AUDIOLOGICAL SOCIETY OF AUSTRALIA Inc.
ADVERTISING GUIDELINES
- General principles in advertising
- Accuracy in advertising
- Full disclosure in advertising
- Advertising and other members
- Vulnerable clientele
- Use of the word ‘free’ in advertising
- Treatment and devices
- ASA Code of Ethics
- ASA Standards of Practice
- Advertising and the law
- Advertising and the ASA
- Using membership of Audiology Australia in Advertising
Introduction
These advertising guidelines are provided for the benefit of ASA members. Members
are strongly encouraged to consider them when engaging in advertising. Businesses
with interests in the field of audiology are encouraged to consider these guidelines
also.
The ASA Marketing guidelines are intended to include (but are not limited to) broadcasts, printed matter, telemarketing, press releases, community forums or web-based promotion. Advertising includes promotion to the public at large as well as to other businesses or members.
The following guidelines are not binding and do not therefore represent any restraint on trade. Further, by their nature, they cannot cover every contingency in the choices confronting members when publicly presenting their best face. Members are encouraged, however, to recognise that advertising methods will affect the public perception of themselves as individuals, the clinics they work in and the entire profession. The application of simple discretion and an adherence to the following guidelines and their spirit, are principles which will hopefully serve as a useful compass for members.
1 General principles in advertising
The purpose of advertising includes the promotion of oneself, one’s business
or the services offered. It is a means of attracting the attention of potential
clients to services and providing information about the same.
1.1 Advertising should be of value to the target.
1.2 Effective advertising typically includes the name, contact details, phone
number, availability and services provided by the member or business.
1.3 Advertising should allow potential clients insight into the availability and potential appropriateness of services, devices or treatments as it may apply to them.
1.4 Advertising should not be unprofessional and members should avoid being excessive or vulgar in self promotion
1.5 Whether advertising is directed to peers or the public, client welfare should always remain the primary concern of ASA members
2 Accuracy in advertising
2.1 Members should not profess or imply that they possess specific skills or
qualifications which they do not hold.
2.2 Advertising of devices and products should not lead to unrealistic expectations of positive outcomes.
2.3 Advertising statements should be factual and avoid persuasive language.
3 Full disclosure in advertising
3.1 If a member is attending a forum (wholly or in part) for the purposes of
promoting treatment, devices or one’s business interests, this should
be easily understood by a naïve observer.
3.2 Advertising that intends to promote a business, treatment, device or member should clearly identify any affiliation not otherwise clear to the naïve observer.
3.3 Advertising that intends to promote a business, treatment, device or member should also include the name of that business, treatment, device or member by name.
3.4 When promoting a device, treatment or business any fiduciary interest not readily apparent to the target, should be clearly stated.
4 Advertising and other members
4.1 Advertising should not bring the profession into disrepute
4.2 Advertising should never undermine public confidence in the profession.
4.3 Members should not advertise themselves in a manner which states or implies ineptitude or undesirability on the part of other members or businesses. Use of superlative terms to describe members implies superiority of skills and is discouraged.
4.4 It is inappropriate for members to advertise superiority of skills over other members. Value judgements should not be made regarding the comparative competence of other members and subjective comparisons are also inappropriate.
4.5 Members should not advertise themselves with regard to any specific role they perform for the ASA. Active participation in the ASA is not considered a guarantee of clinical excellence. The use of ASA roles in advertising oneself potentially implies harmful and unfair subjective comparisons to other, less active members.
4.6 Members should not advertise themselves on the basis of other voluntary or professional positions that they hold outside of the specific role which is being promoted by the advertising material.
5 Vulnerable clientele
Many clients and potential clients of members are elderly, vulnerable or otherwise
susceptible to being misled. Members should work to avoid the reality or perception
of unfair treatment.
5.1 Advertising should be as transparent as possible
5.2 All advertising should be accurate, balanced and any statement of fact should be able to be easily understood by vulnerable people.
5.3 Testimonials of outcomes by private individuals are discouraged as they may lead to unrealistic expectations of outcomes for potential clients.
5.4 Advertising by members should not contain any falsehood, deception or misrepresentation.
6 Use of the word ‘free’ in
advertising
6.1 Any disclaimers regarding ‘free’ treatment should be clear to
a naïve person and easily visible in all advertising.
6.2 Where a member or business provides ‘free’ as well as other
services, treatments or devices available for a fee, advertising should not
imply that this entire range of treatment will be provided without direct cost.
6.3 Members and businesses should not advertise ‘free’ services
without genuine intention to supply them.
6.4 Any advertising of ‘free’ services should also include other information for the target to make an informed decision before selecting a member for service provision.
7 Treatments and devices
7.1 Members engaged in advertising should recognise that there are no universal
solutions to client needs. Devices and treatments should not be promoted in
this manner.
7.2 Practitioners should not publicly endorse specific devices or treatments in advertising material, as this may be perceived as a general recommendation of appropriateness to each and every client.
7.3 Practitioners should not recommend any treatment or device without thorough assessment of a client.
7.4 In the interests of maintaining professional dignity, treatments and devices should not be promoted solely on the basis of price. Any advertised discount should also be demonstrably genuine.
7.5 Members should avoid public association with any treatments or devices that are demonstratively ineffectual, unsafe, damaging or otherwise unlikely to be of benefit to clients.
8 ASA Code of Ethics
The ASA wishes to remind members of their obligations to the Code of Ethics,
specifically Section A which addresses members’ relationships with clients.
9 ASA Standards of Practice
Prior to advertising their services, members are encouraged to re-familiarise
themselves with the ASA Professional Standards of Practice for Audiologists.
When advertising services, especially the availability of ‘free’
initial appointments, the ASA definitions of services are encouraged. Definitions
of terms including hearing screening, standard audiological assessment, hearing
aid assessment and consultation are available at: http://www.audiology.asn.au/standards.htm
10 Advertising and the law
The ASA wishes to bring to the attention of members the ACCC guidelines for
advertising. These are available at: www.accc.gov.au/
10.1 Members are advised that false, misleading or deceptive advertising is
prohibited by the Trade Practices Act (1974). The attention of members is drawn
to s52 of the Act in particular.
10.2 When engaging in unsolicited marketing, members are also advised to familiarise themselves with the National Do Not Call Register and their requirements regarding the same. Relevant information is available at: www.donotcall.gov.au
11 Advertising and the ASA
11.1 All breaches of the ASA Code of Ethics should be managed as described in
the code.
11.2 The ASA may respond to any breach of these advertising guidelines. The ASA may call to the attention of the author any advertising in breach, against the possibility that the author was not aware that they were outside of these voluntary guidelines.
11.3 Full members of the Society following these guidelines are encouraged to include the fact of their ASA membership in advertising material. It reinforces the position Audiology Australia takes in delivering the highest standards of hearing healthcare and even provides a justifiable “competitive edge”.
12 Using membership of Audiology Australia
in Advertising
12.1 We encourage members to identify themselves as Full & CCP members of
the Society, but please remember that you are a member as an INDIVIDUAL and
therefore any reference to membership MUST be directly associated with your
name NOT the name of your CLINIC. We also encourage Full & CCP members to
used MAudSA(CCP) “note; it is CCP not CCC – in all their promotional
material. So if an individual is named then it is appropriate to use their membership
status, e.g. “Jim Brown, Full & CCP member of ASA” or Jim Brown
– MAudSA(CCP) – but not “Australian Hearing Full & CCP
member of Audiology Australia”.
12.2 Self –promotion or personal gain:
It is not acceptable to refer to any position you may hold as an office-bearer
in advertising material unless the Society itself has chosen to indicate the
individual’s ASA position in response to a media query, e.g. “Jim
Brown, ASA Federal President said ….” BUT this must not happen in
any way that could be considered self-promotion or promotion for personal or
business gain. There have been cases brought to ASA’s attention where
individual office-bearers have, for example, referred to their State Branch
position in advertorial in a way that could be construed as having the Society’s
endorsement of them and their business when this is not the case! It is, however,
quite acceptable to refer to being a Full & CCP member of the Society “and
we actively encourage you to do so” as a means of setting yourself apart
from non-members and/or audiometrists so that the community begins to understand
what being a Member of Audiology Australia represents.
12.3 So what can you say? You can use some or all of the following:
• Audiology Australia (The Audiological Society of Australia Inc (ASA)
trading as Audiology Australia) is the peak body representing Audiologists in
Australia
• Established in 1968, it has a current membership of over 1550 audiologists,
representing some 97% of the profession
• ASA’s stringent Code of Ethics, Clinical Practice Standards and
Clinical Certification Program – supported by an evidenced Continuing
Professional Development (CPD) Program to maintain clinical currency ensures
that Australians receive the highest standard of hearing health care from Audiologists
with up to date professional knowledge and clinical skills
• Audiologists are university qualified hearing scientists, responsible
for the non-medical assessment of hearing and hearing rehabilitation
• The current entry qualification into the ASA is a Masters in Clinical
Audiology
12.4 Using the ASA logo:
We welcome the use of the Audiology Australia logo by members, but there are
specific ways in which it can be used. For this reason we expect any member
who wishes to incorporate the ASA log into their advertising to submit their
advertisement PRIOR to using it in any publication and to do this EVERY time
it is intended to be used. ASA will then approve (or not) the use of the logo
for that specific advertising purpose. This approval ensures that any reference
to “Audiology Australia”, The Audiological Society of Australia
Inc, the ASA, the logo etc. cannot be misconstrued by the public as implying
any level of support for a particular device, a specific manufacturer or even
the clinic in which a member works when this is in fact not the case.
Notes on the advertising of ‘free’
services and devices
Advertising of ‘free’ services
Distinct from the actual provision of ‘free’ services, is the manner in which they are advertised. Community perceptions surrounding the dignity of the profession and the public “valuation” of our skills – as this applies to the actual provision and the advertising of ‘free’ services as defined above – are significantly and negatively affected by misleading advertising.
By advertising ‘free’ services, the provider has very publicly put an economic value on their time - and presumably the time of all ASA members - of zero dollars. By extension, in an open and competitive market, the time of an audiologist may similarly come to be valued by health care consumers as no more than nil. This potentially becomes a problem for the image of a profession which already has trouble distancing itself from vocationally trained technicians as well as a low public profile. Without the power to regulate members’ advertising or their provision of ‘free’ services the erosion of the perceived value of professional time can be mitigated via a voluntary behaviour. Public, self-evaluation of our own skills as being without worth might potentially be minimised, for example, by avoidance of the word ‘free’.
Clarification of current use of the word ‘free’ (and others) in advertising material is already confusing. Greater disclosure in advertising might help health care consumers decide what is actually being offered by providers when choosing the company/practitioner with which they make initial contact.
Examples of ambiguous and alternative terms and phrases include :
‘Free testing’ - This phrase does not necessarily imply any particular value to the services nor that the test is potentially incomplete. In practice, neither assumption is necessarily accurate.
‘Complimentary hearing screening’ - Carries connotations that the service carries at least some value and that the assessment is of an initial nature only
’Fully subsidised’ and ‘Government funded’ – Many rehabilitation clinics will use a full OHS voucher assessment as the first in-clinic consultation with a client some or most of the time. It would be misleading to advertise this initial appointment as ‘free’. By tacitly acknowledging the involvement of a third party in the process, the provider also acknowledges that they will be compensated for their time and that their clinical skills have genuine value.
‘Initial consultation’ - If a ‘free’ assessment appointment is first and foremost an entrance toward a device fitting, the reality should be acknowledged. For example, if COSI goals (or similar) are likely to be recorded or device discussion is likely to take place, this assessment is more likely to be viewed as an initial consultation towards rehabilitation rather than a ‘free’ assessment of audiometric thresholds. Ideally, the offer of such an appointment would be advertised as accurately as possible. Use of the term ‘initial’ implies that further consultation may follow, potentially incurring expense if a rehabilitation programme is embarked upon as a result of the initial appointment. Similarly, a phrase like ‘first appointment’ is potentially more accurate.
‘Free hearing screening during Hearing Awareness Week’ - The subtext here is that typically this service would carry a charge but that particular circumstances will absolve the client of this expense. As such, in this context, the term ‘free’ is less ambiguous as it is framed by other information.
It is recommended that ASA members avoid use of the word ‘free’ in advertising.
It is also recommended that ASA members disclose the nature of services as
accurately as practicable when advertising services for which they will not
directly charge.
Advertising of ‘free’ devices
The use of the term ‘free hearing aids’ in advertising is particularly
misleading on four counts:
1) The term ‘free’ is a gross oversimplification. Typically, such
‘free’ devices are in fact heavily or completely subsidised by the
OHS scheme and by extension the public purse. These devices and associated services
have a real monetary value and the clinician will be involved in a voluntary
scheme for which they are reasonably compensated.
2) In reality, such ‘free’ devices will be available to OHS sponsored clients almost exclusively. This should be revealed at the same time the possibility of ‘free’ devices is brought to the attention of a potential client.
3) The above arguments regarding use of the word ‘free’ to describe
services also apply to devices. Hearing aids and other listening devices are
particularly useful tools for many ASA members in the hearing rehabilitation
of many clients. As previously stated however, use of the word ‘free’
potentially devalues the worth placed on these devices by clients and does not
indicate the true market cost of being fitted with hearing devices without an
OHS subsidy. A more sober appraisal of the cost of devices by clients might
lead to a less casual approach to rehabilitation by clients – a complaint
sometimes voiced by clinicians. Further, instant price orientation can shift
perception of a device from a clinical prosthesis to a commercial product.
4) Advertising ‘free hearing aids’ immediately puts the focus of future rehabilitation programmes onto the device, which is unhealthy. Although hearing aids are singularly useful in many rehabilitation programmes, they are not the only tool which may prove useful. Further, the immediate pre-eminence of devices in rehab might, on some level, absolve the potential client from taking responsibility for their own programme, while also losing sight of the primacy of the client in a programme. Unhealthy reliance on a device from the outset can ultimately bring the focus of subsequent issues onto the device rather than onto the client. Finally, and most importantly, device focus lessens the role of the clinician. ASA members are experts in all facets of hearing and while non-audiologists can claim to fit aids (including fully subsidised aids via OHS) the depth of skill and learning owned by ASA members is not reflected in device driven advertising and certainly not in the advertising of ‘free’ devices. This style of advertising potentially leads clients to place minimal value on other services within a rehabilitation programme.
It is recommended that the term ‘free hearing aids’ not be used
by ASA members or associated organisations in advertising.