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Stop Stigmatizing Your Own Product: an Open Letter to the FDA

Updated: Jan 23, 2022

Hearing device marketing is at a crossroads as the FDA considers over-the-counter (OTC) hearing aid guidelines

Multi-racial woman in her late 20s or early 30s with a high ponytail and large hoop earrings. She is wearing a tan earbud-like hearing aid.
This stock photo was labeled "young hipster." That's right. Hearing aids could soon be a statement!
I have long been mystified as to why any American company, notorious for liking money, would use their own marketing to alienate consumers.

Quick recap: the FDA has issued a set of proposed guidelines for over-the-counter hearing aids. The products would be a no-prescription option for people with mild-to-moderate hearing loss. The rules are expected to open the floodgates for more competition in the hearing device industry, creating better access and lower prices for up to 30 million American adults.


Unless said industry continues to drop nuclear bombs on its own product's reputation.


For decades, hearing aid companies have stigmatized their own products. You've seen the goofy TV commercials framing hearing aids as an embarrassing thing that make old people look stupid, and thus should stay hidden. This fabricated stigma has led people to believe hearing aids are open season for ridicule (check out my other post for a longer rant on society's blind eye to this intersection of ageism an ableism). It has tragically steered millions away from better hearing.

I'm asking the FDA to include a warning in their guidelines against stigmatizing marketing messages.

I have long been mystified as to why any American company, notorious for liking money, would use their own marketing to alienate such broad segments of consumers. With 15 percent of Americans 18+ living with mild-to-moderate hearing loss, the industry is facing a critical opportunity to boost demand like never before. It is literally a multi-million-dollar incentive to show the world that hearing aids are for everyone!


That's why I'm asking the FDA to warn against stigmatizing marketing. I have no idea if the FDA would include this type of thing in its guidelines. But as with any political issue, it is far better to take your message directly to the decision-makers than to just post about it!


I submitted my comments to the FDA via Regulations.gov Sunday, January 16th. Here is what I wrote:


 

16 January 2021


Janet Woodcock, MD

Acting Commissioner

Food and Drug Administration

5630 Fishers Lane, Rm 1061

Rockville, MD 20852


RE: Docket No. FDA-2021-M-0555 RIN 0910-AI21, Medical Devices; Ear, Nose, and

Throat Devices; Establishing Over-the-Counter Hearing Aids

Comments submitted electronically via www.regulations.gov


Dear Commissioner Woodcock and Colleagues:


As an individual consumer, I appreciate the opportunity to comment on the proposed rule Medical Devices; Ear, Nose and Throat Devices; Establishing Over-the-Counter Hearing Aids.


I have gathered from media coverage of President Trump’s FDA Reauthorization Act, and President Biden’s executive order Promoting Competition in the American Economy, that the primary objective of this rule is to drive down hearing aid prices. This objective has the potential to change millions of lives, bringing more success and better mental health to American adults with untreated mild-to-moderate hearing loss. It also stands to generate new revenue for American companies, as long as adequate demand exists in the marketplace.


I am writing to discuss a vital piece of the competition equation: market expansion via increased hearing aid adoption. Alongside guidelines regulating product specifications and labeling, I would like to see the FDA discourage product marketing that stigmatizes hearing loss and hearing aids.


Hearing aids have a PR problem. I can’t think of another industry, besides hearing devices, that has used its own marketing to alienate such broad segments of potential customers. For decades, too many hearing aid companies have stigmatized their own products as embarrassing, shameful, restrictive, and a badge of senility. One audiologist told me that some of her patients would rather struggle with hearing loss than risk anyone finding out they have hearing aids. Why would someone feel this way about a product that could make life better? Because of the way stigma, fabricated by the industry itself, has permeated society deeply enough to steer millions away from hearing aids.


The hearing device industry is at a crossroads. Companies can either seize this unique opportunity to frame OTC hearing aids as must-have products for all adults with mild-to-moderate hearing loss, or they can stick with the self-sabotaging status quo. Current players have missed out on millions of dollars from hard of hearing consumers in their 20s, 30s, 40s, and 50s, while clumsily targeting seniors with oversimplified and sometimes insulting messaging. In the spirit of promoting competition and making money, it’s time to manage the hearing aid’s reputation.


This means re-educating not only the target segments, but everyone who comes into contact with hearing devices of the future. I hope to see more brands elevate authentic stories illustrating how a product can transform the consumer’s self-esteem, brainpower, career, and relationships. They could also run campaigns challenging society’s false assumptions about hearing loss. Marketing angles abound in this emerging OTC hearing aid category. But without a nudge from regulators, I fear too many companies will further the trend of torpedoing the product’s appeal to consumers. That’s why it is critical for the FDA to warn against stigmatizing marketing messaging.


Like one in ten millennials, I have mild-to-moderate hearing loss. Unlike my most of my peers, I have 12 years of experience using prescription hearing aids. I took a leap of faith purchasing my first $5,000 pair after graduating college in the Great Recession. It was the best money I ever spent. After a lifetime of social struggle and listening-fatigue anxiety, my devices let me shine. Thanks to my hearing aids, I now excel in my media career, play a team sport, serve my community, and attend business school.


I know firsthand the hope and relief that comes from better hearing, along with the ongoing financial strain brought on by a lack of competition in the hearing device industry. I’m thrilled for this unprecedented era of better access and lower prices for more Americans like me.


Thank you for the opportunity to comment on the proposed rule.


Sincerely,



Erica Jansen

Founder, HearingHabits.com

erica@hearinghabits.com


 

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