We write following the HSC hearing on 8 March and with particular reference to the written evidence submitted by the Hearing Aid Council (HAC). Together, our companies employ and train almost 100% of the new entrants to the profession and feel compelled to correct some of the misconceptions that could arise from the HAC submission.

EDUCATION AND TRAINING

  In its submission HAC describe the training provided to new entrants as "work based". Clearly, the submission must be brief but such brevity is grossly misleading. The comment implies on the job training is the extent of the training provided, this could not be further from the truth. An initial period of intense classroom training, approaching six months, prepares the trainee for a written examination of which the syllabus, question preparation and marking procedures are the total responsibility of HAC. This is followed by a practical examination also wholly in control of HAC and now in conjunction with Anglia Ruskin University. Success is not a foregone conclusion with a success rate in recent years of around 60%. Not until a trainee has been successful in both parts of the exam may he/she attend a client without the direct supervision of a Registered Dispenser. Exam success is followed by a further minimum of six month period of pre-registration under the direct and indirect supervision of a qualified Dispenser; duly evidenced by a `log book' the criteria for which is stipulated by HAC. Only after this second period may the trainee apply for the status of Registered Hearing Aid Dispenser.

REGULATION

  In the context of "regulation", the HAC submission used the phrase "not fit for purpose" and it could be concluded that it was their opinion that the regulation of private sector Dispensers was inadequate and ineffective. We believe such a conclusion would be incorrect.

  Subsequent to admission to the HAC register, Dispensers must follow the HAC programme for Continuous Professional Development and adhere to the comprehensive HAC Code of Trade Practice.

There is ample evidence that the HAC Code and their associated investigating and disciplinary procedures are applied robustly.

  Inevitably, regulation has moved on since the 1968 Act and the proposed new framework will undoubtedly better fit the 21st Century's perception of regulation; however, we trust the Committee will conclude from the above that the private sector is currently subject to appropriate regulation.

PUBLIC PRIVATE PARTNERSHIP

  It would be easy to conclude from the HAC comments that the recent PPP in Audiology was evidence of inadequate regulation. What was, in fact, being pointed out was that current HAC jurisdiction covers only retail transactions and does not extend to NHS audiology. Consequently within PPP there was the potential for a regulatory gap; the HAC's point regarding the limits of their jurisdiction is valid. However, under PPP each PCT established a precise professional service specification together with a formal process to ensure full patient protection. Hence, in practice, there was no void in regulation or "consumer" protection. Further, Patients, PCTs and RNID expressed satisfaction with the standards delivered by the private sector and certainly no suggestion of consumer risk or harm.

  We trust that this additional clarification is helpful, should we be able to be of any further assistance we shall be pleased to hear from you.

Mark Georgevic, The Hearing Company

Peter Ince, Specsavers

Graham Lane, Hidden Hearing

Jeff Murphy, Ultravox

Peter Ormerod, David Ormerod Hearing Centres

30 April 2007