Page last updated: 28 September 2020
This statement provides an overview of the key issues affecting people who are deaf or have hearing loss in the context of the UK’s coronavirus response. It also sets out Action on Hearing Loss’ recommendations for action.
There are 12 million people in the UK with hearing loss, including an estimated 900,000 with severe or profound hearing loss. We know that it is older people who are at higher risk of becoming severely ill due to coronavirus. With more than 70% of people over the age of 70 living with hearing loss, the needs of this group must be taken into consideration in the UK’s response.
Due to the fast-moving nature of events and changing guidance, we will update this statement on a rolling basis. If you would like to confirm that you have the latest version, or for further information, please contact:
Ayla Ozmen, Head of Research and Policy:
- 07787 538267
The Equality Act requires reasonable adjustments to be made to support disabled people, including providing information in an accessible format. The Accessible Information Standard (AIS) puts a legal requirement on all health and social care providers to provide information in people’s preferred format. People’s rights under this legislation must be upheld, even in these unprecedented times.
We welcome that the majority of audio public health messaging currently available is subtitled, though this isn’t always the case. A large proportion of current public health messaging also remains inaccessible to British Sign Language (BSL) users. For many of those whose first language is BSL, reading written English can be difficult. Critical information on the GOV.UK website for example, including information on testing, is not accessible. In addition, the Government has been slow to develop BSL versions of vital mailings sent to the public, such as the shielding letter and subsequent mailings to the shielding group. Information in relation to local lockdowns has also been largely inaccessible.
There also needs to be further clarity on the accessibility of the Government’s Test and Trace programme. We were made aware that the Test and Trace information line had been made available via video relay, however, this information was not available on any Government web page or any Government resource. We did a poll to ask whether BSL users were aware of this access option, a huge 94% said they were not. In light of this, the Government has begun advertising the availability of video relay, which is very welcome. It remains unclear, however, if or when the App will be made accessible to BSL users.
With regard to broadcast media, BSL versions of the day’s news are available at limited intervals of the day. With significant announcements being announced at short notice however, timely access to information has become more important than ever. Government’s decision to work with broadcasters to provide live BSL interpretation for the daily press conferences was therefore a very welcome step that should continue now the press conferences are no longer taking place on a daily basis. There was, however, unfortunately no BSL interpretation for the critical announcement that took place on 23rd March or for the Prime Minister’s return to work speech on 27th April. In addition, although the Government has now made the in-vision BSL interpreter for press conferences available for use by all broadcasters, this is not being adopted more widely and is still only featured on the BBC News channel and the Government’s own social media channels. The online dashboard which has replaced the daily briefings is also unavailable in BSL.
We, along with other leading disability charities, wrote to the Prime Minister calling for urgent action in this area. We are very pleased that as a result of this, a named senior lead has now been identified to lead work on accessible Government communications. On the request of the new lead, again in conjunction with other disability charities, we have produced a ‘shopping list’ of accessibility requirements for broadcasting, social media, websites, mailings, contact methods and apps.
The Government should work with the disability sector to ensure accessibility is built into all public health communications from the outset.
Remote appointments, PPE and communicating with people with hearing loss
The latest Office of National Statistics (ONS) report on coronavirus and the social impacts on disabled people in Great Britain: July 2020, showed that 47% of people with a hearing impairment have reported that coronavirus has impacted their access to healthcare and treatment for non-coronavirus related issues, compared to 16% of non-disabled people.
People who are deaf or have hearing loss rely heavily on visual cues for effective communication. These include body language, gestures, facial expressions and lip reading. Being able to see lip patterns and facial expressions is also vital for those who communicate through BSL.
People are currently being encouraged, and choosing, to have health and social care appointments and interactions over the telephone but for many people with hearing loss, telephone conversations, in which visual cues are lost, are difficult or impossible. For some, in some circumstances, video conversations are also difficult.
Under the AIS, all health and social care providers must identify, record and meet people’s specific communication needs, many of which will have, until now, been met by face to face contact. Even in these exceptional times, however, accessible standards must still be upheld and there are simple options that will improve the accessibility of services for those who are deaf or have hearing loss. These include using screens with captions where possible and utilising and advertising Text and Video Relay Services. See our communication advice for health and social care professionals here. See also, communication advice produced in conjunction with other charities here.
Services should, in particular, consider the most appropriate means of providing interpretation to BSL users. Remote or video interpreting is not always appropriate for medical appointments, BSL is a 3D language and having medical jargon provided on a 2D screen increases the risk that miscommunications and misunderstandings will occur. We would not want to see a blanket policy to provide all interpretation remotely. Decisions need to be made in consultation with the patient and based on their communication needs. Service providers should utilise new guidance on working in medical settings during Covid-19 from the Association of Sign Language Interpreters (ASLI) when deciding how to provide interpretation to patients.
People who are deaf or have hearing loss have also told us that they are struggling to communicate with health and social care professionals during face to face consultations and interactions as a result of visual cues being masked by Personal Protective Equipment (PPE). Those health and social care professionals who themselves have hearing loss are also struggling with this barrier. Whilst we of course want to keep people as safe as possible and advocate following current public health guidance to ensure this, for some people with hearing loss in health and social care settings a safety risk can also be presented by inaccessible communication.
As all hospital staff are now required to wear Type 1 or 2 surgical masks at all times, and all hospital visitors and outpatients are expected to wear face coverings, this challenge has been significantly exacerbated. Recent advice issued by the World Health Organisation states that if a policy of targeted continuous medical mask use is adopted, the disadvantages that this brings to people who are deaf or hard of hearing should be ‘carefully taken into account.’
We called on the Government to provide urgent clarity for health and social care providers on how to fulfil duties under the Accessible Information Standard in the context of widespread PPE use. With a number of designers and manufacturers around the world developing transparent masks that enable lip reading, we also called on the Government to assess the safety and viability of these products for use in health and social care services in the UK.
We are delighted, therefore, that a Type 2R transparent mask has now been approved for use and that the mask is currently being made available to NHS Trusts and social care providers across the UK.
We are pleased also that guidance has been issued to NHS Trusts clearly stating the barrier that PPE presents to those with hearing loss, as well as giving tips on how to communicate with people with hearing loss when wearing PPE. The guidance says that where possible, clear masks should be used by staff to communicate, or alternative communication methods such as speech to text apps and video relay can be used. We understand that the guidance also allows for exceptions to be made to the wearing of face coverings on an individual basis.
We also welcomed the limited reference in the Government’s recent guidance on PPE in care homes to the scenarios in which PPE presents significant difficulties for some. Whilst this is welcome, comprehensive guidance on how to communicate with people with hearing loss when wearing PPE must be issued to all health and social care providers, as this is a challenge that goes beyond hospital and care home settings.
Additional barriers are also emerging as the lockdown begins to be eased. Many health and social care settings are putting in place practices that will present additional barriers to people who are deaf or have hearing loss, such as screens in waiting areas.
In addition, as the lockdown is eased and the Government begin to reflect on what measures put in place during this period have worked well and should continue, there is a risk that remote services and further existing or anticipated barriers will be adopted for the long term without taking into consideration the needs of people who are deaf or have hearing loss. Indeed, the Secretary of State for Health recently announced that going forward, GP appointments would be remote by default.
The Government and professional bodies should promote simple options for meeting communication needs, amongst health and social care professionals.
The Government should issue guidance to all health and social care providers on how to fulfil duties under the Accessible Information Standard in the context of widespread PPE usage.
The Government and health and social care commissioners and providers should consider the unintended consequences for disabled people of new measures put in place when easing the lockdown and beyond.
Social distancing measures
The May Office for National Statistics (ONS) report on coronavirus and the social impacts on disabled people showed that concerns about access to essentials tended to be most frequent among those with hearing or dexterity-related impairments. During lockdown, those with hearing loss who were required to shield told us that they were unable to list themselves as a priority for supermarket deliveries as the only point of contact was the telephone. It is essential that other accessible communication channels are provided and advertised by all essential services.
The latest ONS report from July shows that concerns about access to essentials continues to be a concern for people with hearing impairments. 50% of people with a hearing impairment reported that coronavirus has impacted their access to groceries, medication and essentials compared to 17% of non-disabled people.
It is also important that people with hearing loss are considered as shops and services re-open with social distancing measures in place. The use of face coverings, social distancing and Perspex screens in retail outlets is creating new barriers for people with hearing loss. In addition, shops are implementing measures like queuing and one-way systems which need to be actively and visually communicated to customers. Any failure to make these adjustments accessible to people with hearing loss could see them inadvertently break the rules and suffer social consequences such as peer policing.
The guidance issued by the Department for Business, Energy and Industrial Strategy makes limited references to disability and the need to make reasonable adjustments on behalf of either staff or customers. The guidance needs to ensure that outlets are aware of the need to practice deaf and disability awareness and shows where barriers can be overcome – for example by reducing background noise and using induction loops. The guidance also encourages stores to utilise ‘social distancing champions’ and position colleagues to manager customer flow; staff undertaking these roles should have received deaf awareness training and know how to communicate effectively.
Face coverings for the general public are now mandatory in England on public transport and in shops, supermarkets, and in other specified enclosed spaces where social distancing is not possible. Face coverings are now also mandatory for staff in retail, hospitality and taxis.
We welcomed the legislation and Government guidance which explicitly states that those travelling with or providing assistance to people who rely on lip reading to communicate, as well as others with a ‘reasonable excuse’, are not required to wear face coverings on public transport. We also welcomed the extension of these exemptions to apply in all settings in which face coverings are mandatory.
Because hearing loss is a hidden disability, however, despite these exemptions, many remain concerned that they will face abuse or negative reactions from the public if they request people remove face coverings to communicate or if those accompanying them remove their coverings.
Face coverings with clear panels, which allow for lip reading, are available for purchase in the UK. Some members of the public have also chosen to make their own face coverings with clear panels at home. There are a number of links available online that demonstrate how to make these. Although we are aware that some such face coverings steam up, preventing lip reading and that others may reduce the sound level of some frequencies in speech, adding an additional challenge for people with hearing loss, people with hearing loss have overwhelmingly reported that such face coverings are more helpful for them in communicating with people than the standard coverings used. Much of the general public, including employers and those working in the community, however, are unaware of the existence or need for such face coverings.
The Government has confirmed that they are currently looking into the possibility of a wider review of the safety of face coverings with a clear panel which is needed before they are able to promote their use. This is very welcome, though must be done with some urgency. In the meantime, the Government has confirmed that coverings with a clear panel, so long as they cover the nose and fit underneath the chin, do fit within current specifications and are an acceptable form of covering where this is a legal requirement.
In addition to the challenges that face coverings bring in terms of preventing lip-reading and muffling speech, some have also reported challenges with face cover straps and behind the ear hearing aids. There are clips that you can purchase that may help with this. Some patterns for home-made masks also have ties at the back of the head rather than behind the ears.
In light of these significant challenges, deaf awareness amongst the public becomes even more vital than ever and many of the tips we suggest for use by health and social care professionals can be adopted by other services. We have also produced tips for use by the general public and an exemption card which can be used to help you communicate your needs.
The card was developed in light of our research findings which indicated a demand for a card which people with hearing loss could use to notify others of their condition, highlight the exemption for those assisting them and indicate the need for changes to meet their communication needs. A majority of respondents to our survey suggested this card should be available on national and local government websites. We therefore welcome the Government’s creation of an exemption card and badge which includes a version stating ‘please remove your face covering so I can understand you better’.
The Government has recently launched an extended iterative campaign to improve awareness of face coverings amongst the general public, particularly with regard to when and where to wear them, including exemptions. This is welcome and we are working with the Government to ensure that the campaign incorporates the below recommendations.
The Government should work with supermarkets and other essential service providers to ensure that people with disabilities are not excluded from accessing essential services.
The Government should ensure that the guidance issued to retail outlets includes information on how to mitigate the barriers caused by social distancing on people with hearing loss, and that staff given prominent roles to support people using outlets in new ways have received deaf awareness training.
The Government should raise awareness amongst the general public, transport operators and retailers of the exemptions to mandatory face covering.
The Government should provide clarity on and improve awareness of the face covering options that are safe and available to make and purchase.
The Government should raise awareness of the challenges faced by people with hearing loss amongst employers and the general public and share tips to meet communication needs.
The World Health Organisation published a statement on 21 August advising that “children aged 12 and over should wear a mask under the same conditions as adults, in particular when they cannot guarantee at least a 1-metre distance from others and there is widespread transmission in the area.”
The UK Government is not recommending face coverings in education settings generally, though schools and colleges will have the discretion to require face coverings in communal areas where social distancing cannot be safely managed. In local lockdown areas, face coverings are now mandatory in settings where pupils in Year 7 and above are educated for adults and pupils when moving around, such as in corridors and communal areas where social distancing is difficult to maintain.
The same exemptions as outlined above in relation to access to services also apply in education settings.
The Government should ensure that information issued to schools and parents on the use of face coverings in education settings highlights the exemptions and in particular, how they apply when communicating with children and staff who are deaf or have hearing loss.
As part of the initial response to Covid-19, NHS England and Improvement (NHSEI) issued guidance setting out how providers of community services could release capacity to support the NHS where necessary. This guidance included a partial stop in the delivery of adult audiology, with many providers only able to offer essential or urgent services. Since its publication (20 March 2020, updated 2 April 2020) some audiology providers have been able to partially resume adult services, offering face-to-face and/or remote options (telephone, video call and postal). The original NHSEI guidance has now been superseded by Implementing Phase 3 of the NHS response to the COVID-19 pandemic (published 7 August), which states that all adult and community services halted by the original guidance should now be fully reinstated.
Further to this, guidance co-written by the largest professional bodies in audiology gives practical steps on resuming activity while adhering to infection prevention and control measures. The latest update recommends offering face to face appointments to all patients as required. However resuming face to face audiology services at pre-Covid levels will not be possible for many providers, which may lead to significant variation in provision across the country. Furthermore some patients may not wish to immediately return to a clinical environment. It is fair to assume this could be a problem within audiology given that a large proportion of the case load is over 70, and therefore regarded as clinically vulnerable to Covid-19.
The new NHSEI guidance encourages using remote technology across services to facilitate the return to normal activity. The British Academy of Audiology has published guidance on utilising remote technology within the context of audiology to meet demand. Enhancing digital services is a core part of the NHS response to Covid-19 and while innovation to increase and improve access through technology is welcome, patient attitudes and experiences of remote care, including audiology, need to be the primary focus when developing and implementing new digital pathways.
Looking forward, the medium and long term impacts of the Covid-19 pandemic on NHS audiology services are yet to be fully realised. While digital remote technologies are likely to remain a permanent aspect of service delivery, it is worth acknowledging areas that may affect services in the coming months or years. For example, a latent demand for audiology assessments, and therefore an increase in waiting times, has been noted as a possible cause for concern. Some audiology providers have reported a dramatic fall in referrals for routine hearing assessments. As lockdown restrictions ease, providers may then see a rapid increase in referrals. Indeed lockdown or face covering requirements themselves may have alerted many people to unaddressed hearing loss, leading to an increase in demand. Similarly, some anecdotal and small scale research has been published suggesting a link between Covid-19 and hearing loss. While the evidence is currently very limited, we welcome calls for further high-quality investigation.
Cochlear Implant Services
As a result of the need to release capacity and mitigate risk of transmission, all elective NHS operations were cancelled, including cochlear implantation surgery. NHS England and Improvement has published surgical prioritisation guidance which sets out how operations should be prioritised as elective surgeries resume. We welcome that this guidance recognises the need for urgent cochlear implantation, in cases such as those at risk of cochlear ossification post-meningitis and pre-lingual deafness. This has been further clarified in guidance from ENT UK, stating that these cases should be implanted within 1 month.
Cochlear implant centres and advocacy groups have expressed concern over cochlear implantation surgery within the wider context of surgical prioritisation post Covid-19. There are concerns of a reduction in non-urgent adult implantations as other life-saving operations are prioritised. Furthermore, the guidance from ENT UK has not stipulated a time frame in which to carry out non-urgent cochlear implant surgery. This is especially concerning when it is estimated that around only 5% of adults in the UK who could benefit from a cochlear implant actually have one. Recent efforts from cochlear implant advocacy groups have been focused on increasing uptake and the effects of Covid-19 have the potential to reverse this vital work. Encouragingly we know some CI centres are now accepting new referrals, however there is likely to be a reduction in referral numbers, due to an overall reduction in adult patients being seen in audiology, ENT and general practice.
Audiology services should facilitate remote delivery where possible and appropriate, ensuring those who cannot access remote delivery are prioritised when face-to-face services resume.
Allocate funding for large scale and detailed research to investigate the link between Covid-19 and hearing loss.
NHS Trusts should treat specific cases of cochlear implantation surgery as a priority and ensure non-urgent implantation is prioritised as elective surgeries resume.
Remote working and social distancing
Society’s response to Coronavirus has radically changed the way we are working. This has largely been caused by the closure of workplaces, remote working and the imposition of social distancing and other safety measures for workplaces which have either remained open or are now beginning to re-open across England. These changes have created additional barriers for many disabled people, including those living with deafness and hearing loss, which threatens to undermine their employment prospects. Even before the crisis, people with hearing loss were marginalised in the workplace and our research demonstrates that poor employer attitudes and a lack of support and guidance on making reasonable adjustments has denied people with hearing loss the opportunities their talents deserve.
We fear that without the provision of clear guidance and additional support for employers, disabled people, including those with hearing loss and deafness, will suffer redundancy, unemployment and furloughing disproportionately during this crisis. A recent report from Citizen’s Advice shows that 1 in 4 disabled people (27%) are facing redundancy. This rose to 37% of those who said their impairment or condition has a large impact on their day-to-day life. This compares to 1 in 6 across the population.
Additional barriers for people living with deafness and hearing loss
On 12th May the UK Government issued guidance to workplaces in England setting out how to work safely during the coronavirus pandemic with a view to reopening a number of workplaces. The Government produced fourteen guides covering different types of workplaces. These contained advice which would impose noticeable barriers for some people with deafness and hearing loss. Relevant advice which could make working life harder for people with hearing loss includes:
- people work back-to-back rather than facing each other
- physical barriers are erected between workstations
- face masks can help reduce transmissions
- people to be stationed two meters apart.
When these guidance documents were first issued they made no reference to disability or the need to make reasonable adjustments for disabled people. This was a mistake and meant that at a time when many organisations where consulting the guidance, rearranging the workplace and conducting their Covid risk assessment they were not being forced to consider the needs of disabled staff. We welcome the fact that subsequent updates have stated the need to ensure that employers continue to make reasonable adjustments to support disabled employees. However the guidance documents offers no further information on how this can be do, nor does it signpost to existing support for employers on the law relating to disability employment or the practical support which already exists.
It should also be noted that the number of people working from home has nearly quadrupled since the imposition of the lockdown and that this will also create new and different access requirements for people living with hearing loss. For many people the increased use of telephone and video conference will create barriers and mean that they will need new adjustments.
Action on Hearing Loss has provided advice and communication tips which respond to the barriers created by social distancing and homeworking and information for employers on how they can support their staff with a hearing loss through the imposition of Covid secure guidance.
Action on Hearing Loss has produced extensive research showing the problems that people with hearing loss face in the workplace: including the lack of confidence that business leaders have in communicating with those with hearing loss, their inability to access information and support to understand disability employment and the steps they can take to support people, and the perception that people with hearing loss can be a health and safety risk. If employers struggle to respond to disability and hearing loss in normal times then it is even more essential in the current situation – where workplaces are having to be re-designed almost overnight – that they are provided access to simple advice.
This guidance needs to contain advice on how to resolve conflicts between social distancing measures and the needs of disabled people. The Government should liaise with organisations, like Action on Hearing Loss, to produce tailored guidance which states how barriers created by social distancing can be overcome or mitigated for people with different disabilities. This information should be published through the Disability Confident scheme and signposted within the fourteen guidance documents from the Department for Energy and Industrial Strategy on safe working mentioned above.
Access to Work
The closure of workplaces and imposition of new safety measures has had a major impact on the way people work and for disabled people this will require substantial changes in the support they receive through the Access to Work scheme. For many people with hearing loss, especially BSL users, their existing Access to Work package will no longer meet their needs, either in relation to the type or amount of support they require. For example, somebody with an allocation of in-person BSL interpretation will now need to consider remote interpreting, which might not be provided for in their existing grant.
We welcome the steps that the DWP have taken to increase flexibility for people with Access to Work grants, including the extension of support to people who are now working from home. We also welcome that a physical signature from a line manager is no longer required to process payments within the scheme.
It is important that these changes are communicated to frontline Access to Work Advisors and Assessors; too often in the past welcome changes in Access to Work policy have not been reflected in the real-life experience of scheme users. It is also crucial that the process of workplace assessments is updated to ensure that people working from home are given accurate assessments which provide effective support.
We have received feedback that the changes to the scheme have not been communicated to existing scheme users, meaning that many people have not claimed the additional support they need.
Access to Work remains the ‘Government’s best kept secret’ with our evidence showing that the majority of business leaders and people with hearing loss have not heard of the scheme. This is an ongoing problem, but with many people with hearing loss being faced with additional barriers because of Covid it has become even more important to promote the scheme to employers and employees.
The Government should signpost to its existing (albeit limited) resources on disability employment and work with expert organisations, like us, to provide further guidance on how to overcome or mitigate the additional barriers social distancing creates. This guidance should be promoted alongside guides to support disabled staff working remotely from home.
The Government should ensure that Access to Work implements the additional flexibility to existing scheme users which has been announced, in relation to both the support they receive and the way that the scheme is processed. This flexibility should be communicated to scheme users, and their employers, as soon as possible.
The Government should also promote Access to Work to employers and employees so that people who need additional support for the first time because of remote working or social distancing are encouraged to make a claim.
Increased isolation will inevitably affect many people’s well-being and mental health due to a lack of social contact and difficulty accessing support. People who are deaf or have hearing loss are at greater risk of further isolation due to social distancing measures, as well as increased use of masks and face coverings.
Whilst many are increasingly turning to the telephone to maintain contact with friends and family, this means of contact is inaccessible to many who are deaf or have hearing loss. In addition, whilst initiatives to tackle social isolation during the pandemic are underway, these initiatives primarily involve moving support online. For BSL users and those with hearing loss this does not necessarily provide the same level of accessibility, especially for older people who might lack the necessary digital skills.
The May ONS report on coronavirus and disability showed that just 14.7% of people with a hearing impairment reported visiting green spaces – the lowest percentage of all disabled groups. In addition, 54.8% of people with a hearing impairment reported leaving their home in the past week, compared to 80% of disabled people with a mental health impairment. Older age is associated with an increasing prevalence of some impairment types (for example, mobility or hearing impairments) and with decreasing likelihood to report leaving the home.
The latest ONS report from July highlights the increased prevalence of loneliness for people with a hearing impairment. 64% of people with a hearing impairment reported feeling lonely either always, often, some of the time or occasionally, compared to 44% of non-disabled people.
We welcome the Government’s new campaign to tackle loneliness during the coronavirus lockdown. We must remember, however, that the coronavirus pandemic will begin to recede, but unfortunately, loneliness and social isolation will remain for many who are deaf or have hearing loss.
Recommendations: The ONS should control for age in future analysis of isolation amongst disabled people.
The Government should ensure that loneliness stays high on the agenda through the coronavirus pandemic and beyond.
Recently published ONS data shows that people who said they are ‘limited a lot’ by disability are twice as likely to die from coronavirus than non-disabled people.
The Government should ensure further research is carried out into the causes of disabled people being twice as likely to die from coronavirus.