Jen Rohrig Design

I intend to continue researching this as I do believe it’s a complicated subject but I also wanted to write down my initial thoughts on Over the Counter (OTC) Hearing Aids. OTC Hearing Aids are not a new idea but this week the FDA finalized their proposal for the concept and they could become available as soon as October. The OTC hearing aids are meant to be only for adults with mild to moderate hearing loss.

The initial proposal: FDA Issues Landmark Proposal to Improve Access to Hearing Aid Technology for Millions of Americans, was published in October 2021.

The proposal came as a result of President Biden’s July 2021 Executive Order on Promoting Competition in the American Economy, which called for the FDA to take steps to allow hearing aids to be sold over the counter because of the following:

“Hearing aids are so expensive that only 14% of the approximately 48 million Americans with hearing loss use them. On average, they cost more than $5,000 per pair, and those costs are often not covered by health insurance. A major driver of the expense is that consumers must get them from a doctor or a specialist, even though experts agree that medical evaluation is not necessary. Rather, this requirement serves only as red tape and a barrier to more companies selling hearing aids. The four largest hearing aid manufacturers now control 84% of the market.”

All of the issues mentioned in that paragraph are true – mainly that hearing aids are expensive and they’re not covered by insurance. However, I’m very concerned about this part of the above quote: “experts agree that medical evaluation is not necessary” as I don’t believe this is true for a number of reasons. The first being – how does one know what their level of hearing loss is without a hearing test? How do they know there’s not some other issue causing what appears to be hearing loss?

Second, hearing aids are meant to be programmed according to an individual’s audiogram. Correctly programmed hearing aids only amplify the frequencies that a person has trouble hearing, in no way is this a simple increase in volume. This means a medical evaluation is needed to obtain an audiogram for correctly programmed hearing aids. In addition, hearing aids can be programmed to reduce background noise and other issues – can these OTC hearing aids do that?

My concern is that people will purchase these hearing aids without being fully aware of what they’re doing and cause more harm than good. They may believe OTC Hearing Aids are similar to the reading glasses available at many stores, but this is not the case. While the FDA proposal does indicate there should be a requirement for maximum volume and other safety features I remain concerned about what it means for people who obtain them without being fully aware of all of the issues. As it stands I don’t think people are fully aware of how hearing aids are programmed nor do I believe they realize they have to be maintained in order to continue functioning. At least not those who are just realizing they have a hearing loss.

Jaipreet Virdi’s article The Unintended Consequences of OTC Hearing Aids | WIRED does a good job of exploring many of the issues with OTC hearing aids, beyond what I wrote above including the following:

What needs to change then, is how we perceive hearing aids in the first place. Rather than leaning heavily on the implication that hearing aids are inherently embarrassing, these devices should be marketed as tools for highlighting the vitality and richness of deaf experience, of which wearing hearing aids—OTC or not—is one approach. More crucially, manufacturers need to collaborate with deaf users and designers to improve features that better benefit the variety of customers: greater longevity, improved battery power, options for aesthetic features, and affordable models for all degrees of hearing loss.”

I’m aware a lot of this is about having choices and not wanting to deal with the medical establishment. I’m also aware that this has the potential help those who could never afford hearing aids in the first place – at least those with mild to moderate hearing loss. It’s one reason why I want to keep researching it. I’m also aware I’m coming at this from the side of having been hard of hearing from birth so I’ve always gone to audiologists to obtain hearing aids and other services from them. I don’t know what it’s like on the other side – slowly losing your hearing. But I also think that’s why we need to change the perception of hearing aids as Jaipreet Virdi says in the quote above.

A lot of people will ask that question because for the most part they go through their lives without needing to think about how difficult things can be. Sometimes even when they do experience some difficulty they’ll think “that’s just the way the world is” without considering if it could be better. Sometimes the only reason why things are at least somewhat accessible is because it’s the law.

A blot post from AssistiveWare asks Why isn’t the world accessible in the first place? for Global Accessibility Awareness Day.

If we believe that accessibility is important and we should be implementing it, why don’t we already consistently and thoroughly account for disability in design? Is it just a knowledge gap, or is there more at work?

In my previous post The ADA at 32 I talked about how many people don’t really have a full understanding of the limites of the American’s With Disabilities Act. They will talk about how things are “illegal now” or to simply “call the ADA” to report issues. Things can and should be made better and it’s a struggle to get people to understand why things should be improved for all of us. I also included a few links in that post about how the ADA does not go far enough.

My answer to “why bother?” is “why not?” – I mean honestly why not make things accessible to everyone? The problem is as I said above the majority don’t even see the problems that do exist. It isn’t a problem for them so they don’t bother thinking about it. As a result accessibility depends on people actually fighting for it and continuing to make noise about the various issues that exist.

Accessibility Benefits Everyone

But let’s look at it another way – accessibility isn’t just for disabled people, when done correctly it can benefit everyone.

Why Designing For Accessibility Helps Everyone written by Daniel Abrahams at Access Innovation Media:

Automatic doors can also save businesses money – they open only when needed, they cut down on energy waste which directly implies a reduction in heating costs plus no fingerprints on the doors either so no need for extra cleaning.

Getting Accessibility Right

We still need to make sure things are accessible to all those who need it. Often accessibility is denied without thought because someone believes it isn’t worth the cost or the time. Sometimes it’s about a lack of awareness of what is needed or assumptions being made about the types of accommodations that should be offered.

For example I’ve seen situations where only a sign language interpreter was offered and when captioning was requested as well it was denied because “there’s an interpreter provided” – which ignores the fact that many who are hard of hearing don’t know sign language and still need captioning. Of course there’s also the assumption that automocati captions are good enough without realizing just how bad auto captions are.

Another example is in webinars the sound quality may be bad and when it’s pointed out people are directed to the captions that exist. The problem with this is that people with cognitive issues may not be able to read the captions and are depending on good sound quality.

In both examples any attempts to point out issues are dismissed because people believe what they have done is enough.

About Competing Accessibility Needs

Competing accessibility needs do exist. Sometimes making things accessible for one group will make things inaccessible for another. Attempts to mitigate the problems should be made but it should also be acknowledged that it isn’t always possible. There are things that should be done to address the issue however.

Understanding Competing Accessibility Needs by Brooke Winters at Thinking Person’s Guide to Autism:

It may not be possible to make every single event accessible to every disabled person but there are steps we can take to make sure that every disabled person has events that are accessible to them.

Final Thoughts

Accessibility is always a work in progress and I believe we should always try to do better. We should notice when things are difficult and we should make noise about it when possible. It’s important to remember that the Americans With Disabilities Act often depends on disabled people to voice complaints about inaccessibility before anything is done. Nothing changes unless someone says something so people should say something.