Sense International Romania and Beyond Senses – the association of people with deafblindness in Romania salutes the government's initiative to review the disability classification criteria.

In this regard, today, September 12, 2025, we have submitted our proposals to the competent authorities, which we present in this article.

Deafblindness is a severe multisensory disability, often associated with other types of disabilities. Deafblindness causes major difficulties in communication, access to information, orientation and mobility. Deafblindness can be congenital or acquired, the problem being equally complex in both cases. In the case of congenital deafblindness, vision problems may be evident from birth, while hearing problems may be observed later. Acquired or accidental deafblindness occurs after birth, due to illness or trauma, or as a result of the aging process.

We note that deafblindness is recognized by Law 448/2006 as a distinct disability, being assigned code 10. However, there are no criteria based on which complex assessment services can correctly classify deafblind people in the type of deafblindness disability – code 10. For this reason, at the level of the entire country, there is a very small number of people with deafblindness identified – 80 people with deafblindness, of which 8 children and 72 adults.

We emphasise the fact that vision and hearing losses do not add up, but multiply, the combined impact of the two deficiencies is profound and generates a distinct disability, with specific support needs.

We come to you with the request to clarify the situation of people with deafblindness in our country and to use this opportunity to revise the criteria in order to include in the revised legislation the criteria related to deafblindness.

Based on the existing criteria in the proposed order, we propose to supplement Chapter 2 – Sensory functions, with point IV, as follows:

IV. Evaluation of persons with deafblindness (simultaneous impairment of visual and auditory functions) for classification as a disability

1. Deafblindness is a complex multisensory disability that simultaneously affects both the visual function and the auditory function of a person. This type of disability generates significant difficulties in communication, access to information, spatial orientation and mobility;
2. In the evaluation of visual functions in a person with deafblindness, the indicators, parameters, table with activities/limitations, respectively participation/needs from point I – Evaluation of persons with visual impairment for classification as a disability will be used;
3. In the assessment of auditory functions in a person with deafblindness, the indicators, parameters, the table with activities/limitations, respectively participation/needs from point II – Evaluation of persons with impaired auditory functions for the purpose of classification in disability will be used;
4. In the complex assessment of a person with deafblindness, both medical documents attesting to the impairment of visual functions and medical documents attesting to the impairment of auditory functions will be taken into account.
5. In the event that only one of the two sensory functions is classified as a disability, the other being also affected but at the limit of classification, proven by medical documents, the person will be classified as a type of disability Deafblindness (code 10), medium disability.

Classification criteria

DEAFBLINDNESS (CODE 10) MODERATE DISABILITY

• Moderate visual impairment + Auditory function at the limit of classification = Moderate deafblindness
• Visual function at the limit of classification + Moderate auditory impairment = Moderate deafblindness

DEAFBLINDNESS (CODE 10) SEVERE DISABILITY

• Moderate visual impairment + Moderate auditory impairment = Severe deafblindness
• Visual function at the limit of classification + Severe auditory impairment = Severe deafblindness
• Severe visual impairment + Auditory function at the limit of classification = Severe deafblindness

DEAFBLINDNESS (CODE 10) PROFOUND DISABILITY

• Moderate visual impairment + Severe auditory impairment = Profound deafblindness
• Severe visual impairment + Moderate auditory impairment = Profound deafblindness
• Severe visual impairment + Severe auditory impairment = Profound deafblindness

DEAFBLINDNESS (CODE 10) PROFOUND DISABILITY (with or without caregiver)

• Profound visual impairment (with or without caregiver) + Auditory function at the limit of classification = Profound deafblindness (with or without caregiver)
• Profound visual impairment (with or without caregiver) + Moderate auditory impairment = Profound deafblindness (with or without caregiver)
• Profound visual impairment (with or without caregiver) + Severe auditory impairment = Profound deafblindness (with or without caregiver)