Comment from Best-McWain, Susan, KY DDS

The following comments are submitted on behalf of the KYDDS: In general, we feel that the proposed changes are positive, especially the removal of the aided testing and also the addition of guidelines for evaluating claimants with cochlear implants. The part about the otologic exam within two months of the audiogram is somewhat confusing, in that later on it is stated that an otoscopic exam must be done immediately before the audiogram to ensure that there is not a medical reason that testing would be invalid. We understand the otologic exam is to establish the impairment while the otoscopic exam is just to rule out something that would invalidate testing. We do have a question: While it is mentioned that tools like the OAE can be used to determine an impairment is not severe, we wonder if we could use a pure tone screen by an SLP in the same way.