The current FTC Guides state that “endorsers qualifications must in fact give the endorser the expertise that the endorser is represented as possessing with respect to the endorsement.” The proposed modification of an illustrative example in the Guides implies that an endorser of a hearing aid should not be referred to as “Doctor” as this implies that the endorser is a medical doctor. The text goes on to note that “a non-medical doctor” (e.g., an individual with a Ph.D. in audiology) might be able to endorse the product if the advertisement discloses the nature and limits of the endorser’s experience.

The Academy comments highlight current educational training and scope of practice for audiology in all 50 states and references the 2022 Academy Position Statement that supports the use of the title “doctor” for members who have earned doctoral degrees from accredited institutions, with the provision that the audiologist provide clarification as to which field they hold their doctorate. The Academy letter requests that this illustrative example be amended to reflect this clarification.

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