Tax benefits & hearing loss
A Fanie Dreams Perspective: Are We Adequately Assessing Functional Impact?
For many persons with hearing disabilities, the impact of hearing loss cannot be fully understood from an audiogram alone. A person may be able to hear reasonably well in a quiet room, yet experience significant difficulty understanding speech in background noise, participating in group discussions, following public-address systems, using the telephone, attending meetings, or communicating effectively at work and in everyday life.
This raises an important question: Are we adequately assessing the functional consequences of hearing loss when determining whether a person meets the disability criteria for tax purposes?
What does SARS require?
The South African Revenue Service (SARS) defines a disability for tax purposes in terms of a moderate to severe limitation of a person's ability to function or perform daily activities, resulting from a physical, sensory, communication, intellectual or mental impairment, which has lasted or is expected to last for more than one year and is diagnosed by a duly registered medical practitioner.
The ITR-DD – Confirmation of Diagnosis of Disability is used in this process. Parts B, C and D must be completed by an appropriately qualified registered medical practitioner. Importantly, SARS's current ITR-DD guidance for hearing disability recognises that: “Hearing disability is defined as the functional limitations resulting from a hearing impairment.”
Hearing disability is defined as the functional limitations resulting from a hearing impairment.
- SARS ITR-DD
The ITR-DD also contains audiological criteria for adults and children, based on pure-tone averages and the degree of hearing loss.
Hearing loss is not experienced only in decibels.
Audiological measurements are important. They provide an objective description of hearing sensitivity, but the lived experience of hearing loss can be considerably more complex. Two people with similar audiograms may experience very different levels of functional difficulty depending on factors such as:
background noise;
distance from the speaker;
group conversations;
room acoustics;
telephone communication;
public-address systems;
listening fatigue;
speech clarity;
the availability of captions or assistive listening technology;
the person's communication environment; and
the effectiveness of amplification or other support.
This is why the distinction between audiological severity and functional impact deserves careful consideration.
What about “mild” hearing loss?
A particularly important question is whether a hearing loss described as mild audiologically can nevertheless result in a significant functional limitation. Fanie Dreams is not suggesting that mild hearing loss automatically qualifies as a disability for tax purposes. Rather, the question is whether the functional consequences of the impairment are being adequately considered when an individual assessment is made.
A person may require hearing technology, assistive listening systems, communication adjustments or other forms of support to participate effectively in everyday activities—even where the audiological description alone might appear relatively modest.
Reasonable accommodation is part of the bigger picture
The White Paper on the Rights of Persons with Disabilities recognises reasonable accommodation as including necessary and appropriate modifications and adjustments, including assistive devices and technology, to enable persons with disabilities to exercise their rights on an equal basis.
For persons with hearing disabilities, this may include measures such as:
assistive listening systems;
loop or FM systems;
captions;
appropriate communication technology;
favourable seating;
visual or vibrating alerting systems;
written information;
communication support; and
adaptations to the way information is provided.
However, reasonable accommodation and tax eligibility are not the same thing.
The fact that an accommodation is necessary for equal participation does not, by itself, mean that the related expense qualifies for a tax benefit. SARS applies specific statutory requirements to disability-related and physical-impairment expenditure. The expenditure must meet the applicable requirements and be necessary for alleviating restrictions arising from the impairment or disability.
A conversation worth having
The SARS framework already recognises that hearing disability involves functional limitations resulting from hearing impairment. The question Fanie Dreams wishes to raise is whether those functional consequences are consistently understood, documented and applied in practice when the existing criteria are considered. This is particularly important because hearing loss is diverse. The same degree of hearing loss does not necessarily produce the same functional consequences for every person.
This is not a claim that every person with hearing loss qualifies for disability-related tax benefits. It is an invitation to examine whether the functional consequences of hearing loss are being adequately understood and documented when the existing criteria are applied.
Perhaps the question is not only how well a person hears, but how effectively that person can function and participate after appropriate correction and support.
That is a conversation worth having.
Fanie Dreams Movement
Peer support
Dreaming of an inclusive world where everyone belongs.
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