the Association of Specialized and Professional Accreditors (ASPA). It appears the accreditation body is limited to continuing education courses and programs.
We appreciate the opportunity to express our concerns. ASHA remains committed to working with the Committee to address access to timely hearing health care services, but does not believe that H.R. 3508 is the solution. For additional information please contact Ingrida Lusis, ASHA’s director of federal and political advocacy, at firstname.lastname@example.org or 202-624-5951.