New Zealand Audiological Society proposed new clause - Code of Ethics
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17 August 2012
New Zealand Audiological Society
Enquiry: New Zealand Audiological Society proposed new clause
Thank you for the opportunity to comment on the New Zealand Audiological Society's (NZAS) proposed amendment to clause 4.1 of the NZAS Code of Ethics. It appears that the reason for the change is to allow NZAS to impose expectations regarding the professional independence of audiologists while recognising the practical realities of clinic ownership and other financial arrangements. I commend NZAS for recognising the importance of such expectations, particularly in light of our recent correspondence about the disclosure of financial conflicts of interest by individual audiologists and/or the audiological clinics to consumers when providing audiological services.
I am pleased to see that the proposed new clause emphasises transparency in the provision of information to consumers and recognises the paramount importance of the best interests of such consumers. However, I consider that the proposed clause could more clearly highlight the importance of consumer choice in the informed consent process.
Consumers should be presented with appropriate options prior to recommendation(s) being made by the audiologist. The ultimate choice must then rest with the consumer. I therefore suggest a slight change to the proposed new clause as outlined below in italics:
"Members must maintain professional independence at all times. This means acting in the best interests of consumers of audiological services, free from commercial pressures. Accordingly, audiologists must have the freedom and discretion to present appropriate options to the consumer and then, if appropriate, make recommendations on whatever brand or model of hearing aid and other related accessories, will best meet the consumer's needs. It is then up to the consumer to make a choice as to which, if any, to select.
I agree that consumers should be informed about any commercial relationship between an audiology clinic and a manufacturing company. However, there may be other financial conflicts of interest, apart from ownership, that are not necessarily covered by the proposed new clause. For example, where an audiologist is self-employed, that audiologist is not required to disclose any commercial relationship they may have with a manufacturer, or an audiology clinic that is owned by a manufacturer. There may also be other situations where financial incentives and/or pressures operate independently of ownership structures. In light of this, I recommend that the proposed new clause be amended to apply to all potential, apparent or actual financial conflicts of interest, however they arise or are structured.