22 May 2025

NCHA Scotland responds to the Scottish Government’s Implementation of the Review of Audiology Services in Scotland

Children with hearing loss need timely access to high-quality care, and the NHS must prioritise their needs. Therefore, NCHA Scotland welcomes the progress being made in this essential area as set out in the Minister's update to the Health, Social Care and Sport Committee.

The implementation report shared by the minister is right to state that professional regulation works best on a UK-wide basis to maintain professional mobility and prevent professionals from relocating to avoid disciplinary measures. This way of working is already the case in primary care audiology, which relies on HCPC-registered audiologists. In contrast, hospital audiologists can work without being regulated or they can volunteer to join a PSA accredited register. NCHA Scotland believes that regulation should focus on protecting the public, and the HCPC should regulate all audiologists. We look forward to working with all UK governments on this vital public protection issue.

The report also acknowledges the need to ensure adults get access to timely, high-quality care. However, unfortunately, our recent FOI research shows that many audiology patients still suffer avoidable long waits, and there is no quality assurance system in place. Therefore, we welcome the government prioritising work on evidence-based quality assurance systems. However, we believe public consultation is the best way to achieve this and maximise transparency and accountability on patients' behalf.

To solve issues in NHS audiology in Scotland, services must urgently be redesigned around patients, not professional or provider interests, by following the epidemiological, clinical and economic evidence and asking patients what they want. This evidence will strongly support the need for an NHS primary care audiology service across Scotland. So, we welcome the report stating there is "enthusiasm and willingness to investigate opportunities to deliver meaningful and sustainable change for our population", including developing a community audiology service.

We look forward to being invited to be part of those discussions with the Scottish Government, hospital and health board colleagues.

Colin Campbell, chair of NCHA Scotland, said: "The first wave of this work has rightly focused on addressing gaps in training that led to significant safety risks in paediatric audiology. The challenge is that the workforce and capacity crisis in hospital audiology make it an unsafe and unsustainable model of care. It is not fair to expect hospital audiologists to solve these structural issues. It is now more urgent than ever to include primary care audiology in all discussions if the NHS is to avoid further risk and costly delays. We stand ready to share our expertise and to help the Scottish Government and health boards with the exploration and implementation of primary care audiology opportunities - in any way we can."