Committee Secretariat,
Joint Standing Committee on the National Disability Insurance Scheme
PO Box 6100,
Parliament House,
Canberra ACT 2600 30th January 2016.
Dear Committee Secretariat,
Joint Standing Committee on the NDIS – Hearing Services Terms of Reference
Thank you for giving us this opportunity to contribute to your inquiry.
Hearing Business Alliance represents the interests of independent businesses who participate in the provision of hearing services within Australia. We were formed in late 2016 due to the challenges and changes which our members face, and already have twenty seven member companies. As an organisation that includes Audiologists and Audiometrists, HBA acknowledges the Code of Practice 2016, which determines the competencies of both professional groups. We believe this is the basis on which services should be provided within the context of the NDIS program.
a) The eligibility criteria for determining access to, and service needs of, deaf and hearing impaired people under the NDIS:
It has been suggested by some of our members that there are obvious gaps in service as the system currently stands. (These include anyone who is not a pensioner/ not a veteran/ not under 27 years of age/ does not have a compensation claim, or does not have an ENT referral).
Currently we have in place the Office of Hearing Services (OHS) program which the Government funds to provide hearing assessment and the provision of hearing devices to pensioners and veterans. The hearing needs of this cohort may be significantly different to those of a younger more dynamic and socially engaged group. All of our members are providers under this program and we are all concerned that any changes to the public funding of hearing services would be to the detriment of this program and the pensioners, veterans, clients with complex needs and patients under twenty six years of age who currently derive great benefit from this program.
HBA Ltd Submission 30th Jan 2016 - Senate Inquiry into the Provision of Hearing Services under the NDIS 1
Currently any OHS program provider is eligible to apply to NDIS to be a provider under the NDIS. This procedure is onerous as the literature provided by NDIS, the ‘Tool Kit” and associated documents runs to approximately one thousand pages. Looking to the future some of our members have concerns that this may change to an even more onerous accreditation process which could potentially act as a barrier to entry for small business, which may not have the specialist in-house administration personnel. We believe that to avoid additional bureaucracy, the simplest way would be for accredited businesses with an OHS contract to be given automatic NDIS accreditation. This would take advantage of the current accreditation process and avoid extra expense of setting up a parallel system for the provision of hearing services under the NDIS.
Our members would also like to understand the mechanism for entry of clients into the NDIS program. Some of our members have expressed concern about Memoranda of Understanding that have been established between Australian Hearing and GP Clinics using Government ownership and scale of operation as a selling point to GP clinics. https://www.hearing.com.au/PDSA/ This refers to the CPD program offered by Australian Hearing, which promotes their MOU to the competitive disadvantage of other providers. Our concern moving forward is that the close relationship between AH and NDIS planners gives AH a significant competitive advantage over smaller independently owned hearing clinics.
Our members would also like clarity from NDIA as to what criteria are proposed for determining eligibility for the provision of hearing services to clients? To date information provided to us through NDIS information meetings has been unclear, inconsistent and conflicting. Currently under the OHS program, eligible pensioners are able to be fitted with hearing aids if they have a three frequency hearing of over 23dB, whereas we have information from one of our members who was told by NDIS that 45dB has been utilised as the threshold to determine a client’s eligibility. A change in threshold of this magnitude would have a significant effect on the services provided to pensioners if OHS is absorbed into NDIS.
Our members would also like clarity as to the level of hearing aid technology that will be funded. We have heard reports of recipients of NDIS hearing aids (on a pilot scheme) being given automatic entitlement to top technology level hearing aids. We are also given to understand that some patients decided to be fitted with less expensive hearing aids and kept the cash difference. A policy for replacing lost aids in these circumstances would also require clarification.
HBA Ltd Submission 30th Jan 2016 - Senate Inquiry into the Provision of Hearing Services under the NDIS 2
Hearing aids are only one aspect of the services provided by hearing clinics to the hearing impaired community. As business owners we remain concerned that there appears to be no provision under NDIS for audiology outside the provision of hearing devices including vestibular rehabilitation, tinnitus counselling, Auditory Processing Disorders, and more. We would like to understand the referral pathways for hearing impaired patients under the NDIS.
b) Delays in receiving services, with particular emphasis on early intervention services:
We would also suggest that NDIS factor in the possible privatisation of Australian Hearing and the impact in service delivery that may flow through from this change. For instance, do NDIS foresee that a privatised Australian Hearing would continue to have a monopoly of paediatric services, and if not how will other providers achieve the appropriate competencies?
We are concerned about any delay for children and adults receiving services. With children, any delay could have significant impact on the child’s ability to learn, impacting on the development of speech and language. With adults, any delay could affect their ability to get a job that enables them to earn a decent salary, which then allows them to be able to support themselves and their family while being a responsible member of society. Hearing loss that is not treated can have negative psychological, cognitive and social impact.
c) The adequacy of funding for hearing services under the NDIS: It is impossible to provide an answer to this question without understanding the proposed budget the eligibility criteria for services including the fitting of hearing devices.
We are aware that Price Waterhouse Cooper is undertaking a costing review for services under NDIS. Small business providers do not have the purchasing power of the larger chains, especially the vertically integrated providers, and the government-owned Australian Hearing and therefore our financial margins are significantly lower compared to these larger organisations. We would therefore ask that this point be taken into account when reviewing any fee schedules.
Some of our members have experienced that payment from NDIS can take many months. Furthermore, on at least one instance payment was made to the client, who was then expected to pay the clinic. This arrangement may add to further delay, and reduce payment
HBA Ltd Submission 30th Jan 2016 - Senate Inquiry into the Provision of Hearing Services under the NDIS 3
security. For the committee’s information, under the current OHS program, all payments are made within two to three days of receiving a claim and that is paid directly to the clinic. Small business is least able to endure cash flow pressure that might ensue if payment terms are extended.
d) The accessibility of hearing services, including in rural and remote areas: From our members’ perspective, the provision of health services, including hearing services, tends to be less accessible in rural areas, and it is in these rural areas that there is a significant proportion of services delivered by independent providers. We would suggest that it would be reasonable to have a rural weighting on services to take into account the extra costs involved in providing a service including travel time and freight costs.
e) The principle of choice of hearing service provider: Currently client choice is a fundamental principle within the OHS program. The existence of MOU’s may undermine the principle of client choice, and disadvantage both the small independent provider and the client. We request that NDIS explore the fundamentals of these relationships with a view to the possible effects on client choice.
f) The liaison with key stakeholders in the design of NDIS hearing services, particularly in the development of reference packages:
We have information that suggests that at least one NDIS planner has been advising patients that only Audiologists are eligible to provide services under NDIS. Clearly, this is a significant concern for our members who employ Audiometrists. Under the current OHS program, both accredited Audiologists and Audiometrists are both able to provide services to the hearing impaired across Australia. We are concerned that all providers are given consideration, and would ask that HBA, as an inclusive representative of small business, be included in this process.
HBA Ltd Submission 30th Jan 2016 - Senate Inquiry into the Provision of Hearing Services under the NDIS 4
g) Investment in research and innovation in hearing services: In Australia the principle research body is the National Australian Laboratory (NAL), which is an institution with an international reputation for excellence.
“NAL receives funding from the Commonwealth government through an appropriation from the Office of Hearing Services, and supplements this funding through grants from various funding bodies such as the Co-operative Research Centres (CRC) program, National Health and Medical Research Council (NHMRC), NSW Medical Devices Fund (MDF) and others.”
(Reference - https://www.nal.gov.au/about-nal/)
Our concern is that literature and promotional material emanating from Australian Hearing specifically states that this is a unique relationship, and by so doing provides commercial advantage to Australian Hearing. The current Australian Hearing literature states
“We are uniquely supported in Australia by our research division, the world-renowned National Acoustic Laboratories (NAL). “ (Reference https://www.hearing.com.au/PDSA/ )
We would request that this issue is examined when NDIS examine funding alternatives for research.
h) Any other related matters: Providers of hearing services are like any other business: we require some level of stability and certainty to be able to continue to invest in people and infrastructure. We would request that NDIS planners take this into account and provide all businesses a realistic time period to re orientate their business models once the modelling is completed.
From our members’ feedback on the current NDIS system, we believe that there are significant fundamental questions that remain unanswered about the provision of hearing services under the NDIS. Therefore, we would ask that the following questions are addressed and clarified for our understanding on the proposed operation of hearing services under the NDIS.
- Is OHS program going to be absorbed into NDIS?
- What hearing services will be covered by NDIS?
- Who will be eligible to provide hearing services? HBA Ltd Submission 30th Jan 2016 - Senate Inquiry into the Provision of Hearing Services under the NDIS 5
- Will there be a new accreditation process?
- What will be the three frequency average for providing hearing rehabilitation?
- On what basis is fee for service determined?
- What will be the payment terms? Thank you for this opportunity to address our members’ opinions and on behalf of the board of the Hearing Business Alliance Ltd we would welcome the opportunity to address the committee with respect to points raised in our submission.
Yours sincerely,
Hearing Business Alliance Ltd.
Stephen Logan
Company Secretary
(Signed on behalf of the HBA Ltd Board of Directors)
HBA Ltd Board Members
Donald MacDonald – Company Director and Chairman
Stephen Logan – Company Secretary
Gayle Dicieri – Company Director
Josephine Khairy – Company Director
William Olayos – Company Director
HBA Ltd Submission 30th Jan 2016 - Senate Inquiry into the Provision of Hearing Services under the NDIS 6