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Access to health
Policy statement
Our position
People with hearing loss face multiple barriers when trying to access health services. They
may find it difficult or impossible to book an appointment, receive test results or order a
repeat prescription over the phone – and may need support to understand what is being said
in the consultation/treatment room. People who use British Sign Language (BSL) may need
BSL interpretation to communicate well and understand written information.
Health services have a legal duty to make reasonable adjustments if people with hearing
loss face these difficulties. Health services should comply with standards for accessible
communication and information and provide a range of contact methods such as email, SMS
Text or Text Relay for people with hearing loss who cannot use the telephone. Hearing loop
systems should be available in waiting areas for people who use hearing aids and people
with hearing loss should be able to communicate well during appointments. A properly
qualified, registered BSL interpreter should be provided to everyone who needs one.
Introduction
This policy statement presents the main issues people with hearing loss face when
accessing health services. We outline our stance on accessible communication and
information and set out the action that should be taken by Government, NHS organisations
and health services, including both primary and secondary care services, across the UK to
make sure people with hearing loss are able to contact services when they need to,
communicate well and understand written information1.
We use the term 'people with hearing loss', throughout this statement to refer to people with
all levels of hearing loss, including people who are profoundly deaf.
Background
Under the Equality Act 2010 (the Disability Discrimination Act 2005 in Northern Ireland)
health services across the UK are required, by law, to make reasonable adjustments if
people with hearing loss face substantial difficulties when accessing services. Failure to
make reasonable adjustments counts as discrimination and is against the law. Health
services are also responsible for meeting the costs of reasonable adjustments.
In England, NHS England’s Accessible Information Standard2 sets out clear guidance on
what NHS providers and providers of publicly funded adult social care must do to make their
services accessible for people with disabilities and sensory loss, including people with
hearing loss. The standard, which becomes a legal requirement by 31 July 2016, establishes
1
Please note that, like many policy documents, this statement reflects the issues relevant at the time
of writing. Over time, this may be subject to change, such as new legislation being introduced, and we
may review and amend the document.
2 NHS England (2015) Accessible Information Standard. SCCI 1605. Available at:
https://www.england.nhs.uk/ourwork/patients/accessibleinfo-2/
July 2016
a clear framework to make sure people with hearing loss (and their parents, guardians
and/or carers) are able to communicate well and understand the information they are given.
In Wales, NHS Wales’ All Wales Standards for Accessible Information and Communication
for People with Sensory Loss3 provides guidance on what people with sensory loss should
expect when accessing health services. The standards state that people with hearing loss
should be able to contact health services when they need to – and have access to
communication support and information in accessible formats. The standards also state that
the design and layout of waiting rooms and clinical areas should support good
communication. There must be staff training, so that the standards can be implemented
properly, and Local Health Boards (LHBs) and NHS Trusts must monitor and review
compliance regularly.
People with hearing loss have the right to request reasonable adjustments when accessing
health services. Research shows, however, that people with hearing loss often face
unnecessary and costly barriers to communication (see below).
Evidence
People with hearing loss often need support to contact health services, to understand
information, and to communicate well during appointments, but research shows this is rarely
provided.
Contacting health services
People with hearing loss may find it difficult or impossible to use the telephone to book
appointments, order repeat prescriptions, receive test results or contact emergency or out of
hours services. People with hearing loss may benefit from other contact options such as
email, SMS Text, online booking and Text Relay. Our Access All Areas4 research showed
that many people with hearing loss are forced to struggle with the phone, or go in person, to
book an appointment, due to the lack of accessible contact methods:
 A majority of respondents to our survey (72%) contacted their GP by phone, yet just
under half (44%) said this is their preferred method of communication.
 Just under half (46%) visit their GP in person to book an appointment, but less than one
in 10 (9%) preferred to book an appointment in this way.
 Approximately one in 10 (9%) contact their GP by email but a third (31%) would prefer to
book an appointment this way – this suggests a level of unmet need.
Visiting health services
When people with hearing loss visit their local GP, urgent-care centre, walk-in centre or
pharmacy, they may need additional support to communicate well with staff and know when
it’s their turn to be seen. Alarmingly, our Access All Areas5 research shows that one in seven
(14%) respondents to our survey said they had missed an appointment because they didn’t
3
NHS Wales (2013) All Wales Standards for Accessible Communication and Information for People
with Sensory Loss. Available at:
http://gov.wales/topics/health/publications/health/guidance/standards/?lang=en
4 Ringham (2012) Access All Areas. Available at: www.actiononhearingloss.org.uk/accessallareas
5 Ringham (2012) Access All Areas. Available at: www.actiononhearingloss.org.uk/accessallareas
July 2016
hear their name being called in the waiting area. NHS England6 estimates that this costs the
NHS £14 million every year – a substantial sum that could be saved by making reception
desks and waiting areas accessible for people with hearing loss.
Reception staff should be aware of the support people with hearing loss may need to help
them communicate and there should be a hearing loop system installed on reception desks,
so people who use hearing aids can communicate with reception staff when they need to.
More than half (51%) of GPs who responded to a survey from Sign Community, RNIB and
RNID Northern Ireland7 did not provide deaf awareness training for their staff and only half
(50%) provided hearing loops in waiting areas. People with hearing loss may also benefit
from visual display screens that clearly display when it’s their turn to be seen. But our
Access All Areas research shows that less than half (44%) of survey respondents reported
that their GP surgery uses visual display screens to call patients in to appointments.
Under NHS England’s Accessible Information Standard8 and the All Wales Standards for
Accessible Communication and Information for People with Sensory Loss9, health services
must ask people if they need help to communicate and understand written information, make
sure this information is recorded on their patient or service-user record and give people with
hearing loss the opportunity to complain and provide feedback about the quality of care.
More needs to be done to make sure legal requirements are met and standards for
accessible information and communication are implemented and enforced. Research by
Action on Hearing Loss Cymru, RNIB Cymru and Sense Cymru10 shows that, a year after
the launch of the All Wales Standards in 2013, only a small proportion (9%) of survey
respondents noticed an improvement in the way health services communicate and share
information with people with sensory loss. Only a fifth (20%) had been asked about their
communication and information needs and over half (58%) did not know how to make a
complaint.
Communication support
Research shows that people with hearing loss may struggle to hear what is being said by
GPs and other health professionals due to poor deaf awareness and the lack of
communication support in consultation areas, which may lead to confusion over their
6
NHS England (2015) Accessible Information: specification. Available at:
https://www.england.nhs.uk/ourwork/patients/accessibleinfo-2/
7 RNID Northern Ireland et al (2010) Is it my turn yet? Access to GP practices in Northern Ireland for
people who are deaf, hard of hearing, blind or partially sighted. Available at:
http://www.actiononhearingloss.org.uk/~/media/Documents/Policy%20research%20and%20influencin
g/Research/Previous%20research%20reports/2010/Is%20it%20my%20turn%20yet/Is%20it%20my%2
0turn%20yet.ashx
8 NHS England (2015) Accessible Information Standard. SCCI 1605. Available at:
https://www.england.nhs.uk/ourwork/patients/accessibleinfo-2/
9 NHS Wales (2013) All Wales Standards for Accessible Communication and Information for People
with Sensory Loss. Available at:
http://gov.wales/topics/health/publications/health/guidance/standards/?lang=en
10 Action on Hearing Loss Cymru, RNIB Cymru and Sense Cymru (2014) One year on: the All Wales
Standards for communication and information for people with sensory loss. Available at:
https://www.actiononhearingloss.org.uk/~/media/Documents/Wales/One%20year%20on%20report%2
0FINAL.ashx
July 2016
diagnoses – and ineffective care. Our Access All Areas11 research showed that, after
attending an appointment with their GP, more than a quarter of survey respondents (28%)
had been unclear about their diagnosis and approximately a fifth (19%) had been unclear
about their medication. When asked why they felt unclear after their appointment, more than
half (64%) said the GP did not face them and more than half (57%) said the GP did not
always speak clearly – suggesting that, if GPs followed simple communication tips, this
could improve understanding and make treatment safer and more effective. People with
hearing aids can benefit from hearing loop systems, yet over a third (35%) said these
weren’t available.
The situation is even worse for people who use British Sign Language (BSL). English may
not be their first or preferred language – and they may need a qualified BSL interpreter to get
the most out of their appointment – but this is rarely provided. Research by the Our Health in
Your Hands campaign12 shows more than two-thirds (68%) of survey respondents who
asked for a sign language interpreter for their GP appointment didn’t get one; and more than
two-fifths (41%) felt unclear about their diagnosis because they couldn’t understand the sign
language interpreter.
NHS England’s Accessible Information Standard13 states that people with hearing loss
should have access to a National Registers of Communication Professionals working with
Deaf and Deafblind people (NRCPD)-registered communication professional if they need
one, as this provides assurance that professionals hold suitable qualifications, hold
enhanced disclosure from the Disclosure and Barring Service (DBS) and engage in
continuing professional development. The standard is clear that family and friends should
not be used as interpreters unless the person with hearing loss explicitly asks for their help
to communicate.
Without a properly qualified communication professional, people who use BSL in particular
are at risk of worse care and poor health. Research by the charity SignHealth14 shows that
over a third (34%) of people who use BSL were unaware they had high or very high blood
pressure and more than half (55%) of those who said they had cardiovascular disease were
not receiving appropriate treatment. This suggests that people who use BSL may not be
getting the care they need due to problems with communication and understanding. People
who use BSL may also benefit from health information in accessible formats such as BSL
video, but only 10 of the 900 videos available on the NHS Choices website are available in
BSL – that’s just over 1%.
Research also shows that many pharmacies are inaccessible for people with hearing loss.
Our Access All Areas research shows that just over a third (35%) of respondents said their
pharmacy consultation took place in a private room (private rooms are important for patient
11
Ringham (2012) Access All Areas. Available at: www.actiononhearingloss.org.uk/accessallareas
Our Health in Your Hands (2012) Survey of BSL users about access to communication support in
healthcare. Available at: https://www.actiononhearingloss.org.uk/get-involved/campaign/equaltreatment/the-problem/survey-of-bsl-users.aspx
13 NHS England (2015) Accessible Information Standard. SCCI 1605. Available at:
https://www.england.nhs.uk/ourwork/patients/accessibleinfo-2/
14 SignHealth (2014) Sick of it. Available at: http://www.signhealth.org.uk/sickofit/
12
July 2016
confidentiality but can also aid communication by reducing background noise) and only a
small proportion (8%) said that a hearing loop system was available.
Recommendations
We recommend the following to make sure people with hearing loss don’t face unnecessary
barriers to communication when accessing health services.
Governments and NHS organisations across the UK should:
 Enforce the Equality Act (and the Disability Discrimination Act in Northern Ireland) to
make sure people with hearing loss are protected from discrimination and to ensure
health services make reasonable adjustments.
 Raise awareness of equalities legislation amongst health services and the public.
 Make sure mandatory standards for accessible communication and information are in
place and properly enforced. Performance against standards should be routinely
monitored, including through inspections, and results should be published.
o In England, NHS England should provide funding, resources and training to help
services meet the requirements of the standard. NHS England, the Care Quality
Commission (CQC) and Healthwatch England should work together to enforce
the Accessible Information Standard.
o In Wales, Local Health Boards (LHBs) should set out and enforce a timetable for
implementation to make sure the All Wales Standards for Accessible
Communication and Information are properly met.
 Sources of health information available to the public, such as NHS choices, NHS Direct
and NHS Inform, should ensure they accessible to BSL users.
Contacting health services
 Health services should provide a range of contact methods such as SMS, email, online
booking, textphone or Text Relay for people with hearing loss who find it difficult or
impossible to use the telephone.
Visiting health services
 Health services should provide deaf awareness training for staff and make sure waiting
areas are accessible for people with hearing loss. For example, hearing loop systems
should be available on the reception desks for people who use hearing aids.
 People should be asked if they need help to communicate and understand written
information and their needs should be recorded on patient or service-user records. Staff
should know when to take action, to make sure people with hearing loss get the support
they need when they contact health services or attend appointments, in line with
standards for accessible communication and information.
 Health services should promote reasonable adjustments and processes should be in
place to make sure people with hearing loss can give feedback about the quality of care.
Communication support
 Health services should provide training to make sure GPs and other health professionals
are deaf aware, and technology such as hearing loop systems should be available in
waiting areas and consultation rooms for people who use hearing aids.
July 2016

A communication professional, such as a BSL interpreter, should be available for
everyone who needs one, in line with standards for accessible communication and
information.
Action on Hearing Loss will:
 Work with the NHS across the UK to make health services more accessible for people
with hearing loss.
 Raise awareness of the standards for accessible communication and information and
provide information and guidance so that people with hearing loss know what they
should expect from health services – and what action they can take if these expectations
aren’t met.
Resources
When you need to see a GP – guidance for patients and GPs
https://www.actiononhearingloss.org.uk/supporting-you/when-you-need-to-see-a-gp.aspx
Best practice guidance in creating accessible primary care for people with hearing loss
http://www.rnib.org.uk/best-practice-guidance-creating-accessible-primary-care-servicespeople-sensory-loss
NHS England’s Accessible Information Standard
https://www.england.nhs.uk/accessibleinfo
All Wales standards for people with communication and information for people with sensory
loss
http://gov.wales/topics/health/publications/health/guidance/standards/?lang=en
Access All Areas
http://www.actiononhearingloss.org.uk/accessallareas.aspx
July 2016