Health and Social Care Bill

Memorandum submitted by RNID (HS 05)

About us

RNID is the UK’s largest membership charity supporting people who are deaf or hard of hearing. We provide information, services and support; we fund and undertake medical, social and technological research; we work to influence policy and practice and campaign for improved services; and we raise public and professional awareness on the impact of hearing loss.

Introduction

This briefing sets out some key points relating to hearing loss in the following areas of the Health and Social Care Bill. We would encourage the Committee to seek clarification on these points with Ministers.

1. Summary

2. Commissioning

3. Information

4. Hearing loss as a public health issue

5. Integrated health and social care services

6. Standards

1. Summary

1.1 There are nine million people in the UK who are deaf or hard of hearing – one in seven of the population. Two million people in the UK use hearing aids, but a further four million people who could benefit from their use don’t currently have them. At present it takes people an average of ten years to receive a diagnosis of hearing loss [1] , in which time they can become isolated from the work place and from friends and family networks. This delay can also exacerbate other health conditions.

1.2 The prevalence of hearing loss increases with age. Over half (55%) of people over 60 have a hearing loss and 90% of patients over 81 [2] . The number of people with a hearing loss is increasing. The Medical Research Council estimates that the number of deaf and hard of hearing people is set to increase by about 14 per cent every ten years. This means that in 30 years time there will be more than 13 million people who are deaf or hard of hearing in the UK.

1.3 Hearing loss is a major public health issue which carries a serious impact on life quality, potentially leading to more complex mental health and social needs. It is vital that if audiology and hearing loss services are to be commissioned by local consortia that these groups have the necessary expertise, that information about audiology and hearing loss services and information on wider health and social care services is readily accessible to people with a hearing loss and that services are operated to a high standard.

2. Commissioning

2.1 Under the proposals put forward in the Bill, audiology and hearing loss services will be commissioned locally by GP Consortia. RNID is concerned that GPs have low awareness of the needs of people who are deaf or hard of hearing. Recent research shows that GPs fail to refer up to 45% of people [3] reporting hearing loss (for any intervention, such as referral for a hearing test or a hearing aid).

2.2 We therefore welcome the duty placed on the Commissioning Board in the Bill to obtain advice from persons with professional expertise relating to the physical or mental health of individuals (Clause 19, New Section 13G, page 17, line 17), and would like to clarify through committee stage what form this duty will take and confirm that they will take advice on all conditions, including hearing loss, and that this will then be passed on to all commissioning consortia.

2.3 We also welcome that this duty will also apply to each commissioning consortium (Clause 21, New Section 14O, page 30, line 32), particularly as audiology and hearing loss services will be commissioned at this local level. We would welcome clarification about whether receiving guidance from the Commissioning Board, in line with the point raised above, would constitute meeting this duty, or if consortia must take expert advice on the services they are commissioning on an individual basis.

2.4 Whilst we welcome these duties, we are unclear as to the impact of wording used earlier in the Bill (Clause 16(6), page 13, line 1 "The regulations may require the Board to consult prescribed persons before exercising any of its functions…") that regulations may, as opposed to must, require the Board to consult prescribed persons before exercising any of its functions. We would welcome clarification of the impact that this wording could have on the expertise that the Board seeks.

2.5 We would welcome clarification during committee stage of how detailed the guidance that will be published for commissioning consortia will be (Clause 22, New Section 14V(1), page 33, line 8), particularly in order to ascertain whether there will be published guidance on all conditions for which the consortia must commission services. Equally, we would welcome clarification of how meaningful the commissioning plan that each commissioning consortium must prepare before the start of each financial year will be. We would welcome clarification of how detailed these plans will have to be and whether they will go down to condition specific level (Clause 22, New Section 14Y(1), page 34, line 5).

3. Information

3.1 We welcome provisions in the Bill around the supply of information to people accessing health and social care services. We would urge the committee to explore the three issues of: ensuring that there is sufficient information available to people about audiology and hearing loss services; ensuring that information on wider NHS and social care services is accessible to people with a hearing loss; ensuring that health professionals are able to easily obtain and use information about a person’s hearing loss in order to help meet their needs.

3.2 Information about audiology and hearing loss services

Information is essential for people who are deaf or hard of hearing. When people are given more choice and information over the interventions they can receive such as being fitted with a hearing aid, attending lip reading classes or receiving hearing therapy, they are more likely to partake and benefit from these services.

3.3 High quality and accessible information is fundamental to addressing hearing loss needs and preventing a person’s hearing loss causing or exacerbating other health issues. Researchers have found that people who are deaf or hard of hearing can experience lower health-related quality of life, higher distress, anxiety, depression, social isolation and loneliness with negative implications on emotional, mental, and physical health [4] .

3.4 The appetite of people with hearing loss for this information is clear - in 2008 alone, over 300,000 printed pieces of information were handed out or posted out via events or help lines by RNID, over 250,000 leaflets were distributed to audiology clinics and pharmacies and 3.4 million visits were made to the information and resources section of our website [5] .

3.5 We are therefore concerned that a recent RNID survey showed that 4 out of 5 people (79%) [6] , when fitted with a hearing aid, received no information about other services or assistive technology, which might help to maximise their independence and wellbeing. We welcome that the Bill includes the provision of information and advice in the duty on local authorities and the Secretary of State to improve public health (Clause 8 (3(a)), page 5, line 11). We would welcome the committee exploring how Ministers envisage this duty being met, particularly in light of Government citing the voluntary sector as a potential information provider.

3.6 As a provider of specialist information, RNID expects an increase in the volume of information requests we receive. This service comes at a cost and it is essential that, if the reforms place voluntary sector organisations at the heart of information provision to help meet this duty, they are adequately resourced. Already, the Department of Health has decided not to fund further reprints of its booklet ‘How to use your hearing aid’. This content was developed by RNID, and we know patients and audiologists find it invaluable – the DH printed 75,000 last year and stocks are now below 30,000.

3.7 Information on wider NHS and social care services

Improvements in information provision for people with a hearing loss accessing wider health and social care services are essential to help reduce the inequalities that this group faces, and we therefore welcome provisions in the Bill to place a duty on various bodies, including commissioning consortia, to reduce these inequalities (Clause 19, New Section 13F(1), page 17, line 5 – the Board’s duty; Clause 22, New Section 14N(1), page 30, line 19 – the duty on individual consortiums).

3.8 Research shows that more than a quarter of patients with hearing loss have difficulty getting an appointment with their GP, where surgeries won’t book appointments by email, web or text. Of those patients who see their GP, a third are left unclear about the diagnosis after the visit because of communication difficulties [7] . Almost a third (30%) of British Sign Language (BSL) users avoid going to see their GP because of communication problems [8] . Research shows that 70% of BSL users admitted to A&E units were not provided with a BSL interpreter to enable them to communicate [9] .

3.9 Information regarding options for people with communication support requirements available on admittance to hospital would ensure that patients and service users are more adequately supported when stressed or anxious and accessing NHS services. Deaf awareness amongst staff is particularly important in acute settings. Healthcare staff also need to ensure that hearing aid users have well maintained and working hearing aids fitted at all times, and check regularly that patients can hear. With this in mind we would welcome clarification at committee stage as to how stringent these duties will be.

3.10 Information about a patient’s hearing loss

It is essential that a person with hearing loss receives any communication support that is necessary, from ensuring that staff are aware that they lipread to the provision BSL interpreter. We would like to see healthcare records prominently displaying a person’s communication requirements and any support they require by having this information electronically flagged for healthcare staff, including receptionists. In this manner the right provisions can be made in a timely way. We would therefore welcome clarification of this during examination of Clause 234, page 196, line 10.

4. Hearing loss as a public health issue

4.1 We welcome the example provided in the explanatory notes accompanying Clause 19, New Section 13F, page 17, line 4 of the Bill that reducing late presentation of conditions is a means to help reduce health inequalities. At present it takes people an average of ten years to receive a diagnosis of hearing loss [10] , a delay which can exacerbate other health conditions and lead to isolation from the work place and from friends and family networks.

4.2 The isolation that results from a hearing loss being allowed to develop, the withdrawal from accessing services such as a GP or pharmacist and the adaptation that people make in terms of avoiding communication with others, all lead to a reduction in the ability to access healthcare services when needed. We would like to ensure that conditions such as unaddressed hearing loss are not ignored as public health issues and that Ministers clarify how public health can be broadened out from traditional areas such as obesity and smoking cessation. This is particularly pressing with hearing loss as the Medical Research Council estimates that the number of deaf and hard of hearing people is set to increase by around 14 per cent every ten years.

5. Integrated health and social care services

5.1 We welcome provisions in the Bill to seek a better link up between health and social care providers through the duty placed on the National Commissioning Board in Clause 19, New Section 13J(1), page 17, line 40 and on Health and Wellbeing Boards in Clause 179, page 152, line 25. There are many services that people can be sign posted to once they have been diagnosed with a hearing loss and fitted with a hearing aid, such as community equipment to help them adapt their home to their hearing loss and to services such as RNID’s Hear to Help projects that help new hearing aid users learn basic maintenance and upkeep of the devices. However, we know that at present this signposting does not always take place, as a recent RNID survey showed that 4 out of 5 people (79%) [11] , when fitted with a hearing aid, received no information about other services or assistive technology, which might help to maximise their independence and wellbeing.

5.2 Whilst we welcome the provisions in the Bill that may facilitate this taking place, we would welcome Ministers clarifying how this will take place in practice, particularly in light of the prospect of non co-terminus boundaries between commissioning consortia and local authorities.

5.3 We welcome provisions in the Bill that Joint Strategic Needs Assessments will now have a wider scope to include future needs of the local population (Clause 176(3(c)), page 149, line 13). It is essential that these assessments take hearing loss into account – RNID looked at a small sample of these and found that at present they do not. We would like to see more robust national guidelines introduced so that they capture the needs of every person.

5.4 Two key factors – the current level of unaddressed hearing loss and demographic change leading to an ageing society - mean that the demand for audiology and hearing loss services will grow. There are four million people across the UK currently experiencing a hearing loss for which the use of hearing aids would be appropriate but who do not have them, and the Medical Research Council estimates that the number of deaf and hard of hearing people is set to increase by about 14 per cent every ten years.

5.6 We would welcome clarification during committee stage as to how future need will be assessed and the level of evidence that will be required to demonstrate a future need that must be taken into account.

6. Standards

6.1 The provisions in the Bill for the National Institute of Health and Care Excellence (NICE) to develop quality standards present an opportunity for robust quality standards that encompasses public health, clinical and social care interventions of hearing loss services, to the benefit of patients (Clause 218, page 189, line 28). We would welcome clarification of how broad these standards will be and to what degree they would be condition specific, and would also welcome examination of the term ‘may’ in this clause, as we are concerned that this could indicate that quality standards will be viewed with differing importance between commissioning consortia.

6.2 We also see the database of quality indicators that the Bill sets out as being produced by the Information Centre (Clause 248, page 203, line 23) as an excellent opportunity to ensure that audiology and hearing loss services operate to a high standard to the benefit of patients, and would again welcome clarification of how broad these indicators will be and to what degree they would be condition specific.

February 2011


[1] Davis, A. et al: ‘Acceptability, benefit and costs of early screening for hearing disability: a study of potential screening tests and models’ (Health Technology Assessment 2007; Vol. II: No. 42)

[2] Davis , A ‘Hearing in Adults’ 1995

[3] Ibid.

[4] See for example Nachtegaal, J., Smit, J.H., Smits, C., Bezemer, P.D., van Beek, J.H.M., Festen, J.M., Kramer, S.E. (2009). “The Association Between Hearing Status and Psychosocial Health Before the Age of 70 Years: Results From an Internet-Based National Survey on Hearing”, Ear & Hearing , June 2009 - Volume 30 - Issue 3 - pp 302-312.

[5] ‘RNID Information Review’ July 2010

[6] RNID: ‘Annual Survey Report 2008’ p3

[7] RNID ‘A Simple Cure’ 2004

[8] RNID ‘A Simple Cure’ 2004

[9] RNID ‘A Simple Cure’ 2004

[10] Davis, A. et al: ‘Acceptability, benefit and costs of early screening for hearing disability: a study of potential screening tests and models’ (Health Technology Assessment 2007; Vol. II: No. 42)

[11] RNID: ‘Annual Survey Report 2008’ p3