NOV 2024: Australia’s State and Territory Health Ministers are considering options for regulating the audiology profession
Comprehensive knowledge and expertise in managing the complex nature of deafness and hearing loss is critical across all hearing health practitioners. The public is at risk if other vulnerabilities are not recognised and addressed as part of hearing health services.
Hearing loss and deafness are often identified at vulnerable points in life, such as when a child is newly born or during advanced age, when cognitive decline may be present. Hearing loss is often a symptom of a broader health condition and can coexist with other disabilities.
Protecting the Public from Unsafe Practice is our Priority
Deafness Forum Australia is committed to supporting the registration of audiologists and audiometrists in Australia under the National Registration and Accreditation Scheme, emphasising the benefits it would bring to public safety.
Earlier this year, Australia’s Health Ministers commissioned a report to explore the level of regulatory intervention necessary for hearing healthcare offered by audiologists. Under investigation was whether audiology should
become a registered profession, meaning that every Australian audiology practitioner would be subject to monitoring and enforcement of uniform standards through thorough audits, investigations, and penalties.
Supporting Audiologists and Audiometrists
Deafness Forum Australia values the expertise and dedication of audiology and audiometry professionals. We aim to further support these practitioners by advocating for a structured registration process that ensures ongoing quality and recognition for qualified practitioners.
Regulation presents an opportunity to strengthen trust between individual consumers and their chosen audiology professionals. Building this trust can enhance the support for individuals experiencing hearing loss and deafness, ensuring they receive the necessary care and assistance they need.
Non-zero-sum gain
The challenge in making a case for registering audiologists and audiometrists in Australia under the National Registration and Accreditation Scheme is explaining that it is not a competitive, win-lose scenario.
We believe that all parties will benefit – the community, the profession, device retailers and governments. It’s a win-win for Australia.
Ensuring Consumer Safety: Protected Titles Are Important
Currently, audiologists are self-regulated, meaning their title is not legally protected, which could leave consumers more vulnerable to unqualified practitioners.
Implementing registration would legally protect the use of practitioner titles such as “audiologist” or “audiometrist”, ensuring that only those who meet mandatory qualifications and standards can use them.
In Australia, titles like “physiotherapist” and “doctor” are legally protected under the National Registration and Accreditation Scheme (NRAS), managed by AHPRA*, meaning only qualified professionals can use these titles. Without similar protections for titles like “audiologist” or “audiometrist”, there is a risk that someone could use these titles without the necessary qualifications, which could harm consumer safety. * The Australian Health Practitioner Regulation Agency, aka AHPRA, protects the public by regulating Australia’s registered health practitioners.
AHPRA’s system includes a national register for protected titles, allowing consumers to verify credentials and report unregistered practitioners. This also allows for a national consistent complaint pathway. While Australian Consumer Law offers some protection against misleading claims, AHPRA’s registration system provides stronger safeguards by ensuring professionals meet national standards and are monitored for ongoing competence.
State healthcare complaint mechanisms currently offer limited safeguards. A code of conduct exists for all unregistered healthcare practitioners, but being state specific, suspended individuals could move interstate and continue to practice.
Self-Regulation: Limited Scope
Because audiology is a self-regulated profession, qualified audiometrists and audiologists may opt into being regulated through membership of a professional body. Professional bodies will accredit their members if they complete prescribed and ongoing education and work hours, but there is no legal requirement to be a member of a professional body, and accreditation is primarily recognised for public and private health funding purposes.
The professional bodies can only investigate complaints about their members. If misconduct is proven, the professional bodies can only counsel and train them, and if needed, terminate their membership. Professional bodies can’t prevent non-members or those who commit misconduct from delivering hearing services; and they can’t influence anyone who is not a member.
The Right to Complain can be a Complex Pathway
The process of making a complaint can be complex and time consuming and therefore, a disincentive to raising concerns. Determining which complaint mechanism to use requires understanding of various complaint authorities, and those who start a complaint process with one authority may be told to take their complaint elsewhere. Complaints against a business require a complaint to Fair Trading (different names apply in different states) or The Australian Competition and Consumer Commission (ACCC).
The registration of audiologists and audiometrists in Australia under the National Registration and Accreditation Scheme could simplify the complaint process for consumers. With a centralised registry, such as AHPRA’s, consumers can more easily verify credentials and navigate the complaint system, allowing for a more straightforward and effective way to address grievances.
Mandatory Registration for Many Healthcare Professionals in Australia
Registered healthcare professionals in Australia are regulated under the National Registration and Accreditation Scheme (NRAS). Only professionals listed on that register are allowed, by law, to use
the title of that profession. For example, anyone who uses the title optometrists in Australia must, by law, be on the national register.
Registration of health professions under the NRAS offers assurance to the public that the practitioner has met consistent national standards. Numerous health professions are already regulated this way, including occupational therapy, optometry, osteopathy, pharmacy, physiotherapy, and podiatry as well as medical doctors and nurses.
National Registration and Accreditation requires professionals to hold recognised qualifications and renew their registration annually and requires them to participate in ongoing professional education.
The public can search for registered healthcare professionals through the Australian Healthcare Practitioner Regulation Agency website.
Complaints against registered professionals are investigated by the relevant appointed board. Mandatory registration for health practitioners ensures standards through meaningful penalties for unprofessional conduct. Penalties can include suspension or deregistration, meaning that the person cannot practice that profession any longer anywhere in Australia.
Deafness Forum Australia’s Position
Protecting the public from unprofessional practice is a priority for Deafness Forum Australia.
Deafness Forum Australia supports the registration of audiologists and audiometrists under the National Registration and Accreditation Scheme, emphasising the benefits it would bring to public safety.
We believe that registration would enable the public to trust that they will receive services from suitably qualified professionals, registered with a national body and to have a transparent and simplified complaints pathway when they do not.
Benefits All Australians
We want consumers to trust audiology and audiometry services in the same way they trust others who provide their healthcare, such as general practitioners, nurses, or optometrists.
Mandatory professional registration would mean that the public could trust the titles audiologist and audiometrist, so that anyone calling themselves an audiologist must have university qualifications in audiology. Audiologists achieve a Masters’ level qualification to provide their primary care role.
Audiometrists complete a range of certifications, including to diploma level, and conduct hearing tests across a range of settings.
Currently, there is the potential for public and health professional confusion about the expected role of the two professions.
Without registration and title protection, there is no mechanism to address this. (Unleashing the Potential of our Health Workforce – Scope of Practice Review Final Report, Oct 2024)
Mandatory registration will offer more accessible information about each registered audiologist or audiometrist via an online search of a single government-maintained website.
A simplified complaints pathway that applies to all registered professionals will be open to consumers.
Anecdotal evidence suggests practitioners would value registration and hope to affirm their professional status through the same mechanism that recognises their colleagues in other healthcare professions.
Being registered will provide audiologists and audiometrists with formal acknowledgment of their qualifications and competence. We believe that audiologists and audiometrists will gain professional credibility and recognition from other healthcare professionals as fellow registered practitioners.
Latest Development
State and Territory Health Ministers have commissioned further consultation and modelling to inform final consideration and decision about the future regulation of audiology.
We do not know if registration of all audiologists and audiometrists was recommended to the Health Ministers. It is possible that the Health Ministers have entertained the idea of regulation for only some audiologists, such as those offering diagnostic or implant services for infants.
As the peak citizen representative body, we do not support only partial registration of some audiologists. We believe that every Australian, regardless of their age or associated condition or disability, deserves a new and robust system to ensure professional hearing services. Further, a partial registration model will make regulation and complaints processes even more complicated than they are now.
The Health Ministers’ inquiry is set to resume this month, with limited opportunities to contribute to decisions. Invited stakeholders will be consulted about costs, implementation, risks, and impacts on First Nations communities. We were advised that the consultation process would include interviews with select stakeholders. All other stakeholders would be invited to provide input via a public process hosted on the Queensland Health website. The findings are to be presented at the next Health Ministers Ministerial Council meeting in early 2025.
Deafness Forum Australia is committed to bringing the consumer voice to the decision-making. Your lived experience as consumers, how you have engaged with audiologists, audiometrists or others in the hearing services in hospitals, school, private, commercial or government settings, is important and deserves attention.
Your voice can make a difference – share your views with Deafness Forum Australia
Deafness Forum invites you to tell your story – in confidence – about your experiences receiving care from hearing care providers. We will convey your collective experience to decision makers.
Service providers, your experience and views matter too. Deafness Forum invites you to share your perspective so that we can understand the issues from all perspectives.
There are two surveys.
To share your lived experience as a user of hearing services, please complete our online survey before 30 November 2024.
https://www.surveymonkey.com/r/R8ZX6CV
This survey is designed to find out more about your lived experience and opinion of regulation for audiologists and audiometrists.
The second survey is for people in the profession
https://www.surveymonkey.com/r/RLVWL76
We invite you to contribute your experiences, knowledge, and opinions through our anonymous survey to help us better understand the potential benefits and challenges of mandatory professional registration.
SEP 2024: Past Reviews, Future Vision: Discussion Paper Summary
In our discussion paper, “Past Reviews, Future Vision,” we explore how the Australian Government Hearing Services Program (the Program) has evolved over time. We look at three key reviews from 2012, 2017, and 2020/21 to understand what actions have been taken, identify any gaps, and suggest improvements for better hearing health for all Australians.
Currently, one in six Australians experiences hearing loss, and this number is expected to rise to one in four by 2050. This makes it essential to provide high-quality support for everyone who needs it.
Our paper starts an important conversation about the challenges and opportunities within the Program. We propose a framework focusing on key areas like putting participants first, offering tailored support, addressing overall health needs, providing accessible information, and ensuring assistance for vulnerable groups. By collaborating with the community and stakeholder organisations, we aim to ensure that all Australians can access the hearing support they need at every stage of life.
As you read our paper, we invite you to think about what improvements could be made and how we can work together to enhance the Hearing Services Program for everyone. Together, we can create a more inclusive and effective program that helps all individuals thrive.
- Read the DeafnessForumAustralia Hearing Services Discussion Paper
- View our webinar launching the paper
- Read the Launch Webinar Transcript
Current disability issues and the NDIS
For a deep dive into issues and developments in disability advocacy and the National Disability Insurance Scheme, visit Hayley’s Journal.
June 2024: Australia’s State and Territory Health Ministers are considering options for regulating the audiology profession
Update, OCT 2024
“On 16 August 2024, the Ministerial Council considered the Audiology Decision RIS.
“Following this, Ministers have requested further work on implementation of audiology regulation under the National Registration and Accreditation Scheme, including targeted consultation to inform a final decision.
“The Queensland Health Project team will progress this additional work on behalf of the Health Workforce Taskforce with a planned update to the Ministerial Council in early 2025.”
Office of Minister for Health, Mental Health and
Ambulance Services and Minister for Women
Queensland Government.
Occupational therapists, optometrists, osteopaths, pharmacists, physiotherapists and podiatrists are among the 16 professions regulated by an independent regulatory body. Yet, audiologists regulate themselves via their own peak body.
We support action to ensure that the scope of service delivery performed by audiologists is aligned to nationally prescribed levels of knowledge, skills, and experience, and that professional qualifications mechanisms exist to manage underperforming audiologists, as well as those who engage in unethical business practices.
Deafness Forum Australia considers having a single organisation, independent of the profession, that has oversight or authority to investigate and consistently manage complaints and apply sanctions across the audiology profession to be essential to protect the community and enhance the reputation of the audiology profession.
Our Recommendation
Deafness Forum Australia strongly supports the registration of the audiology profession under the National Registration and Accreditation Scheme.
We recommend that it be expanded to cover national registration of both audiologists and audiometrists.
Read our submission: Support for registration of the audiology profession JUN2024
March 2024: First Nations Roundtable
Deafness Forum Australia hosted a roundtable meeting with a select group of influential stakeholders with a shared aim of helping to address the ear care and hearing health disparities in First Nations communities. The Roundtable, in March 2024 in Canberra, was facilitated by Prof Kelvin Kong AM, an eminent ear, nose and throat surgeon and ardent social advocate. We discussed pivotal aspects of healthcare access and delivery, focusing on the challenges. From the Roundtable, an official communique was created: Meeting Communique – Addressing Aboriginal and Torres Strait Islander Hearing Healthcare MAR-2024
To augment the communique, we prepared a report that aligns the Roundtable outcomes with Closing The Gap Agreement priorities and the Roadmap for Hearing Health: Aligning Strategies with National Priorities – Roundtable Indigenous Hearing Healthcare MAR-2024.
Also in March, our national newsletter was a tribute to the talent, resilience and wisdom of Aboriginal Women in Hearing Healthcare and Advocacy. You can download and read this special edition of One in Six.
Closing The Gap: Addressing the hearing health of Aboriginal and Torres Strait Islander Peoples in the criminal justice system.
Australia’s justice system remains ineffective in addressing the complex needs and vulnerabilities of Aboriginal and Torres Strait Islander peoples. We must stop the perpetual cycle that exists between childhood ear disease and the disproportionally higher rates of incarceration for this population. Read our report, Hearing Health of Aboriginal and Torres Strait Islander Peoples in the criminal justice system APR 2024.
High Proportion of Indigenous Canberrans in Prison
Nearly a third of Canberra’s average prison population is Indigenous, despite Indigenous Canberrans constituting only 2% of the ACT population. The Australian Capital Territory is currently facing a significant challenge, with the highest rate of incarceration rates for Indigenous people in the nation compared to non-Indigenous residents. A critical yet often overlooked aspect of the plight of First Nation Australians in incarceration warrants attention: undiagnosed and untreated hearing loss. Read more on this topic here.
Navigating Barriers and Promoting Inclusivity
In producing this paper, our primary aim was to highlight the pressing concern of inadequate hearing service access for people from culturally and linguistically diverse backgrounds. We examined existing research and summarised the findings in accessible language. We hope that this paper will foster enhanced awareness of these issues, spark meaningful dialogue and further research and collaborations in the field. We offer clear recommendations to policymakers, hearing healthcare practitioners, and community program managers. Here is where you can read the report.
Disability Employment Centre of Excellence
Deafness Forum Australia provided its suggestions for the creation of a national Disability Employment Centre of Excellence.
This Centre, to be established by the Australian Government, aims to significantly improve employment opportunities for individuals with disabilities, addressing the persistent employment gap across Australia. Despite their eagerness and ability to work, people who are deaf or hard of hearing face higher unemployment rates than people without disability and can experience numerous employment barriers, including attitudinal, environmental, and systemic challenges. We’ve listed what we think should be the Centre’s goals. Read more here.
Hearing services provided through the National Disability Insurance Scheme and the way to improve them
When the Australian Government initially discussed its plans to transfer existing hearing services to the National Disability Insurance Scheme, we received assurances from both the NDIA and the Department of Health & Aged Care that service quality and timeliness would be maintained, with the goal of improvement. They also assured us that the costs to the Commonwealth would not exceed the current expenses at that time. However, neither of these assurances have been fulfilled.
Given these circumstances, a service delivery model should be adopted that ensures easy access to high-quality and consistent hearing services at a reasonable cost to the government. Read our recommendations in a letter to the Review of the NDIS conducted by the Commonwealth Department of Prime Minister and Cabinet.
Attaining universal inclusion of all people who need the support of the NDIS
In a submission in 2023 to the Government review of the NDIS, we identified 9 key factors that if addressed, can dramatically improve the community’s trust in the NDIS.
Preventing hearing loss with Safe Listening Habits
Preventive health action is the key to achieving a healthier Australia by 2030. Avoidable hearing loss represents an enormous social and economic cost to Australia. Prevention is the most effective way to reduce hearing loss and tinnitus. Exposure to noise, whether prolonged or of short duration, is a major cause of approximately one-third of adult-onset hearing loss. And it is almost entirely avoidable. Read more about Preventable hearing loss. You can also read about Australia’s National Preventive Health Strategy 2021-2030 – it provides a high-level guide to preventive health actions.
Unaddressed hearing loss is a serious public health problem.
Australians with good hearing health are better able to lead fulfilling and productive lives. People who have untreated hearing problems tend to have much higher general healthcare costs than those without hearing loss – as much as 50% more. Along with the distress experienced by individuals with hearing loss and the financial costs faced by families, hearing loss results in an annual cost to Australia’s economy of $30 billion dollars. Read more about Australia’s high levels of untreated hearing loss.
There have been problems with Children’s cochlear implants in hospitals in two states
There are two state government investigations currently underway, but we feel that independent investigations may be necessary to earn community trust.
We will keep the community posted as we work through how we can constructively contribute to the investigation and systems improvements. The immediate priority is supporting the families and children, and if you go to the following web links you can read what we have recommended on their behalf.
- Cochlear implant crisis at Adelaide Children’s Hospital
- Two stood down as QLD health investigates cochlear crisis
Addressing the burden of hearing loss among vulnerable groups in the community
The objective of the Australian Government’s Hearing Services Program should be to ensure that vulnerable groups, those requiring specialised programs to address their hearing needs, and people on low income have access to high-quality hearing services at no cost or minimal cost. In order to do so, the eligibility of the Program should be extended to a broader group of vulnerable people:
1. People on a Health Care Card, or Low-Income Card
2. Seniors Health Care Card Holders
3. Children of refugees
4. People in the criminal justice system
5. People in Aged Care
Creation of a new eligibility category for Aged Care under the Community Service Obligations component of the Australian Government Hearing Services Program
Residents of aged care facilities are currently unable to access the hearing services they need under the Voucher Program component of the Hearing Services Program (HSP). These clients have complex needs and research has shown that residents in aged care require a different model of service delivery than is available through the Voucher Program.
Testing to detect noise-induced hearing loss in the workplace
The inability to hear can be a significant threat to a worker’s health and safety. Occupational hearing loss and deafness is a completely preventable injury. It is a serious injury that has a profound impact on an individual’s quality of life.
Two characteristics of noise-induced hearing loss have been thoroughly established. The amount of hearing loss increases with noise intensity, duration and exposure, such that more intense and longer-duration noise exposures cause more severe hearing loss.
Deafness Forum Australia, Unions NSW, The Australian Workers Union (NSW Branch), and affiliate unions believe it is important to test a worker’s hearing at the commencement of their career (within three months of the worker commencing work where hearing protection is required), to provide a baseline measurement as a reference for future audiometric test results. Once this is done, early identification of changes to hearing due to noise is the most effective way of assessing the effectiveness of any control measure in place and in turn preventing hearing loss, which can take place over a long period of time or can in some cases be instant. Follow-up testing should occur every two years. Testing should occur well into the work shift so that any temporary hearing loss can be picked up. More frequent audiometric testing may be needed if exposures are equal to or greater than 100dB(A).
Not only does early detection of noise-induced hearing loss through audiometric testing in preventing further hearing loss, it also assists in the medical and scientific study of hearing loss.