The results have been that fewer, and fewer licensed specialists are willing to take the responsibility, and chance with their own licenses in order bring in new blood.
The evidence is quite clear at any of our conventions. One has only to look around, and estimate the average age in order to get the picture.
Replacing it, is an extremely rigid, three part process designed to take place over a six months period. Breaking the training down into three two month segments in which the exact things that an apprentice are allowed to do, and not do, are spelled out in precise detail. Including, exactly where the sponsoring specialist must be at the time.
Add to this rigidity, a further requirement ,that each and every candidate must complete a very specific home study course, available only through an affiliate of the International Hearing Society.
On top of that is an additional requirement for ongoing maintenance of the National Board Certification in Hearing Instrument Sciences, with it’s annual fees, and a picture begins to emerge of local, and international organizations with an agenda that clearly reaches beyond the realm of furthering professional standards, into one of supporting only it’s own methods, standards, and means, to the exclusion of all others.
Taken together with the regulations that put the licensee’s license in absolute jeopardy, for any transgression of an apprentice, regardless, of how they should handle such a transgression, and the results are, a dying profession.
When viewed in the further light of the Florida Board of Hearing Aid Specialist decision to disallow continuing education credits from Audiology online, when even their own parent, IHS recognizes these courses, it becomes clear that the regulations aren’t really about protecting the public’s interests, or even furthering good continuing education. But rather they have been written for the sole interests of certain of the regulated.
The idea that this Board, and these regulations are needed to protect the public is as preposterous at this point, as is there continuing overreach.
They do however view themselves, as being absolutely critical in the prevention of audiologists from taking over, and achieving “gatekeeper” status, either over the sale and distribution of hearing aids, or over the regulation of hearing aid dispensers.
Scrupulous care has been taken, and extensive lobbying goes on continuously, to make sure that the Board of Audiology, and the Board of Hearing Aid Specialists are separate, and that one has no control over the other profession.
Though they both dispense hearing aids, and both would very much like to control exactly how each other does that..
Now, let me make this clear, I am not against licensing, or competency exams, as a means of guaranteeing the public that should someone advertise themselves, as a hearing aid specialist, or audiologist, that those individuals should have demonstrated due knowledge, and proficiency in order to make such a claim.
Licensing provides the public with that assurance.
Beyond that, and at this point in Florida’s regulatory process, it is all about controlling access to hearing aids, who can buy them from whom, and under what circumstances.
However, dictating exactly the texts that must be studied, when those are only available from an IHS affiliate, and requiring an active BC/HIS in order to even qualify to apprentice someone, regardless, of your experience, training, or other credentialing, is clearly beyond the scope of protecting the public.
This regulatory activity lands squarely in the area of protecting the professional organizations and their business, or commercial interests, and is therefore outside of the regulatory pejorative, as specified and ignored in the authorizing statutes.
Not allowing any audiologist, or licensed hearing aid dispenser to train, and prepare their trainees in a manner they see fit, simply destroys the very concept of them as professionals. It substitutes instead a paternal, nanny state, and self serving organizational structure, that is in fact killing our profession.
The single most effective tool in the protection of the public from the unscrupulous hearing aid dispenser, or audiologist, regardless of their educational background, or credentialing, is the thirty day return privilege.
Very simply, in Florida, if the consumer isn’t satisfied with their hearing aids, or your services, they have a right to fire you, anytime within thirty days of delivery of their hearing aids.
The dispenser, or audiologist is then obligated, by law to return 95% of the purchase price of the hearing aids within thirty days. They are allowed to keep up to a $200 professional fee for a binaural fitting, or $150 for a monaural and up to a 5% restocking fee on the instruments themselves.
Failure to do so, constitutes a third degree felony in the State of Florida.
Therein, we have the single most effective consumer protection tool ever invented.
Give the consumer thirty days to decide. If, they are satisfied, of what interest at all is the transaction to the state?
If, they are not satisfied on the other hand, they need no Board, or regulatory apparatus from Tallahassee, in order to get effective redress.
As a felony, any sworn law enforcement officer is sworn to investigate. The local Sheriff, or Cop on the beat, is all the regulatory mechanism needed. The complaining consumer can get local, more, or less instant redress.
While on the other hand, any frivolous claims of failure to refund their money could just as easily be countered, by any honest dispenser with their paper trail. End of complaint, or start of prosecution, depending upon evidence easily produced by either, or both parties.
So, when seen in this light, we begin to see, that the entire structure of minimal required procedures, exacting training segments, only available from one source, and a requirement for ongoing membership in the BC/HIS, in order to even qualify, to apprentice someone, and it becomes ever increasingly clear, that these are regulations very much of, for, and, by the regulated few.
These regulations and this Board, are designed to give the illusion of protecting the public. But, they go far beyond that, to insisting on controlling the entire way of doing things.
From training new hires, through the entire delivery process. Which coincidentally involves their control over the hearing aid market, and most importantly their control over who can sell you a hearing aid.
Board examinations, even the strictest, are absolutely alright with me. I have no problem with demonstrating knowledge of subject, or requisite skill, in order to be, or even maintain a license.
What I object to, very much, is an incredible micro-management of my practice for nothing more than the appearance of protecting the public. Especially, when the public is being quite well protected by that most effective, and easiest to understand of regulations that requires, no further state involvement.
What I object to, is a Board, like Florida’s, that is owned by a Professional Society, who is owned by their lobbyist. A Board that fails to acknowledge the changes in our market, equipment, and consumers. A Board who insists on ever stricter regulations, that have nothing to do with aught but, the appearance of protecting the public, while actually protecting their own, commercial, and organizational interests, rather than, that of the very public that they were constituted to, and purport to protect.