- The Honorable Brett Guthrie
Chair
Committee on Energy and Commerce
United States House of Representatives
Washington, D.C. 20515 - The Honorable Jason Smith
Chair
Committee on Ways and Means
United States House of Representatives
Washington, D.C. 20515 - The Honorable Frank Pallone, Jr.
Ranking Member
Committee on Energy and Commerce
United States House of Representatives
Washington, D.C. 20515 - The Honorable Richard Neal
Ranking Member
Committee on Ways and Means
United States House of Representatives
Washington, D.C. 20515
Dear Chairman Guthrie, Chairman Smith, Ranking Member Pallone, and Ranking Member Neal:
On April 10, the Medicare Audiology Access Improvement Act (H.R. 2757), which would decrease the
quality of hearing healthcare for Medicare beneficiaries across the United States, was introduced and
referred to your committees for consideration. This legislation would significantly compromise patient
care by reclassifying audiologists as Medicare providers and expanding their scope of practice beyond
their educational training and clinical competencies, resulting in increased healthcare costs, potential
misdiagnosis of serious medical conditions, and undermining the physician-led, team-based approach that
ensures comprehensive care for our nation’s seniors. The undersigned groups strongly urge you to
oppose H.R. 2757.
We appreciate both committees’ ongoing dedication to patient safety and ensuring high-quality healthcare
for Medicare beneficiaries. As medical specialty societies, these are our areas of focus as well. H.R. 2757
would undermine these critical goals by removing the necessary physician oversight required in the
diagnosis and management of hearing loss among Medicare beneficiaries. Without a proper medical
assessment, reversible causes of hearing loss may go undetected or misdiagnosed, potentially leading to
permanent hearing damage. This legislation is not only detrimental to patient outcomes but would also
increase the financial burden on both individual beneficiaries and the Medicare program through
unnecessary treatments and avoidable complications that result from bypassing physician evaluation.
For example, audiologists are not trained to diagnose a patient with certain medical causes of hearing loss,
such as a tumor pressing on the vestibular nerve of the ear. They are also not adequately trained to
identify subtle signs of trauma or abnormalities, such as a perforated eardrum. Should patients receive
care from an audiologist before being medically evaluated by a physician, these severe causes of hearing
loss will go undiagnosed and untreated and will inadvertently cause further harm.
While audiologists are valued healthcare professionals who work for and with physicians, they do not
possess the medical training necessary to perform the same duties as physicians, nor can they provide
patients with the medical diagnosis and full spectrum of treatment options required. Audiologists are not
physicians and should not be treated as such under the Medicare program.
Granting nonphysician providers the ability to treat patients without physician referral will also drive up
costs. Studies have shown that nonphysician providers increase utilization of healthcare resources, require
longer consultations and more follow-ups, increase clinical staff time, order more tests, and have
poorer quality of referrals to specialists.
On the other hand, studies show that nonphysician providers deliver excellent quality care, when done
under the supervision of a physician. These positive outcomes prove the value of the physician-led,
healthcare team model.
Furthermore, surveys show 95% of patients want a physician involved in their diagnosis and treatment.
With eight years of formal education, a minimum five-year residency, and at least 15,000 hours of clinical
training, otolaryngologist-head and neck surgeons are the most qualified clinicians to diagnose and treat
ear, nose, and throat conditions—and are trained to lead a care team. A physician-led hearing healthcare
team, with coordination of services, is the best approach for providing the highest quality care to patients.
Despite claims that expanding the scope of practice for nonphysicians will address workforce shortages,
H.R. 2757 will not increase patient access, even in rural and underserved areas. Physicians and
nonphysicians tend to practice in the same areas, and these findings are confirmed by multiple studies,
including state workforce studies. States that have allowed nonphysician providers to operate with greater
autonomy have not seen an increase in access to care for their rural populations. Nonphysician providers
do not live and work in rural and underserved areas at higher rates than physicians. Even if the patient
safety and cost concerns were set aside, this legislation would still fail to deliver on its core promise of
enhancing access to care.
For these reasons, we strongly urge you to oppose any efforts to advance H.R. 2757. The physician-led
model of care remains essential for ensuring Medicare beneficiaries receive proper diagnosis, appropriate
treatment, and the highest standard of hearing healthcare. Thank you for your consideration, and if you
have any questions, please contact the American Academy of Otolaryngology–Head and Neck Surgery’s
Director of Advocacy, Harry DeCabo, at hdecabo@entnet.org or (703) 535-3695.
Sincerely,
National Organizations
American Academy of Otolaryngology – Head and Neck Surgery
Administrator Support Community for ENT (ASCENT)
American Academy of Facial Plastic and Reconstructive Surgery
American Academy of Otolaryngic Allergy
American Association of Child and Adolescent Psychiatry
American Association of Neurological Surgeons
American Association of Orthopaedic Surgeons
American College of Surgeons
…
Read full letter here with complete list of organizations.
