We have read the written and oral evidence presented to the above enquiry on 8 March. There are three particular points that require clarification and on which we offer some additional comments:

PRICE

  At Q37 during the oral evidence session, the Committee briefly pursued the disparity between the NHS price for hearing aids and the price charged by the independent sector. The assumption was made that the comparable figures are £70 for NHS and £2,000 for private (these were the figures used in RNID publicity at the introduction to the NHS of digital hearing aids in 2000 and quoted by the Department of Health in its evidence to the Committee). Time did not allow for the issue to be discussed in detail. However, a number of additional factors need to be considered:

  1.  The NHS figure of £70 was the cost per digital hearing aid to the NHS of bulk purchasing from the manufacturer (ie the wholesale price). It did not include supply, fitting or follow up service to the patient.

  2.  The independent sector figure was the fully inclusive price of the complete Audiological service, including the cost of the digital hearing aid, pre and post fitting with ongoing lifetime rehabilitation and support.

  3.  At the time, the figure of £2,000 was challenged and even the RNID never claimed it to be usual or average but an isolated extreme. As Mr Murphy said in his evidence on 8 March, the average "all inclusive" independent sector price is now just over £1,000 (Q40).

  4.  Prior to the launch of NHS digital aids there was a National Reference Cost for the assessment, fitting and follow up in relation to NHS analogue hearing aids. The 2005 costs for these analogue aids were average £236/upper quartile £306. The manner of establishing the costs and overheads included in such figures has always been contentious as possibly underestimated.

  5.  However, since the launch of digital hearing aids no such reference costs have been available for the new devices. This makes any valid comparison between the two sectors even more questionable.

  6.  At a rough estimate, current costs of the NHS service, inclusive of one digital hearing aid, is about £400. The cost of the full independent sector service (including a superior device and lifetime care) is £1,000.

  7.  The official NHS patient pathway totals a fraction over two hours and, as the recent DOH document Improving access to Audiology services indicates, now includes aid fitting by assistants and follow up by a telephone call from a secretary (paragraph 28, page 9 and accompanying case study). In comparison, the price of an independent sector digital hearing aid includes full care and support for the lifetime of the device.

  8.  A major factor influencing cost is availability. The independent sector service is available, more or less, upon demand in the high street or even in the client's home, compared with NHS hospital based service requiring an average wait of 45 weeks and in some instances in excess of four years. No independent sector service would dare offer such a service but if it did, its costs would be slashed.

  9.  The unique supply process in the UK results in massive volume through the state-funded NHS route, with minor activity through the independent sector. Consequently the latter operates at less than full potential, whilst being subject to all of those costs associated with larger volume activity. If the full potential of the independent sector was utilised, prices would reduce as economies of scale were realised.

  In summary, the cost disparity for which justification was sought is completely invalid. Furthermore, the comparison is between a service with long waiting times at £400 and a premium service at £1,000.

  It may also be worth pointing out that the NHS digital hearing aid currently available is an external device (ie "behind-the year") whereas the independent sector offers a choice of digital hearing aids, including "in the ear" devices.

REGULATION AND TRAINING

  At Q138 during oral evidence by the Minister, reference was made to the status of hearing aid audiologists. The Committee was clearly disturbed by the submission from the Hearing Aid Council (HAC) and Ronnie Campbell MP queried whether the HAC comments could be a case of "sour grapes" in the light of its pending abolition (Q138). This seems unfair and the following points might be pertinent to a deeper understanding of the issues addressed by the HAC:

1.  The HAC written evidence clearly states that it wishes to see the strengthening of its current regulatory responsibilities and their transfer to the Health Professions Council.

2.  The reference to "not fit for purpose" should also not be misconstrued. As paragraph 10 of its evidence makes clear, it refers to the structure of the current regulatory regime rather than to standards. The reference also refers to the regulation of all hearing aid audiologists—both NHS and independent sector—as do its later comments on the lack of common standards across the profession (paragraph 14).

3.  In terms of independent sector hearing aid audiologists, the current training regime requires trainees to complete a written and practical examination, preparation for which demands a minimum period of six months intensive classroom education. The syllabus and examination are wholly managed by the HAC, which is a statutory not a trade body. However, the training provided is entirely funded by the independent sector and inevitably impacts on prices.

4.  Until they pass their exams, trainees cannot see clients unless a qualified person is present. Following their exam success (the pass rate is around 60%), there is a further six months to complete a period of pre-registration dispensing under the supervision (some direct, some indirect) of a qualified person. Post qualification, compliance with a programme of continuing professional development is mandatory.

5.  Both Registered Hearing Aid Dispensers and their employers are subject to a thorough and strict Code of Practice. This is fully under the control of the HAC together with its associated disciplinary powers which, in the Background to its evidence, the HAC describes as "semi-judicial". There is consistent evidence of discipline being applied when appropriate.

PUBLIC PRIVATE PARTNERSHIP (PPP)

  At Q139 the Committee asked whether the structure of the current regulatory regime could affect the running of the PPP. Again it is important not to misconstrue the evidence given by the HAC, which prompted this question, and the following additional points may be helpful:

1.  The HAC evidence (paragraph 13) made the legal point that because hearing aids provided for the PPP were not by way of a retail sale, the regulatory and standards legislation did not apply. However, the PPP contracts established strict service specifications and Ms Helen McCarthy of the Purchasing and Supply Agency (PASA) in her evidence to the Committee confirmed that no negative feedback had been received about the PPP (Q139).

2.  Ministers, the Department of Health and the RNID have all expressed satisfaction at the involvement of the independent sector in the PPP and the contribution made by the independent sector. In its report, "Sustaining your modernised Audiology service", the RNID stated: "Patient experiences of the PPP were positive... Outcomes from the private sector are as good as, or better than, the NHS service" (page 4).

  We hope these further comments will assist the Committee in drawing up its final report.

Hidden Hearing

20 March 2007