National Disability Insurance Scheme (NDIS) Annual Pricing Review 2022-23

APRIL 2023

Introduction

Audiology Australia (AudA) welcomes the opportunity to provide a written submission to the National Disability Insurance Agency (the Agency) on the NDIS Annual Pricing Review 2022-23.

AudA is the peak professional body for the profession of audiology, representing over 3,400 audiologists across Australia. Audiologists are tertiary qualified allied health professionals with expertise in the assessment, prevention and non-medical management of hearing loss and associated disorders of communication and balance. Audiologists provide hearing services and supports to a wide range of clients, including NDIS participants.

As at 30 September 2022, there were 25,134 participants with a primary disability of a hearing impairment in the NDIS, representing 5 per cent of the total number of active participants in the Scheme.¹ Over 8,000 providers in the NDIS currently support these participants with a hearing impairment.²

AudA has provided the comments and feedback on therapy supports, registration and the labour market as set out in the Annual Pricing Review 2022-23 Consultation Paper for the Agency’s consideration. Please refer below.

Therapy Supports

AudA considers it important for the Agency to ensure that the pricing for therapy supports remains in step with the cost of living. This means raising the price cap for therapy supports and applying indexation on a consistent basis. AudA is aware that participant utilisation of allied health supports is significantly lower than the average utilisation rate for supports as a whole within the Scheme.

AudA recommends that the Agency work with allied health peak bodies to publish clear and communication-accessible information on pricing, and to ensure this information is consistently provided to participants.

In the context of therapy supports for participants with a hearing impairment, AudA highlights that the operational processes and procedures relating to hearing assistive technology products are generally unclear for hearing providers. AS an example, our members have been asked by Local Area Coordinators (LACs) and the Technical Advisory Team (TAT) to unbundle the pricing of assistive technology products from the hearing services provided so that the cost of a hearing assistive technology product can be checked and compared with the expected price range for similar products on the market.

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Our members have reported that the ‘market rate’ for an assistive technology product provided by the LACs and the TAT seems to have been determined by comparing the hearing product prices from larger hearing providers who can afford to offer heavily discounted products and/or from online hearing retailers who do not include fitting fees. Smaller hearing clinics/providers cannot afford to offer these discounts. In one instance, an AudA member received feedback from the TAT that an intermediate hearing aid for a participant with a hearing impairment could be obtained with approximately $1000. It is difficult to understand how the TAT is determining the cost figures for hearing products, as in many cases the costs do not reflect the reality of the pricing that can be reasonably offered by many hearing clinics/providers.

AudA recommends that the Agency increase the transparency of the cost comparison process for hearing assistive technology products, which may include making available to hearing providers any internal price lists or price range for hearing assistive technology products utilised by the Agency and/or for LACs and the TAT to provide details to hearing providers on how the market rate of a hearing assistive technology product has been determined.

Recommendation 1: That the Agency work with allied health peak bodies to publish clear and communication-accessible information on pricing and ensure this information is consistently provided to participants.

Recommendation 2: That the Agency increase the transparency of the cost comparison process for hearing assistive technology products. This may include making available to hearing providers any internal price lists or price ranges for hearing assistive technology products that are utilised by the Agency and/or for Agency staff to provide details to hearing providers on how the market rate of a hearing assistive technology product has been determined.

Registration costs

AudA strongly recommends that the Agency work with the Regulatory Alignment Taskforce and the NDIS Quality and Safety Commission to simplify current provider registration and auditing processes. As at September 2022, 37 per cent of providers supporting participants with a hearing impairment who use a plan manager were registered providers.³

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We highlight that the overall administrative burden experienced by allied health providers in the NDIS system is significant. As outlined in the 2022 State of the Disability Sector Report⁴, 60 per cent of providers agree or strongly agree that there are too many unnecessary rules and regulations in the NDIS.

Our members have consistently raised the issue of the time-consuming regulatory processes within the NDIS. For example, when hearing providers assess participants’ hearing needs to identify the most appropriate hearing assistive technology for participants, they can either choose to fill out the 25-page hearing technology assessment template or provide the information in another format, which must include all information described in the template.

Specifically, AudA members have provided the following comments in regard to the hearing technology assessment template:

The template is a significant barrier for inexperienced clients and may require 2 to 3 hours or longer to complete.
Multiple clients have not accessed an audiologist to get their template completed due to the potential complexity and time involved.
Completing the template is a labour intensive, difficult and time-consuming experience that is frustrating for all parties involved and does not seem to be conducive to good outcomes.
The template could be considerably shortened and simplified.

Recommendation 3: That the Agency work with the Regulatory Alignment Taskforce and the NDIS Quality and Safety Commission to simplify current provider registration and auditing processes.

Recommendation 4: That the Agency address the administrative burden faced by hearing providers in relation to the hearing technology assessment process and work to simplify the hearing technology assessment template so that it is more accessible for providers and participants.

Labour market

AudA recommends that the Agency work with allied health peak bodies to understand and address the issues impacting workforce recruitment, supervision and retention. We consider that boosting the capacity of the provider workforce must either be factored into the price limit or funded directly through the Agency.

AudA is aware that there are unmet allied health provider costs which include funded support for professional development of practitioners, improving capacity to provide student placements, and including students in consultations. Given the significant and likely growing proportion of sole practitioners, there is also a funding gap for upskilling of health professionals in areas of shortage via mentoring and supervision. We note that as at September 2022, 41 per cent of providers supporting participants with a hearing impairment were individual or sole traders.⁵

Recommendation 5: That the Agency work with allied health peak bodies to understand and address the issues impacting workforce recruitment, supervision and retention.

¹ NDIS, Hearing impairment summary, published September 2022. Available at: data.ndis.gov.au/reports-and-analyses/participant-dashboards/hearing-impairment

² Refer i.

³ Refer i.

⁴ National Disability Services, State of the Disability Sector Report 2022. Available at: nds.org.au/images/State of the Disability Sector Reports/SoTDS 2022.pdf

⁵ Refer i.