Hearing Healthcare Providers California
One Capitol Mall, Suite 320
Sacramento, CA 95814
Phone (916) 447-1975
Fax (916) 444-7462
Friday, April 25, 2014
Ms. Breanne Humphreys
Interim Executive Officer, Speech-Language Pathology & Audiology & Hearing Aid Dispensers Board
2005 Evergreen Street, Suite 2100
Sacramento, CA 95815
RE: Draft regulations regarding Audiology Aids
Dear Ms. Humphreys:
The Hearing Healthcare Providers California (hereafter; HHP) respectfully submits comments to the Speech-Language Pathology & Audiology & Hearing Aid Dispensers Board (hereafter; the Board) regarding your draft regulations that would make changes to an audiology aide’s supervision and duties. We greatly appreciate the opportunity to comment on these important proposed changes. HHP is professional association representing the Hearing Instrument Specialists throughout California. Our members test hearing and select, fit, and dispense hearing instruments. Our mission is to enable effective treatment alternatives for hearing impaired Californians and enhance our professional development. In conjunction with our redline edits in the other attached document, the following points reflect our concerns as to the proposed regulations.
Section 1399.154. Definitions. Current language in the California Code of Regulations pertaining to definitions of audiology aides in Section (b) (1) reads: “assists or facilitates while an audiologist is evaluating the hearing of individuals and/or is treating individuals with hearing disorders…” Yet the draft regulations appear to expand that definition and were not redlined in the same manner as the rest of the proposed changes. It appears that this definition expands the explanation of duties performed by an audiologist that an aide can assist with or facilitate. This definition would now include evaluation of vestibular function and/or treating individuals with balance disorders.
Our members are concerned that although as hearing aid dispensers who do not test vestibular or balance issues, allowing an aide to assist in those activities raises consumer protection concerns. If the duty were allowed, it might be used as an example in the future to expand duties to include dispensing activities, to which our members would object. As such, we request clarification on this language as it is not in current regulation but was not included in the Board’s redline edits.
Section 1399.154.25. Responsibilities of Audiology Aide’s Supervisor. Our members request the addition in (c) of the phrase “Be physically present while the audiology aide is assisting with patients, unless an alternative treatment plan has been approved by the board, and provide…” This is consistent with standing regulations, included in the speech-language pathology aide supervision. It should be included here as well.
Section 1399.154.8. Activities, Duties, and Functions Outside the Scope of Responsibility of an Audiology Aide.Current item 10 should be more elaborately defined, and our addition of 11 addresses our concern. A simple prohibition of fitting or selling hearing aids by an audiology aid does not go far enough. Per our membership, there are many more activities leading up to the fitting and selling of a hearing aid, like taking of ear impressions, adjusting or modifying a hearing aid or ear mold, among other things. Those activities require a dispenser license or dispenser trainee license as consumer protections, and these regulations should be modified to reflect these protections. We request that you include (11) as part of our redline edits in the regulations to read “An audiology aide may not perform any of the following functions: Anyactivities that require either a hearing aid dispensing license or a trainee license without first obtaining one.” The other prohibited functions would then be subsequently renumbered.
Once again, thank you for the opportunity to comment on these proposed regulations. For any further questions, please contact HHP Legislative Advocates Bryce Docherty or Vanessa Cajina at KP Public Affairs at (916) 448-2162 or or .
Sincerely,
Don Tucker
President