Deaf and hard of hearing early intervention viability, pricing and specialised service delivery | External submission

Submission to

Joint Standing Committee on the

National Disability Insurance Scheme

Content

Submission summary…………………………………………………………………………………………….. 3

About Royal Institute for Deaf and Blind Children ………………………………………………………. 4

Response to the Terms of Reference ………………………………………………………………………. 5

The transition to a market based system for service providers ……………………………. 5
The impact of pricing on the development of the market ……………………………………. 6
The impact of the Quality and Safeguarding Framework on the development of the market ……………………………………………………………………………………………………………… 7

Submission by Royal Institute for Deaf and Blind Children | Page 2

Submission summary

Royal Institute for Deaf and Blind Children (RIDBC) is pleased to make this submission to the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) on the market readiness for the NDIS. In this submission, RIDBC responds to the following:

The transition to a market based system for service providers
The impact of pricing on the development of the market
The impact of the Quality and Safeguarding Framework on the development of the market.

RIDBC has the capacity to provide further information on a wider range of issues and would welcome the opportunity to provide any further information that may assist the Inquiry.

In summary, RIDBC submits that the Inquiry should consider and/or make the following recommendations:

That the NDIA recognise the administrative and operational costs for Providers during transition to full Scheme and ensure that these costs are reflected in pricing.
That the NDIA adopt more transparency around price setting and that prices are reflective of the true cost of service delivery.
That steps are implemented immediately to ensure ongoing viability and sustainability of early intervention as it relates to the deaf and hard of hearing sector.
That clarity is provided around reporting requirements for Providers operating across multiple jurisdictions during the implementation of the National Framework.
That work be undertaken to ensure that the Quality and Safeguarding Framework reflect evidence for specific fields where this is available.

Submission by Royal Institute for Deaf and Blind Children | Page 3

Royal Institute for Deaf and Blind Children (RIDBC) is Australia’s largest non-government provider of therapy, education and cochlear implant services for children and adults with vision or hearing loss, their families, and the professionals that support them.

Our Mission is to provide quality and innovative services to achieve the best outcomes for current and future generations of Australians with vision and/or hearing loss.

We pride ourselves on working in collaboration with families, children and adults to tailor services that support and fit individual needs and life goals.

Services for children, adults, families and professionals:

Assessment and diagnostics
Early intervention and early learning programs
Specialist preschools, schools and school support
Therapy and re/habilitation services
Audiology and cochlear implant services
Research, postgraduate and professional education.

SCIC Cochlear Implant Program, an RIDBC service, is Australia’s largest and most comprehensive cochlear implant program, setting new benchmarks and delivering the highest level of care and support at every stage of the cochlear implant journey.

RIDBC Renwick Centre conducts world-leading research and provides continuing professional education and postgraduate courses in a range of fields relating to the development and education of children with vision or hearing loss.

RIDBC services are provided to over 8,000 people from eighteen permanent sites across Australia, and by working remotely in rural and regional areas.

As a charity, RIDBC relies heavily on fundraising and community support to continue to make a difference in the lives of people with vision or hearing loss.

For more information about RIDBC, visit www.ridbc.org.au.

Submission by Royal Institute for Deaf and Blind Children | Page 4

Response to the Terms of Reference

1. The transition to a market based system for service providers

As the largest non-government Provider of services for children and adults with a hearing or vision loss RIDBC has a high number of clients needing to transition to the NDIS. Previous state government funding of over $5m per annum received by RIDBC has been decreasing since July 2016 and will cease in June 2018. While it is expected that all people who had been previously supported through this funding will have transitioned to NDIS the delays in Scheme transition and the need to provide early intervention services to newly diagnosed children has had a significant effect on our funding stream. For those clients with NDIS Plans these have varying values and do not cover the cost for supports required for someone with a hearing or vision impairment. The inability to recover costs impedes further market growth.

The transition for Providers from a block-funded model to NDIS fee for service market based approach has required significant changes to operational and administrative processes to ensure compliance as a registered Provider and to develop systems that allow for billing. Additional resources, systems to meet and respond to the continual changes of the NDIS landscape, and staff training in new business processes have also had a cost impact on RIDBC and these costs are not able to be recovered through NDIS.

The NDIA have also transferred the cost for transition to Providers. This is particularly relevant for Early Childhood Early Intervention (ECEI) pathway. This approach is based on the premise of providing limited interim supports and facilitating access to either mainstream services or the Scheme. The cohort of children in the ECEI pathway at RIDBC are eligible for NDIS as they all have a permanent disability. However, the process for new children to access the Scheme under an early intervention pathway is resulting in delays as the ECEI approach does not recognise permanent disability criteria. As a result RIDBC is providing evidence based appropriate early intervention services involving rigorous assessment of children’s and families’ needs and the provision of programs that that seek to match those needs. Current funding provided is not reflective of the actual costs of validated and effective comprehensive transdisciplinary early intervention programs. The roll out of NDIS and subsequent inability for children in transition areas to access Better Start funding has resulted in Providers delivering services as families await access to the NDIS and development of a Plan with no funding. This cost increases as more children seek access to the NDIS.

Recommendation:

That the NDIA recognise the administrative and operational costs for Providers during transition to full Scheme and ensure that these costs are reflected in pricing.

Submission by Royal Institute for Deaf and Blind Children | Page 5

2. The impact of pricing on the development of the market

NDIA pricing decisions to date have ignored evidence previously provided. The current price setting mechanism within the NDIA does not provide for transparency of process and does not consider the true cost of evidence based supports and assure quality and safety standards. At the same time participants perceive that supports are overpriced due to a lack of understanding of the true costs for Providers in providing these supports. In the release of the 2017/2018 Price Guide some process were increased and others remained unchanged. The failure of the NDIA to increase the price for therapy services in July 2017 has not allowed the market to keep pace with the cost of inflation.

The application of the Scheme pricing for participants in rural and remote areas does not allow for the recovery of costs in providing these supports. Similarly, there is nothing on a participant plan indicating that funding has been determined to allow for higher price limits. However, the rural and remote pricing is only eligible for services provided in the location; and does not recognise the costs associated with providing this type of support. Through tele practice RIDBC provides services to children across many rural and remote areas of Australia. This specialist support is provided in the absence of local Providers able to address the specialised needs of children with a hearing and or vision impairment. The annual $3400 cost of the videoconferencing package and associated hardware is borne by the Provider. The NDIS has been a significant market disruptor in the hearing impairment sector. Provision of early intervention service in the field of deafness and hard of hearing have for 70 years led the world in regards to predictable outcomes for children identified with hearing loss. This has been achieved through implementation of evidence based transdisciplinary services that achieve age appropriate communication outcomes for children with no additional disabilities, and optimises communication outcomes for all children. In short, the NDIS is focussing on deficit, not capacity building in a cohort where there is ample evidence of excellent outcomes as a result of appropriate and previously affordable intervention.

The sector of specialist providers is small, with some 8 providers across Australia prior to the NDIS roll out. Currently, there are 6 providers with one further provider currently considering its future viability and likely to seek a merger this year. This reduction in providers is due directly due to the financial impost inflicted by the NDIS as a result of delays in plan allocation, plan size that in no way reflects the cost of service provision, significant administrative impost and constant changes in NDIS processes.

The development of these services has been gradual over the last century, with significant training requirements for individual staff members. Australia has been at the forefront of communication development, with the remaining 5 providers in significant financial crisis. It is not possible for the market to respond to the predicted market failure across Australia should the sector collapse. As a result, children who to date would have achieved normal communication, the social and economic cost of this are clearly articulated in the Hearing

Submission by Royal Institute for Deaf and Blind Children | Page 6

Care Industry Association of 2017, which builds on the pivotal 2006 Access Economics report.

The insurance principles that the NDIS has been built on has failed to invest in in early intervention in order to reap downstream benefits. Whilst financially this is a short-sighted approach economically, the social impacts of this as a result of imminent sector collapse are catastrophic.

Recommendation:

That the NDIA adopt more transparency around price setting and that prices are reflective of the true cost of service delivery.

That steps are implemented immediately to ensure ongoing viability and sustainability of early intervention as it relates to the deaf and hard of hearing sector.

3. The impact of the Quality and Safeguarding Framework on the development of the market

RIDBC is currently registered as a NDIS provider in 6 jurisdictions and is required to meet the individual requirements for each state /territory. This has had a significant impact on resourcing to maintain our registration with duplication of processes for each jurisdiction. As RIDBC was operating during the trial and early transition phase we have 5 different registrations with the NDIA. As such, RIDBC welcomes the implementation of the National Quality and Safeguarding Framework as it will simplify quality and safeguards requirements and provide national consistency. It is also anticipated that our registration will be more streamlined with only 1 registration.

It is acknowledged that the implementation of the framework will commence for NSW and SA in July 2018 but not reach full implementation until 2020. There is concern that this will still have a significant burden on Providers operating across multiple jurisdictions. RIDBC will still be required to meet individual state requirements for other jurisdictions, and at this stage it is not clear whether we will have dual reporting requirements for other components of the framework such as reportable incidents and complaints.

The Quality and Safeguarding Framework is understandably generic, however, this lack of specificity fails to recognise gains made over 70 years in the predictability of outcomes for children who are deaf or hard of hearing accessing specialist transdisciplinary early intervention services. As a result, there will be no return on the investment with non specialist programs or individuals without specialist qualifications.

Recommendation

That clarity is provided around reporting requirements for Providers operating across multiple jurisdictions during the implementation of the National Framework.

Submission by Royal Institute for Deaf and Blind Children Page 7

That work be undertaken to ensure that the Quality and Safeguarding Framework reflect evidence for specific fields where this is available.

Submission by Royal Institute for Deaf and Blind Children Page 8