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June 2026

Over-the-Counter (OTC) Hearing Aids

Question:

I am an audiologist in private practice. I had a client who came to my clinic after purchasing over‑the‑counter (OTC) hearing aids online. They report poor benefit and discomfort and have asked me to “fine-tune” the devices.

The client has not had a comprehensive hearing assessment in over 10 years, and I have identified potential concerns that may warrant further evaluation. I recommended a full assessment before proceeding; however, the client declined, stating cost is a barrier and that they “just want these hearing aids to work.”

How should I proceed in a way that respects the client’s wishes while meeting my professional obligations?

Answer:

Audiologists may encounter situations in which clients choose OTC hearing aids instead of the recommended course of care. In these cases, regulated members must balance respect for client autonomy with their professional obligation to provide safe, competent, and ethical care. ACSLPA has recently developed the Advisory Statement: Over-the-Counter (OTC) Hearing Aids and Professional Obligations, which outlines the minimum professional and ethical obligations of regulated members by interpreting ACSLPA’s Standards of Practice, Code of Ethics, and other key college documents in the context of OTC hearing aids for individuals aged 18 and older.

Some areas to consider include:

1. Client-Centered Service and Informed Choice

A regulated member should respect the client’s right to choose their preferred intervention, including OTC hearing aids, even when it differs from your recommendation. Clients must be informed of the potential risks, benefits, and alternatives related to any proposed service or intervention, including interventions they choose themselves, such as OTC hearing aids. The audiologist’s clinical judgment should guide how these benefits, risks, and alternatives are explained so the client can make an informed decision.

When working with clients who are using or considering OTC hearing aids, it may be prudent to establish a formalized, tailored consent process. This process can ask the client to acknowledge their understanding of the recommendations provided, the risks or limitations discussed, and their decision to proceed. These limitations may include those associated with the OTC hearing aid itself. Please refer to ACSLPA’s Clinical Documentation and Record Keeping Guideline (2021) for information on documentation, record management, and retention requirements.

2. Audiology Practice Considerations

Your clinical judgment should determine whether it is appropriate to proceed without a comprehensive audiological assessment. In many cases, an assessment is necessary to support safe and effective care, enable accurate diagnosis, and identify any contraindications.
Once you have explained the rationale for why an assessment is warranted, if the client declines further assessment, the risks should be clearly explained and discussions and decisions documented. You may continue to provide support:
    • Consistent with evidence-informed practice.
If you determine that you cannot provide safe or competent services because you lack sufficient information or are unfamiliar with the device, you should limit or decline service and discuss alternative options with the client, such as referral to a physician or alternate hearing care provider.

3. Risk Management

If an adverse event or other concern arises, such as device malfunction, inappropriate amplification, or misuse, you have an ethical responsibility to address the issue and take appropriate action to protect the client’s wellbeing. Regulated members are encouraged to report problems or concerns with approved medical devices to Health Canada online or by calling 1-800-267-9675.

Regulated members are reminded that they may contact the College if they have questions or need further clarification. Please do not hesitate to reach out at any time using the Contact Us form.

If there is a conflict or discrepancy with the information or advice set out on this webpage and the information contained in a more official ACSLPA document, then the information contained in the more official ACSLPA document applies and not the information or advice set out here. For the purposes of this disclaimer, ACSLPA’s more official documents include the governing legislation (including the Health Professions Act and the Speech-Language Pathologist and Audiologist Profession Regulation) as well as ACSLPA’s Bylaws, policies, Standards of Practice, Code of Ethics, manuals and/or any other official document approved by Council, a statutory committee or a college official. Persons interacting with ACSLPA are responsible for reviewing and familiarizing themselves with the relevant information contained in ACSLPA’s official documents.