Legislative issues

Letter to Editor of the Echo Press of Alexandria
from MHHP President Gregory D Wales, BC-HIS
Letter to Editor of Alexandria, Mn newspaper ECHO PRESS from MHHP President Gregory D Wales, BC-HIS

When Kathleen Cota, acting director Health Care Purchasing and Service Delivery Division, Minnesota Department of Human Services, St. Paul, MN Made such obviously incorrect statements about a bill being proposed by the members of the Minnesota Hearing Aid Society, I knew, as it's President, the record had to be set straight.


Since the incorrect statements were made by such a prestigous personality, a mere Letter to the Editor from a local hearing instrument specialist wouldn't be able to explain the error.


For this reason I have purchased the necessary space nearby in this newspaper to present, as clearly as I can, how ill-advised Kathleen Cota's statements are. Some of the supporting material is only available by internet and those with internet access should read all they can. (You will notice, there is a lot of good information about hearing healthcare in these sites. Anyone experiencing signs of hearing loss will appreciate them.) To be as meaningfull as possible, Kathleen Cota's Letter to the Editor has been completely presented with our corrections, paragraph by paragraph.


We let the reader draw their own conclusion. How can this be so incorrect? Why? Are some of our government officials that far out of touch?


Shouldn't the Minnesota Department of Human Services at least respect the qualifications of professions Certified by the Minnesota Department of Health?


The most serious consequence of continued present DHS policy is it creates an artificial shortage of Hearing Healthcare Providers in a rapidly growing demand environment. The average family with a hearing loss is forced to endure problems longer than necessary.


Recent studies by the VA and National Council On The Aging show unattended hearing loss results in poorer health to all the members of the family compared to their counterparts whose family member is attended. One might conclude Medicare might even save money by funding hearing instruments for all who needed them.


Gregory D Wales, BC-HIS
Pres. MHHP









Dear Editor,
Please accept and print this official reply to Ms. Cota's Letter to the Editor.

Note: Internet urls are provided for the benefit of readers with internet access wanting to see documentation of issues discussed.



This first link is the original article, which appeared in the News section of the local paper.
Echo Press



The second link is a reply to the original article which appeared in the Letters to the Editor.
Echo Press

Gregory Wales' rejoinder to Kathleen Cota' reply.

http://www.echopress.com/article.cfm?Article_Id=19513


The following portion is a reply, paragraph by paragraph, to Ms. Cota's response.

URLs to related scientific study results that contain documentation supporting MHHP's position are listed at bottom of page.


Gregory D Wales, BC-HIS
MHHP President







Note: Red Italics are added Commentary
Hearing aid rules protect MA consumers



(This title and the contents of the article at least imply that the reason Minnesota's Department of Human Services does not allow Medical Assistance Recipient's hearing to be evaluated for the purpose of selecting and fitting hearing aids by Minnesota Department of Health Certified non-Audiologist Hearing Instrument Dispensers is to protect them from Minnesota Department of Health Certified non-Audiologist Hearing Instrument Dispensers. (It also indirectly implies that everyone with a hearing loss needs protection from Minnesota Department of Health Certified Hearing Instrument Dispensers who are not Audiologists)


Friday, 9/27/02



To the editor:


As the recent news article "Hearing aid dispenser seeks change in law that discriminates," (September 6 Echo Press) illustrated, Minnesotans are fortunate to have a number of dedicated, state certified hearing instrument dispensers who assist people with hearing losses.

(This paragraph has a false premise. It says the article of Sept 6 illustrates that "Minnesotans are fortunate to have a number of dedicated, state certified hearing instrument dispensers who assist people with hearing losses." The article said exactly the opposite. It said "Despite the growing number of people requiring hearing aids in the state, the number of professionals who serve them is lower today than it was 10 years ago, Wales noted." The opening paragraph of the Sept 6 article pointed to the shortage of state Certified Hearing Instrument Dispensers caring for The hearing impaired with the words "Gregory Wales of Brandon is seeking a change in a law that he says discriminates against 147 of the total 348 professionals who dispense hearing aids statewide.) The Sept 6 article goes on to explain exactly how the 147 non-Audiologist MDH certified HIDs and their patients are discriminated against with current DHS policy.)



The article, however, left out important information about how certain state consumer protection rules are in place for people with a hearing loss who are enrolled in the state Medical Assistance, or Medicaid program.



For Minnesotans enrolled in MA (a state-and federal-funded health coverage program for low-income people), we want to ensure that their hearing loss is properly diagnosed and that they receive appropriate treatment. The treatment may or may not involve a hearing aid.



(Once again, if this is the rational of present DHS policy, it assumes MDH Certified non-Audiologist HIDs are the wrong people to be evaluating hearing for the purpose of selecting and fitting hearing aids. The DHS policy makers ignore the fact that the written and practical portion of the MDH HID Certification Exam cannot be passed without a passing score in the audiometry portion of the exam. (This portion of the exam, as well as all portions, are regularly reviewed and approved by Audiologists on the MDH Hearing Instrument Advisory Committee.) All state Certified HIDs, whether Audiologists or not, must demonstrate competence in administering audiometric measurements (measurements obtained using an audiometer) in order to be Certified. The protocol of hearing evaluation to be performed by MDH certified HIDs is spelled out in state law.



There are a number of "red flags" that all HIDs are required to identify when present. By law, when any of these red flags are identified the HID must refer the patient to a physician, preferably a physician who specializes in diseases of the ear before fitting with hearing instruments. )



This is why state and federal regulations provide that an enrollee be examined by an audiologist before a hearing aid is prescribed. This is important for the many enrollees who are nursing home residents and may have cognitive impairments. Minnesota’s four neighboring states have similar or stricter requirements and do not pay hearing aid dispensers to perform audiologic evaluations.

(The word "audiologic" is misleading here. Since only audiologists can perform audiology, only audiologists can do audiologic evaluations. The reader assumes "audiologic" and "audiometric" are interchangeable. Some people have been unaware of the significance of this error. The tests Minnesota law requires performed by an Audiologist HID using an audiometer are no different than those required by a non-Audiologist HID using an audiometer. They are both properly referred to as "audiometric evaluations". The difference is, the audiologists claim exclusive right to calling their's an "audiologic evaluation". And perhaps rightly so. But when "audiologic" is allowed in laws where the word "audiometric" should be used, all non-Audiologist HIDs may be excluded. First sentence unfounded as previous paragraph explained. Second sentence is not a logical conclusion as first sentence is unfounded. Furthermore, non-MA nursing home residents and those with cognitive impairments have historically and are still presently being sucessfully audiometricly evaluated and either referred or fit with proper hearing instruments by non-Audiologist HIDs.



The last sentence implies that Minnesota's neighboring states are the same as Minnesota in this regard. It says, "do not pay". It doesn't say that these states are like Minnesota and do not recognize the audometric evaluation of MA recipients by non-audiologist HIDs, it says it doesn't pay non-audiologist HIDs for performing the evaluations. Wisconsin, for example, does recognize the non-audiologist HID's audiometric evaluations on MA patients. However, they currently won't re-emburse non-audiologist HIDs for providing audiometric evaluations.)



Although Illinois allows hearing aid dispensers to perform two basic hearing aid assessments, the state requires that an audiologist perform all other audiologic assessments for their Medicaid enrollees.



(The phrase, "two basic hearing aid assessments", is inaccurate and misleading. The required audiometric evaluation required by all Illinois HIDs, Audiologist or non-Audiologist, are similar to the battery of tests outlined in the Minnesota law. In Illinois, MA recipients with hearing loss are audiometricly evaluated and fit with hearing aids by non-Audiologist HIDs and re-embursed for the same with MA funds at the same re-embursement rates as Audiologist HIDS. Audiologist HIDs in all states may perform numerous tests that are not part of the required hearing evaluation for the purpose of selecting and fitting hearing instruments. They may also submit bills for these additional tests and be re-embursed with MA funds for providing the tests. Non-Audiologists are not permitted to do the same.)



About 135 independent audiologists are available to serve people enrolled in Minnesota Health Care Programs and a large number of physician clinics across the state provide audiology and otolaryngology services.




(At last count, there are 201 Audiologist HIDs in Minnesota. Not all of them accept MA patients. Clinics do not dispense hearing aids, HIDs do. The number of HIDs in Minnesota today is lower than it was ten years ago. There is an increasing number of potential hearing aid users. The ratio of the number of HIDs available to dispense hearing aids to the number of those needing their services in Minnesota is lower today than it was ten years ago.)



Our consumer service representatives can also assist enrollees to find audiology services close to home.



(Alexandria does not have, nor has it ever had, a full-time Audiologist. The closest are in Fergus Falls and St. Cloud. Audiologists do come to the Alexandria Clinic and Ambulatory Services Section of Douglas Co. Hospital on some days of the week but are not available full time to provide audiometric evaluations or to fit and service hearing instruments. However, Alexandria does have full-time non-Audiologist HIDs.)

As the administrator of the MA program, the Department of Human Services wants to ensure that low-income Minnesotans receive quality health at the most reasonable price. We believe that our state health care providers share this goal and will continue to work with us to do so.



(The number of MA recipients requiring hearing instruments is increasing and the number of those deemed eligible to provide audiometric evaluations is decreasing. The demand is increasing and the supply is decreasing. When demand increases and supply decreases, prices go up. If DHS really wants to provide "quality health at the most reasonable price" they won't continue defending the present policy whicht reduces access and increases costs. Many Hearing Healthcare Providers, both Audiologist and non-Audiologist, have opted out of participating in the MA program because DHS policies are considered unfavorable. For this reason, the shrinking pool of Hearing Healthcare Providers serving MA recipients is even smaller. Those of us still participating in the MA program may share the above stated goal but we don't agree with DHS's means to achieve the goal. Therefore our proposed legislation.)



Kathleen Cota,
acting director Health Care Purchasing and Service Delivery Division,
Minnesota Department of Human Services, St. Paul, MN







Links to the following sites provide more information
on the benefits of utilizing hearing instruments.



Both quality of life and better health of hearing impaired
and their spouses is documented.



See specificially NCOA (National Council On Aging)
and VA (Veterans Administration) study.




http://www.hearusa.com/



http://www.nih.gov/news/pr/oct2000/nidcd-10.htm

Links to websites containing statement
of AAA (American Academy of Audiology) to FDA illustrating:



1. AAA insist Audiologists be gatekeepers to hearing instrument (aid) use in the country.



2. The hearing evaluation AAA recommends needed prior to hearing instrument fitting is less inclusive than the hearing evaulation Mn Department of Health currently requires of their Certified Hearing Instrument Dispensers.




www.audiology.org/professional/atoday/12-5/washwatch.php




www.revisor.leg.state.mn.us/stats/153A/14.html



This link illustrates the benefits to hearing impaired of existing federal requirements that all Hearing Instrument Dispensers ( Audiologist and non-Audiologist) must adher too.