Health and Social Care (Re-Committed) Bill

Memorandum Submitted by Action on Hearing Loss (HSR 13)

About us

1. Action on Hearing Loss (www.actiononhearingloss.org.uk) is the new name for RNID. We're the charity working for a world where hearing loss doesn't limit or label people, where tinnitus is silenced – and where people value and look after their hearing.

2. Hearing loss is a major public health issue affecting over 10 million people in the UK – one in six of the population. As our population ages this number is set to grow and by 2031 there will be more than 14.5 million people with hearing loss in the UK. Currently, only one in three people with hearing loss have accessed hearing aids, leaving four million people in the UK with unaddressed needs. Diagnosis of hearing loss is ad hoc and can take on average 10 years. Evidence suggests that GPs fail to refer up to 45% of people reporting hearing loss, for an intervention such as a referral for a hearing test or hearing aids [1] .


Summary
We would like clarified:

· How the duty to improve the quality of services will translate to an improvement of audiology services on a local level.

· How the duty to reduce inequalities will translate into a reduction in communication barriers for people with hearing loss accessing and benefiting from health services.

· How the duty to promote user involvement will translate into making all patient advocacy activities inclusive of and accessible to people with hearing loss.

· How the duty to obtain appropriate advice will translate to ensure that all commissioners observe best practice and quality standards when commissioning audiology services.

· How the duty to encourage integrated working will translate to ensure integration of services across the whole audiology pathway, including access to rehabilitation and follow-up services.

· How the wider scope of Joint Strategic Needs Assessments to include future needs of the local population will translate to respond to the fact that with an ageing population the demand for audiology and hearing loss services will grow. 

Duty as to improvement in quality of services

3. We welcome the provision in the Bill to place a duty on The Secretary of State and the Board and clinical commissioning groups to improve the quality of services [Part 1, Clause 2, 1A] [Part 1, Clause 19, 13D] [Part1, Clause 22, 14L]. In light of the ageing population, the numbers affected by hearing loss are projected to rise. Now is a crucial time to improve services, information and support for people who are deaf or hard of hearing. Promoting public health, providing early diagnosis and intervention, and supporting wider needs, also make economic sense as such strategies can help to prevent social isolation and improve employment outcomes.

4. Important developments have shaped services for people with hearing loss but there are still huge barriers to access. Currently, only one in three people with hearing loss have accessed hearing aids, leaving four million people in the UK with unaddressed needs. Diagnosis of hearing loss is ad hoc and can take on average 10 years. Evidence suggests that GPs fail to refer up to 45% of people reporting hearing loss, for an intervention such as a referral for a hearing test or hearing aids.

5. There is also a serious lack of integration between health and social care and vital rehabilitative services such as lipreading classes and hearing therapy are also at risk of closure or decline. Many people being diagnosed with hearing loss receive no signposting to community services that can improve their independence, health and wellbeing.

6. To improve quality of services we are calling on the government to: deliver more accessible and integrated services, closer to people’s homes; develop quality standards that take account of the whole pathway – linking public health, clinical and social needs; reclassify lipreading from a leisure activity to an essential communication skill, and rovide funding for classes all over the country, and ensure that hearing therapy is not lost.

7. We seek clarification on how the duty on the Secretary of State and Board to improve quality of services will be implemented locally by clinical commissioning groups.

Duty as to reducing inequalities

8. We welcome the duty on the Secretary of State and the Commissioning Board and clinical commissioning groups to reduce inequalities between patients with respect to their ability to access health services and the outcomes achieved for them by the provision of health services [Part 1, Clause 3, 1B] [Part1, Clause 19, 13F] [Part 1, Clause 22, 14N (a and b)]. We would welcome clarification as to how stringent these duties will be, and whether there will be a particular duty to reduce communication barriers for patients with hearing loss.

9. Currently, lack of deaf awareness amongst healthcare staff and limited access to communication support for people with hearing loss creates significant healthcare barriers, and service users with hearing loss do not enjoy equal access to and outcomes from NHS services.

10. Health services must commit to making services fully accessible to patients with hearing loss. This means ensuring appointments can be booked not just on the phone but by email, text or text-to-speech relay services, ensuring that staff are all fully deaf aware and providing timely access to interpreters where required.

11. 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 [2] . Almost a third (30%) of British Sign Language (BSL) users avoid going to see their GP because of communication problems [3] . Research shows that 70% of BSL users admitted to A&E units were not provided with a BSL interpreter to enable them to communicate [4] .

12. 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.

13. Reducing late presentation of conditions is also a means to help reduce health inequalities. At present it takes people an average of ten years to receive a diagnosis of hearing loss [5] , a delay which can exacerbate other health conditions and lead to isolation from the work place and from friends and family networks.

14. 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.

Duty as to promoting user involvement

15. We welcome the duty on the Board and clinical commissioning groups to promote the involvement of patients and their carers in decisions about the provision of health services to them [Part 1, Clause 19, 13L] [Part 1, Clause 22, 14N(c)] [Part 1, Clause 22, 14P] and the need to enable patients to make choices with respect to aspects of health services provided to them [Part 1, Clause 22, 14N(d)].

16. We encourage individuals to become local hearing loss champions and help shape the development and delivery of hearing services. We would like to ensure that all patient advocacy activities are inclusive of and accessible to people with hearing loss.

Duty as to obtain appropriate advice

17. We welcome the duty placed on the Board and clinical commissioning groups in the Bill to obtain advice from persons with professional expertise relating to the physical or mental health of individuals [Part 1, Clause 19, 13G] [Part 1, Clause 22, 14O] 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 advice gained by the Board will then be passed on to all clinical commissioning groups.

18. 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. If audiology and hearing loss services are to be commissioned by local groups, it is vital 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.

19. We are particularly 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 [6] reporting hearing loss for any intervention, such as referral for a hearing test or a hearing aid. This suggests that GPs would benefit from advice about the importance of early intervention in creating positive outcomes for people with hearing loss.

20. We welcome the introduction of clinical networks and clinical senates and would like to see hearing loss represented across both groups. We would like to see audiology and hearing loss champions sitting within every local authority, responsible for tracking relevant developments in technology, clinical procedures and models of service delivery, and for keeping clinical commissioning groups fully aware of these. We would also like to see some clinical commissioning groups becoming centres of excellence in specialised areas including audiology and hearing loss and the NHS Commissioning Board and clinical networks playing a fundamental role in identifying and disseminating good practice.

21. It is essential that the effectiveness of the audiology services that are commissioned by clinical commissioning groups is accurately measured. Action on Hearing Loss calls for agreed quality standards for audiology services that will apply to the any qualified provider model of services, and calls for NICE Quality Standards to reflect the needs and patient experiences of people with hearing loss and deafness.

22. With growing public spending constraints, we are concerned that audiology and hearing loss services will be assigned relatively low priority by commissioners, or that there will be active rationing through restrictive eligibility criteria (as has already been proposed by some PCTs). The national NHS Commissioning Board should ensure that rehabilitative services – which can have such positive effects on quality of life, activity, participation and independence, especially in later years – are not overlooked by clinical commissioning groups in favour of acute services that have more obvious and more easily measured short-term effects (for example, on mortality and morbidity) and that eligibility criteria for services are set at a universal level.

Duty to encourage integrated working

23. We welcome the duty placed on the Board in the Bill to seek more integrated working between clinical commissioning groups and local authorities in arranging for the provision of services [Part 1, Clause 19, 13J]. We would like to see a duty to ensure join up between health and social care services and providers in particular. We would welcome Ministers clarifying how this duty will take place in practice on a local level.

24. There are many services that people can be signposted 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 our Hear to Help projects that help new hearing aid users learn basic maintenance and upkeep of the devices. Lipreading classes help people with hearing loss to maximise communication, build confidence and increase their independence.

25. However, we know that at present this signposting does not always take place, as a recent survey showed that 4 out of 5 people (79%) [7] , when fitted with a hearing aid, received no information about other services or assistive technology, which might help to maximise their independence and wellbeing.

26. We would like to see a duty on local service commissioners and providers to develop hearing loss strategies and plans in partnership with local health, social and voluntary organisations and people with hearing loss, and to promote innovation and integration of services across the whole pathway, including access to rehabilitation and follow-up services.

Joint Strategic Needs Assessments

27. 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 [Part 5, Clause 189, 3(c)]. It is essential that these assessments take hearing loss into account.

28. 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.

29. Hearing loss is a major public health issue affecting over 10 million people in the UK – one in six of the population. As our population ages this number is set to grow and by 2031 there will be more than 14.5 million people with hearing loss in the UK.

30. Although it is clearly a public health issue that demands action, hearing loss is not currently on the public health agenda. We are calling for hearing loss to be put on the public health agenda of Public Health England, Health and Wellbeing boards, Joint Strategic Needs Assessments (JSNAS) and Joint Health and Wellbeing Strategies. We are also calling for JSNAs to be refreshed to recognise and tackle the high levels of unmet need around hearing loss.

31. Making population assessments around hearing loss is complicated by the current levels of unmet need. Issues of stigma and inbuilt barriers to services mean that one in three people who could benefit from hearing aids currently do not use them.

32. JSNAs should therefore recognise the need for accessible services that would encourage those with hearing loss to access hearing checks and hearing aids. JSNAs also need to account for those with hearing aids who may need to receive ongoing social support to ensure hearing aids are fully utilised. This could be through services such as our Hear to Help, as well as lipreading classes and hearing therapy to help maintain communication skills, independence and wellbeing.

33. We recommend that JSNAs are refreshed to help tackle the high levels of unmet need around hearing loss and to promote prevention, early intervention, and ongoing social support for people with hearing loss.

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

June 2011

Annex

· Hearing loss is a major public health issue affecting over 10 million people in the UK – one in six of the population. As our population ages this number is set to grow and by 2031 there will be more than 14.5 million people with hearing loss in the UK.

· There are two million people in the UK who use hearing aids, but a further four million people who could benefit from their use but don’t currently have them.

· Over half (55%) of people over 60 have a hearing loss and 90% of patients over 81 [8] .

· On average, there is a 10-year delay in people seeking help with their hearing loss [9] , 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.

· Diagnosis of hearing loss in adults is opportunistic and ad hoc.

· Evidence suggests that GPs fail to refer up to 45% of people reporting hearing loss, for an intervention such as a referral for a hearing test or hearing aids

· There is a lack of integration between health and social care for hearing loss.

· Poor access to health services for people with hearing loss causes health inequalities in terms of access to, and outcomes from NHS services.

· Hearing loss can impact on health, wellbeing and employment.


[1] Action on Hearing Loss ‘Hearing Matters’ 2011

[2] RNID ‘A Simple Cure’ 2004

[3] RNID ‘A Simple Cure’ 2004

[4] RNID ‘A Simple Cure’ 2004

[5] 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)

[6] Ibid.

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

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

[9] 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)

Prepared 30th June 2011