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Sycle Continuum of Care - December 2018

Who/What Makes a Qualified Audiologist?

Who/What Makes a Qualified Audiologist?
William D. Fitzgibbon
March 31, 2000
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What is a ''Qualified Audiologist''? At this time, even U.S. Government regulations don't agree. In 1994, the American Speech Language Hearing Association (ASHA) thought it a tremendous victory in defining who is a ''qualified audiologist''. This definition (1994 Medicare Regulation Defining ''Qualified Audiologist'': 42 U.S.C. 1395x 11-3-B) says that an audiologist is one who:

- holds a masters or doctoral degree in audiology
- is licensed in their state, or where state licensure doesn't exist, has 350 clock hours of supervised clinical practicum performed in no less than nine-months post-receipt of a masters or doctorate in audiology.

The current Medicaid definition (1969: June 24 Fed Reg.) (42 CFR 440.110(c)(2) states that a qualified audiologist is one who:

- has the certificate of clinical competence (CCC) from the ASHA
- has completed the educational requirements for the C's, and
- is acquiring supervised work experience to qualify for the C's.

Which is the best for us? Should we adhere to the Medicare definition which requires a state license, or should we use the current Medicaid definition, which requires the CCC-A (refered to hereafter as the ''C's'')?

In New York, I need my state license to practice. My C's are not required to practice audiology in the State of New York. However, Medicaid regulations insist that I be affiliated with a private organization (ASHA). This mandatory ''affiliation'' with ASHA calls for my paying an annual ''re-certification'' fee in order to be considered ''an ethical practitioner.'' In other words, if I don't pay the ''re-certification fee'' to ASHA, two things will happen:

1- I will be considered in violation of my ''code of ethics'' as per ASHA (subject to disciplinary sanctions), and,
2- Medicaid will not ''recognize'' me as a ''qualified audiologist.''

All this because I didn't pay my ''re-certification fee.'' In essence, I would be ''black-listed'' for not paying money to someone/something. Funny, but in my old neighborhood they used to call that ''extortion.'' The major difference here is this type of ''extortion'' is acceptable (per Medicaid's definition).

I have tried to understand why ASHA opposes the ''re-definition'' of the Medicaid regulation. My guess involves two key points: 1) Money and 2) Power.

The math is easy:

Regarding Money (point one above), 10,000 audiologists plus 90,000 Speech Language Pathologists (SLP's) x $120 (the re-certification portion of ASHA dues) = $12 million in annual income (that's a lot of ''re-certificates'' being issued).

Regarding Power (point two above), ASHA has been unsuccessful in many states in getting public schools to require the masters degree for SLP's as the entry level degree (essentially denying the C's as a requirement). Therefore, schools currently have the option of hiring Bachelor's (B.A./B.S.) level speech teachers. The foothold ASHA has is the (current) Medicaid law requires the C's for SLP providers. The schools can bill/receive Medicaid money only if services are supervised by an SLP who currently holds the C's. I believe ASHA does not want this law re-defined because ASHA will lose it's powerful grip on the SLP's in the schools. It appears that ASHA is opposing HR 1068, essentially to maintain their hold on the SLPs, at the expense of Audiology.

This Medicaid re-definition in HR 1068, which is supported by both the American Academy of Audiology (AAA) and the Academy of Dispensing Audiologists (ADA) would establish a consistent definition of our profession in federal law. The ''re-defining'' is already in federal law, all we ask is that the law be ''consistent.''

Other professions (optometrists, chiropractors, dentists, etc.) define their practitioners as those who hold (doctoral) degrees. They are not defined by a ''certificate'' process, but rather, they are defined by their state licenses.

Similarly, those in Limited License Practitioner categories, as defined in the Medicare statute (psychologists, nurse anesthetists, and others who can see patients autonomously) are defined in the only way that has legal meaning- their state license.

The U.S. Department of Labor compiles an ''Occupational Outlook Handbook which categorizes all professions and occupations. Recently, AAA requested audiologists be defined separately from SLP's and that audiologists be included in the ''Health Diagnosing'' Occupation category, along with physicians, optometrists, etc. The Dept. of Labor (DOL) created a separate category for audiologists, but categorized the profession in the ''Health Assessment and Treating Occupations'' in a ''Therapy'' sub-category.

AAA is currently petitioning the DOL to include audiology in the ''Health Diagnosing'' category. Success with the DOL will more accurately identify us as autonomous health professionals.

As the profession progresses toward doctoral level entry, our efforts at re-classification in the SOC Codes will be more likely to succeed. The Health Diagnosing category is made up of professionals which require all participants to hold the minimum of a doctoral degree to practice their profession.

AAA and ADA are also petitioning HCFA to add audiologists to the Medicare statutes list of ''Limited License Practitioners.'' If granted, this re-classification will likely allow audiologists to bill Medicare directly without physician referral. This will accomplish two very important things: 1) It will eliminate other professionals from acting as gate-keepers to our services, and 2) it will increase our reimbursement potential for provided services.

These efforts towards more accurate statutory and regulatory definitions of audiology will bring more independence and autonomy to our profession.

The question is (to me) clear: Do we want to define who we are and control our own destiny, or do we wish to remain second-class citizen health-care provides? The wrong decision at this time may take decades to correct.

Support HR 1068, and let audiology decide its own future.


William D. Fitzgibbon



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