Regulation of Audiology in Australia
MANDATORY NATIONAL REGISTRATION FOR AUDIOLOGISTS?
Qualified, audiologists work according to the code of conduct for unregistered healthcare practitioners (state based at present but national regulation has been approved by COAG) and may voluntarily choose to belong to one or more professionals associations that self-regulate according to their own codes of ethics. Both regulatory systems (professional association membership and state and state/national regulation of unregistered healthcare practitioners) are reactive to complaints, without mandatory registration against which the public can check for qualifications or experience.
Voluntary membership of professional associations means that expulsion of individual members is the only disciplinary measure that can be applied. A member who fails to meet the criteria of a self-regulating professional association (as accredited or holding a clinical certificate) can still provide products and services to the fee-paying public. Membership status is not directly linked to service provision to the fee paying public. Self-regulation means fellow members of an association deciding matters of professional conduct may have an interest in the outcome of any complaint, a situation recognised by those calling for national regulation of those healthcare professions that remain unregistered in Australia.
No compulsory register of audiologists exists in Australia. Any person can undertake audiology work regardless of their qualifications. Given that funding for audiology is limited, many Australians are responsible for paying for audiology services and hearing devices themselves. Consequently, providers who are not audiologists, or providers who are audiologists but who choose not to belong to a professional association, fall outside of the regulation imposed by professional association membership.
Additionally, those hearing related businesses that are not owned by qualified audiologists or audiometrists could fall outside of the regulation imposed on unregistered healthcare providers, as they are arguably supplying a product and not delivering healthcare.
Neither regulation by funding bodies nor regulation by professional associations with voluntary membership prevents the Australian public from being sold treatments for hearing loss that are based on assessments and advice by those without audiology qualifications or those who choose to work outside of funding schemes and professional bodies.
The lack of mandatory registration requirements for audiologists and audiometrists in Australia contrasts with regulation around the world. The following regulatory requirements apply in countries with comparable healthcare systems:
United Kingdom (UK): Audiology in the UK is regulated by the Health Professionals Council (HPC). Registration as a Clinical Scientist (Audiology) with the HPC is required. The title of 'Clinical Scientist' is protected, meaning it is illegal to work under this title in the UK unlss registered with the HPC.
United States of America (USA): Licensing (by state) is required to practice the profession of audiology. The minimum educational level is a doctorate.
Canada: Provinces regulate the profession of audiology. Registration with the regulatory body (known as colleges) in a regulated province or territory is required.
Israel: Certificate of profession issued by the Ministry of Health entitles practicing the profession.
South Africa: Audiologists must register with the professional board for Speech Language and Hearing Professions, which falls under the Health Professions Council of South Africa.
Brazil: Audiologists must comply with federal regulatory (licensure) standards in order to practice the profession as set by the Brazilian Federal Speech Language Pathology and Audiology Council.
Europe: Hearing aid professions are regulated in Austria, Belgium, France, Germany, Ireland, Italy, Lichtenstein, Luxembourg, Norway, Poland, Portugal, Spain, Sweden, and Switzerland. As an example, in Sweden, the professional title audiologist is protected and may be used only by a professional who holds a license issued by the Board of Health and Welfare.
Audiologists are currently not registered in Australia under a professional board falling under AHPRA. Audiologists pose no less risk to the public than do their registered counterparts in optometry, occupational therapy, physiotherapy, psychology. However, audiology did not require state registration prior to the introduction of mandatory national registration which resulted in exclusion from the group of professions required to register when national boards were established under AHPRA in 2010. Considerable change to the service delivery model has taken place in the past decades. Australian Hearing, a Commonwealth Agency, used to be the only provider of services to eligible pensioners. Since the 1990s, the Australian government (through the Office of Hearing Services) has signed contracts with businesses, including large multinational companies, to take on the provision of hearing related services to eligible pensioners. Australian Hearing now competes with large and small businesses as a government agency with a profit motive. Funding for services to children will shift from the Office of Hearing Services to the NDIS by 2019.
Multinational companies have established chains of clinics in Australia and the Office of Hearing services contracts to those multinationals to provide hearing aids to eligible pensioners. Audiology now faces influences from industry that are parallel to relationships between medicine and the pharmaceutical industry, but to date has escaped external regulatory structures that serve to protect the public from exploitation.
Evidence that the current level of regulation of audiology in Australia is inadequate can be seen in reports by the ACCC (March 2017) investigative journalists reporting in the mainstream media (Radio National, ABC 7.30 report, ABC The Checkout and Fairfax journalists) and social media. Public response to those programmes has exceeded expectations. Members of the public report being coerced into the purchase of hearing devices with advanced features in the belief that such devices will alleviate the effects of hearing loss. Such coercion can only be understood in relation to business structure ownership, targets for sales set by business owners and commissions paid to those advising on hearing devices (including audiologists and audiometrists), but which are often undisclosed. Repeatedly the media and consumer groups report on members of the public being advised that they need to replace hearing devices or that hearing devices with a very high price tag are the only ones that will benefit them. Consumer groups report regular complaints of dissatisfaction with hearing aid purchases, aggressive and misleading hearing aid sales, unregulated prices and unsubstantiated claims.
Self-regulation offers very limited protection because complaints are investigated by those who may potentially have an interest in the outcome and the only penalty for unethical or unsafe practice can be expulsion from an association for which membership is not a requirement to practice. Restrictions or bans on practice that might be imposed by a state based healthcare complaints commissioner constitute reactive regulation. Professionals and consumer groups agree that given the powerful and lucrative hearing device industry is so closely associated with audiology, external regulation is necessary to ensure conflicts of interest are not perceived to influence advice provided to the public. Other healthcare fields are regulated so as to ensure the Australian public is protected. Regulation by professional boards applies in the healthcare field exists in Australia for fourteen professions with whom registration with a professional board administered under Australian Health Professions Regulation Agency (AHPRA) is mandatory and applies nationally.
Some professional groups who consider that the public interest would be served by their profession being subject to mandatory national registration have been incorporated into the registration system (eg Chinese medical practitioners and Paramedics). Others have established a private board to mimics an AHPRA board (eg Naturopaths). Others have sought self-regulation in ways that align closely to professional board systems as interim measures until registration is approved (eg Speech Pathologists). Professional bodies of audiologists and audiometrists and consumer groups representing the Australian public agree that self-regulation by professional associations and regulation by complaint is inadequate protection for the public in relation to the field of audiology. Clinic accreditation is cited by some professional bodies representing audiologists as a solution to the lack of regulation. Clinic accreditation is a form of regulation that needs to operate alongside, not instead of, professional registration. Clinic accreditation will not change the current situation of accreditation only by funding bodies without mandatory registration of the practitioners operating out of clinics that are accredited. Ninety-seven percent of audiologists surveyed support mandatory national registration. Representatives of consumer groups (Better Hearing Australia, Parents of Deaf Children, Aussie Deaf Kids, Self Help for the Hard of Hearing and Deafness Forum) have all expressed support for better regulation of audiology.
The Council of Australian Governments (COAG) decides which professions require registration boards. COAG has the authority to act on public concern and can decide to include audiology as a profession that requires mandatory national registration. As recently as 2015, COAG approved another profession (Paramedics) to be regulated under AHPRA.
IAA supports all state governments and their respective Health Ministers to propose and support the establishment of a professional board for audiology to recognise and regulate the practice of audiology in Australia.