SUBMISSION:
National Disability Insurance Scheme (NDIS) Quality and Safeguarding Framework
MAY 2023
Introduction
Audiology Australia (AudA) welcomes the opportunity to provide a written submission to the National Disability Insurance Agency (the Agency) on the NDIS Quality and Safeguarding Framework.
AudA is the peak professional body for the profession of audiology, representing over 3,500 audiologists across Australia and 95 per cent of all practising audiologists in the country. 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 participants in the NDIS.
As at 31 December 2022, there were over 25,600 participants with a hearing impairment as their primary disability in the NDIS and over 8,300 hearing providers supporting these participants with a hearing impairment¹.
AudA has provided feedback in relation to the guiding questions outlined in the NDIS Quality and Safeguarding Framework Consultation Paper for the Agency’s consideration. Please refer below.
What is working well about the Framework? What is not working well to promote safeguards of people with disability and the quality of supports?
As noted in the Consultation Paper, the current NDIS Quality and Safeguarding Framework document is a lengthy and complex document that can be difficult to read and understand by all participants. There is a need to provide a more easily accessible, simplified version. This includes ensuring that any future iterations of the document are accessible to culturally and linguistically diverse communities.
What supports, services and actors should the Framework cover?
AudA considers that the NDIS must fund the full range of required rehabilitation services for hearing loss. This includes support and counselling as needed for the individual and family to improve ability to participate in activities that are meaningful to them; individual and group aural rehabilitation; behaviour change counselling; and devices as alternatives to, or in addition to, hearing aids such as telephone adapters, remote microphone systems and streamers and television devices for hearing assistance.
It is AudA’s view that only through holistic rehabilitation can the outcomes for participants with hearing impairment be met across all of the domains in the Agency’s outcomes
framework. We strongly recommend that the Agency recognises the additional skills and services that audiologists can offer hearing impaired participants, especially behaviour management, counselling and referral to other health practitioners, and individual and group aural rehabilitation. More information about the range of skills of audiologists is set out in the Scope of Practice for the audiology profession².
Recommendation 1:
That the Agency recognises the additional skills and services that audiologists can provide participants with hearing impairment, especially behaviour management, counselling and referral, and individual and group aural rehabilitation, and fund the full range of required rehabilitation services for hearing loss.
What changes are required to the roles and responsibilities of different actors in the Framework?
a. How could these actors work together better to deliver a coordinated approach to quality and safeguarding?
The expectations of intermediaries such as plan managers, support coordinators and local area coordinators in quality and safeguarding are not always clear. We are concerned that there is a consistent lack of awareness being displayed by coordinators and planning staff regarding the role of audiologists and the services and supports they can provide to hearing impaired participants.
For example, we are aware of instances where coordinators and planning staff have facilitated appointments between non-hearing providers and hearing impaired participants without considering the role of hearing providers in addressing participants’ hearing health care needs.
We have also been informed that some coordinators and planning staff are largely unaware of the role of audiologists as allied health professionals and are unable to identify the types of services and supports audiologists can provide to hearing impaired participants. Examples provided by our members include:
- A coordinator facilitating an appointment between a non-hearing provider and a participant who is a newly implanted cochlear implant (CI) patient. When the participant’s audiologist asked the coordinator why she had not been notified to provide hearing supports to her CI patient, the coordinator indicated that they were
unaware that an audiologist was able to provide hearing supports to the participant and also believed that audiologists do not know how to write NDIS reports.
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A planner advising an AudA member that audiologists do not work with assistive technology and being unaware that audiologists are able to provide auditory rehabilitation services.
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Planners routinely advising audiologists to obtain a letter from an occupational therapist to support an application for hearing assistive technology, instead of relying on an audiologist’s own extensive knowledge and experience.
The lack of awareness being displayed by coordinators and planning staff regarding the role of audiologists and the services and supports they can provide to hearing impaired participants can be extremely detrimental to hearing impaired participants and severely undermines the capability and capacity of hearing providers working within the NDIS. This is an issue we have raised on many occasions previously with the Agency.
We highlight that audiologists are highly skilled hearing health practitioners with at least five years of university-level training, including a Masters in Clinical Audiology. On this basis, we consider audiologists are best placed to provide hearing services and supports to hearing impaired participants as they have the in-depth knowledge, training and skillset to do this as part of their Scope of Practice. In particular, audiologists have a thorough understanding of different kinds of hearing technology and what works well and is compatible with a participant’s new and existing hearing assistive technology.
To address this issue, we recommend that education be provided to coordinators and planning staff so that they are informed of the services and supports audiologists can provide to hearing impaired participants. This will ensure that coordinators and planning staff can identify situations where a hearing provider is better placed to address a hearing impaired participant’s needs and goals, and help to reduce the numerous incidences of non-hearing providers prescribing inappropriate hearing assistive technology to participants. AudA is happy to assist the Agency with preparing and/or reviewing materials on these topics to help support and facilitate better decision making by Agency staff.
Recommendation 2:
That the Agency provide education to coordinators and planning staff so that they are informed of the services and supports audiologists can provide to hearing impaired participants.
What changes are required to the types of strategies and measures implemented under the Framework?
b. What is required to drive improvements in the quality of supports and services?
There is a need to ensure that consistent advice, guidance and information is provided to participants and providers in relation to introduced changes to NDIS processes for supports and services.
As an example, last year, the Agency introduced changes to the evidence requirements for mid cost assistive technology devices. Under these new changes, mid cost assistive technology in the range of $1,500 to $15,000 would no longer require a written assessment from an assistive technology advisor.
However, since the introduction of these changes, AudA has experienced a significant degree of difficulty in receiving consistent and clear advice from the Agency on the evidence requirements for hearing devices in the mid cost technology range. Oftentimes, the Agency advice received by AudA was inconsistent with the information published by the Agency. Based on the latest advice and correspondences with the Agency to date, AudA is now advising the following:
- That all hearing aid devices (standard, intermediate, advanced levels) will require a written assessment as part of the evidence requirements. This includes hearing aids that are in the mid cost assistive technology range. The written assessment requirement is stated in the [Assistive Technology, Home Modifications and Consumables Code Guide 2022-2023](refer page 24).
- That any powered devices for hearing will be classified by the Agency as higher risk products. Higher risk products will require a written assessment as part of the evidence requirement prior to supply to a participant. Powered devices for hearing include remote microphone systems, personal amplifiers/binaural listeners, and hearing aids. The NDIS assistive technology product risk table can be viewed here.
Overall, clearer guidelines and consistent information are required in regard to the level of risk associated with different types of supports, including the level of risk associated with different types of hearing assistive technology products and supports.
Recommendation 3:
That the Agency ensure consistent advice, guidance and information is provided to participants and providers in relation to introduced changes to NDIS processes and procedures.
In addition, the cost comparison process for assistive technology products is generally unclear for hearing providers. As an example, our members have been asked by coordinators and the Technical Advisory Team to unbundle the pricing of assistive technology products from the hearing services provided so that the cost of an assistive technology product can be checked and compared with the expected price range for a similar product on the market.
Oftentimes, our members have reported that it seems the ‘market rate’ provided to them by coordinators and the technical team has been determined by comparing the product prices from online hearing retailers who do not include fitting fees and from much larger hearing providers who can offer heavily discounted products, but which smaller hearing providers and clinics are unable to do. In one instance, an AudA member received feedback from the technical team that an intermediate hearing aid for a participant could be obtained with approximately $1000. It was difficult for our member to understand how the technical team member was determining the cost figures for the hearing product, as it does not reflect the reality of the pricing that many hearing clinics/providers can afford to offer.
AudA thus recommends that the Agency increase the transparency of the cost comparison process for assistive technology products, which may include making available to providers any internal price lists or price range for assistive technology products utilised by the Agency and/or for coordinators and the Technical Advisory Team to provide details to providers on how the market rate of an assistive technology product has been determined.
Recommendation 4:
That the Agency increase the transparency of the cost comparison process for assistive technology products. This may include making available to providers any internal price lists or price range for assistive technology products utilised by the Agency or for Agency staff to provide details to providers on how the market rate of an assistive technology product has been determined.
¹ National Disability Insurance Agency (NDIA). Hearing data to 31 December 2022. Available at: data.ndis.gov.au/reports-and-analyses/participant-dashboards/hearing-impairment
² The Scope of Practice for Audiologists is in the process of being revised and updated.