A Message to Wisconsin’s Medical Community

Before addressing specific concerns, it helps to be precise about what the Wisconsin Audiology Modernization Act does and does not do.

As you know, congenital CMV (cCMV) is the leading non-genetic cause of childhood hearing loss in the United States. When an infant fails a newborn hearing screen and cCMV is suspected, there is a strict 21-day window during which antiviral treatment can meaningfully protect that child’s hearing and neurological development.

“Audiologists aren’t trained to interpret lab results or imaging.”

We agree — and that’s exactly why the bill prohibits it.

The amended language explicitly removes interpretation authority. An audiologist ordering a cCMV bloodwork panel is no different from a nurse practitioner ordering a referral panel — the order initiates the workflow. The interpreting physician remains the interpreting physician. Nothing in this bill changes that relationship.

The concern about “unrestricted test ordering” applied to an earlier draft. The Substitute Amendment directly addresses it by tying ordering authority to audiology-specific clinical indications. This is not a loophole — it is the point.

“This crosses the line into practicing medicine.”

Diagnosing hearing loss, auditory processing disorders, and vestibular dysfunction is audiology. It has always been audiology. The Au.D. is a four-year clinical doctoral degree accredited by ACA & ACAE, with graduate-level coursework in anatomy, neuroanatomy, pharmacology, and pathophysiology — not as electives, but as accreditation requirements.

Updating the statutory definition to include “diagnosis, management, and treatment” does not grant audiologists the authority to manage diabetes or order cardiac workups. It aligns Wisconsin law with what a Doctor of Audiology is already trained and licensed to do within the auditory and vestibular system.

“This crosses the line into practicing medicine.”

Diagnosing hearing loss, auditory processing disorders, and vestibular dysfunction is audiology. It has always been audiology. The Au.D. is a four-year clinical doctoral degree accredited by ACA & ACAE, with graduate-level coursework in anatomy, neuroanatomy, pharmacology, and pathophysiology — not as electives, but as accreditation requirements.

Updating the statutory definition to include “diagnosis, management, and treatment” does not grant audiologists the authority to manage diabetes or order cardiac workups. It aligns Wisconsin law with what a Doctor of Audiology is already trained and licensed to do within the auditory and vestibular system.

“Who is liable if an audiologist orders a test?”

The audiologist is. This is not ambiguous under existing Wisconsin medical liability law. When an audiologist places an order, they are the ordering clinician of record. The referring or interpreting physician carries no liability for the order itself — only for their own clinical actions downstream.

This concern may reflect genuine unfamiliarity with how mid-level and doctoral-level ordering authority works in practice. It is the same framework under which nurse practitioners, physician assistants, and optometrists operate — all of whom order labs and imaging in Wisconsin without creating the physician liability exposure MCW described.

“Foreign body removal is dangerous without procedural complication training.”

Cerumen removal and hearing aid dome removal are already within audiology’s established scope of practice. The Wisconsin Audiology Modernization Act codifies these existing procedures into statute to remove legal ambiguity — it does not create a new procedural category or expand into unfamiliar clinical territory.

The bill includes an explicit statutory limit. Foreign body removal is restricted to cases that are not impacted to the point that removal requires anesthesia. This is not a policy position or a professional promise — it is written directly into the bill text. Any case that crosses that clinical threshold is, by law, referred to a physician. The anesthesia boundary functions as a built-in, non-negotiable referral trigger.

The training argument does not hold up against Wisconsin’s own curriculum. UW-Madison’s Doctor of Audiology program — accredited by the Council on Academic Accreditation in Audiology and Speech-Language Pathology — includes CS&D 857: Laboratory in Amplification Systems I, a formal, credit-bearing laboratory course that explicitly covers proper cerumen removal technique. This is not an elective, and it is not a passing mention in a lecture. It is a graded, hands-on lab course completed by every Au.D. student before they ever see a patient in a clinical setting. The training exists. It is documented in the public course catalog. It is being taught right now, in Wisconsin.

Wisconsin’s physicians and Wisconsin’s audiologists serve the same patients. In a state where rural hearing healthcare access is already strained, patients in communities without nearby ENT coverage are the ones paying the price — in double co-pays, in months-long wait times, and in missed 21-day diagnostic windows for congenital CMV.

We are not trying to replace otolaryngologists. We are trying to stop sending patients on a referral loop that delays the care you would also want them to receive faster.

If you have questions about specific bill language, clinical training standards, or want to discuss the amended provisions before the next session, WAA’s Legislative Committee welcomes that conversation.