Submission 37 — Royal Institute for Deaf and Blind Children (RIDBC) — The provision of hearing services under the National Disability Insurance Scheme (NDIS) | External submission

Submission to the

Inquiry into the provision of hearing services under the National Disability

Insurance Scheme (NDIS)

Prepared by Key contact:

Private Bag 29,

Parramatta NSW 2124

361 – 365 North Rocks Road,

North Rocks NSW 2151

Content

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

About Royal Institute for Deaf and Blind Children ………………………………………………………. 7

Response to the Terms of Reference ………………………………………………………………………. 8

The eligibility criteria for determining access to, and service needs of, deaf and hearing impaired people under the NDIS ………………………………………………………… 8
Delays in receiving services, with particular emphasis on early intervention services ……………………………………………………………………………………………………… 9
The adequacy of funding for hearing services under the NDIS ………………………….. 12
The accessibility of hearing services, including in rural and remote areas …………… 14
The principle of choice of hearing service provider ………………………………………….. 16
The liaison with key stakeholders in the design of NDIS hearing services, particularly in the development of reference packages …………………………………….. 17
Investment in research and innovation in hearing services ……………………………….. 18
Any other relevant matter – the proposed transfer of Australian Hearing into non-Government ownership ………………………………………………………………………… 20

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 NDIS to the provision of hearing services under the National Disability Insurance Scheme.

In this submission, RIDBC responds to items 1-8 of the terms of reference, namely:

The eligibility criteria for determining access to, and service needs of, deaf and hearing impaired people under the NDIS;
Delays in receiving services, with particular emphasis on early intervention services;
The adequacy of funding for hearing services under the NDIS;
The accessibility of hearing services, including in rural and remote areas;
The principle of choice of hearing service provider;
The liaison with key stakeholders in the design of NDIS hearing services, particularly in the development of reference packages; and
Investment in research and innovation in hearing services;
Any other relevant matter – the proposed transfer of Australian Hearing into non- Government ownership.

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 regard to matters concerning the provision of hearing services under the NDIS.

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

Issue 1: Eligibility criteria for deaf and hearing impaired people under NDIS

That guidelines are developed for a consistent approach to determining access requirements to NDIS for people with hearing loss across the age spectrum.

That NDIA subjectivity be removed in determining plans and funding packages.

That access to all elements of hearing services that are currently available under the Hearing Services Program (as administered by the Office of Hearing Services) remain available to all Australian children and young people aged 0-25 years with an identified hearing loss.

Submission by Royal Institute for Deaf and Blind Children Page 3

Issue 2: Delays in receiving services

That the critical Newborn Hearing Screening Pathway is maintained, particularly with potential changes to Australian Hearing and within the bounds of the new NDIS era.

That consideration is given to the need for extension of the Hearing Services Program (or the creation of another similar program at a Federal level) to cover the provision and fitting of devices other than hearing aids for children (particularly cochlear implants).

That referral pathways that currently exist, providing Australia with a world class coordinated and sequential hearing and early intervention program, are maintained/ replicated without causing delay to service access.

That mechanisms are implemented that ensure the ongoing sustainability of alternate communication programs in an NDIS environment.

Issue 3: Funding of hearing services under the NDIS

That packages developed for early intervention for hearing loss are reflective of actual costs associated with access to early intervention and hearing device requirements.

That there is a streamlined and consistent approach to the determination of assistive technology needs and funding through NDIS.

Issue 4: Accessibility of hearing services

That the Government takes steps to ensure an extensive awareness campaign is provided to increase awareness of and education about hearing loss in Australia in order to encourage individuals to attend an assessment and encourage their family members to seek assistance.

That the Government takes steps to ensure that the economies of scale in maintaining training, quality safeguards, and clinician competence for paediatric audiology that currently exist within Australian Hearing are assured by having a single obligated provider of hearing services for 0-25 year olds.

That the Government takes steps to ensure that the societal and economic benefits of access to hearing solutions are provided in an equitable way to all Australians irrespective of ability to pay.

Issue 5: Principle of choice of hearing service provider

That, despite the roll-out of full contestability under the NDIS, there should continue to be one single obligated service provider appointed to meet the needs of the current Community Service Obligation (CSO) client market, including 0-25 year olds.

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Issue 6: Liaison with key stakeholders and development of reference packages

That the Government develop and strengthen policy and guidelines on Early Childhood Early Intervention (hearing loss) in conjunction with early intervention providers to ensure an evidence based approach to hearing loss.

That direct access to an assessment package is provided for all children identified through screening to determine ongoing service requirements.

Issue 7: Investment and innovation in hearing services

That the Committee endorses the aim of developing a National Centre for Hearing Loss Demography and Outcomes Research as a Government-funded initiative to be a continuing function of the National Acoustic Laboratories (NAL) or other such agency as may be appropriate, so as to provide:

 the capacity to calculate accurately the incidence and prevalence of permanent congenital childhood hearing loss in Australia;  a basis for ensuring that children identified through newborn hearing screening programs are not lost to follow-up (i.e., that they receive the necessary intervention services and other supports that are required to capitalise on their early identification) regardless of their location or movement within Australia;  access to a population database of children for research on aspects such as aetiology and epidemiology; and  a basis for tracking the long-term outcomes and cost-effectiveness of interventions for hearing loss.

That the Committee endorses the concept of a Total Service Model of hearing health care that is capable of ensuring the articulation and potential co-location of a broad range of services; so as to facilitate maximum return on Government’s investment in a range of hearing services that are not currently well-coordinated or articulated.

Issue 8: Proposed transfer of Australian Hearing into non-Government ownership

That the Committee explore the likely future for Australian Hearing, in the context of the NDIS era, with a particular focus on:

 Safeguarding the of delivery services currently made available through of the Community Service Obligation (CSO) requirements of the Government’s Hearing Services Program, particularly with changing eligibility criteria under the NDIS;

 Addressing areas of service growth and unmet need;

 Providing an enhanced service and improved hearing health outcomes for all Australians;

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 Building on Australian leadership in hearing health and keeping ownership of Australian Hearing in Australian hands;

 Furthering the work of Australian Hearing’s research division, the National Acoustic Laboratories (NAL);

 Extending Australian Hearing’s service offering, ultimately providing a total end to-end service for people with hearing loss, including: integrated assessment; diagnostics; hearing aids; cochlear implantation; therapy; education; rehabilitation and support services.

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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  Teleschool and telepractice programs  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 hearing or vision loss.

RIDBC services are provided to over 6,500 people from eighteen permanent sites across Australia, and in rural and regional areas through RIDBC Teleschool and telepractice.

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 7

Response to the Terms of Reference

This submission addresses 8 specific issues in response to particular terms of reference (1-8).

The eligibility criteria for determining access to, and service needs of, deaf and hearing impaired people under the NDIS

One in six Australians – or nearly 4 million people – are affected by hearing loss or chronic ear disorders, with rates particularly high among Aboriginal and Torres Strait Islander people. By 2050 that number will grow to one in every four Australians.1

Hearing loss has been linked to risks of depression, dementia, blood pressure, heart disease and other serious health problems. If it’s not addressed it can impact on the ability of many Australians to work to their potential. It’s also costing the nation $11 billion a year in lost productivity, plus costs to our health system and the cost of informal careers.2

For those currently receiving services through the Office of Hearing Services Program there is a minimum hearing loss threshold for fittings of hearing devices under the voucher component of the program. While it has been indicated that this will continue through to full implementation of the NDIS, there is a critical need to ensure that there is no diminution of the Federal Government’s commitment to the provision of free and universally available access to hearing services and hearing equipment, under the terms of the Hearing Services Program, following full NDIS roll-out.

Any change to eligibility criteria will necessitate that the Government consider alternative arrangements for those young adults (under 26) with less complex hearing needs who are currently CSO clients eligible for services under the Hearing Services Program but who may be ineligible for services under the NDIS. This is an issue that requires Government policy consideration in light of its promise that no current recipients of Hearing Services would be worse off under the transition from the Hearing Services Program to the NDIS.

In the absence of formal eligibility criteria for people with a hearing impairment, access criteria for NDIS supports is not consistently applied. Criteria needs to be relevant to the nature of the impairment, age cohort and the individual context. The use of levels of hearing loss is appropriate for young children identified with hearing impairment at birth. However, a functional assessment for older children or adults could not be applied to this group. The functional level of disability that will enable eligibility for the NDIS needs to be

1Access Economics & Cooperative Research Centre for Cochlear Implant and Hearing Aid Innovation (Australia) & Victorian Deaf Society, 2006. Listen Hear! The economic impact and cost of hearing loss in Australia 2 Access Economics & Cooperative Research Centre for Cochlear Implant and Hearing Aid Innovation (Australia) & Victorian Deaf Society, 2006. Listen Hear! The economic impact and cost of hearing loss in Australia

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defined, and programs need to be put in place to help those that don’t make the NDIS eligibility cut-off.

Since the rollout of the NDIS we have seen some NDIS participants getting less compared to pre-existing arrangements, access to services and other assistance could become worse for those who do not qualify for the NDIS.

Hearing services and funding should not go backwards, as appears to be happening under the NDIS. Australia will lose its reputation as a world leader in hearing services and research, to the detriment of our population under the current policy settings.

Recommendation:

That guidelines are developed for a consistent approach to determining access requirements to NDIS for people with hearing loss across the age spectrum, with a focus on functional impact of the hearing loss, with universal inclusion for newborns with defined hearing loss.

That NDIA subjectivity be removed in determining plans and funding packages.

Delays in receiving services, with particular emphasis on early intervention services

RIDBC echoes the call from national and international experts within the hearing loss sector, for cost effective screening, prevention and appropriate intervention throughout ‘the life course’. The timeliness of delivery of early intervention programs is premised upon the identification of hearing impairment in children at the earliest possible time.

Following the identification of hearing impairment, the most important factor in ensuring positive long-term outcomes for children with hearing impairment is the provision of prompt and effective early intervention services. We know that early intervention services give children with hearing loss the best possible start to life, so that they can reach their full potential. This early intervention principle also applies for adults who may have progressive or sudden onset hearing loss/deafness, noise induced hearing loss, or age related hearing loss.

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Children identified as having significant bilateral hearing impairment should be fitted as early as possible with appropriate assistive hearing technology. Critical to minimising the time between diagnosis to device fitting, to deal with the time criticality of this scenario, Australian Hearing has to date provided a prioritised service for children to ensure no delay and that children receive regular and frequent follow ups. Depending on individual needs, the most appropriate technology may be wearable (hearing aids of various types and configurations) or implantable (including cochlear implants and other implantable devices such as bone conduction implantable devices).

Under Australia’s world class National Framework for Neonatal Hearing Screening,

Australian Hearing currently plays a pivotal role in the pathway for newborns and the very young that have undergone screening and an initial audiology assessment and are found to have hearing loss. Australian Hearing acts as a gateway service to re-conduct the audiology assessment and refer clients to early intervention services and beyond. The Hearing Services Program provides for the provision of hearing assessment services and access to high quality hearing aids for all children with hearing impairment in Australia.

Under the NDIS there is a delay in access to the above early intervention pathway as the family await access to the NDIS and development of a Plan prior to accessing services. There is need for a streamlined approach to ensure early access and intervention through either the Hearing Services Program or the NDIS.

Intervention techniques that support auditory-oral language development such as auditory verbal therapy or other forms of auditory-oral intervention now account for the vast majority of early intervention strategies employed.

Universal newborn hearing screening (UNHS) and early cochlear implantation are collectively creating a situation where most children with severe and profound levels of hearing impairment are able to effectively access auditory communication.

Children who are deaf or hard of hearing are not, however, a homogenous group. Variability in communication, language and educational needs is an enduring feature of this population and requires individual responses for different children and families. Regardless of the overall positive effects associated with earlier identification and early fitting/implantation, there continues to be children for whom complete access to spoken language is not going to be possible. For these children, there remains a need for programs that focus on alternative or augmentative forms of communication.

Importantly, it should be recognised that the need for alternative programs and communication approaches is not just a feature of individual choice or a particular program’s perspective. The effects of factors such as Auditory Neuropathy Spectrum Disorder and a range of developmental disabilities (among other factors) will ensure that a diversity of communication and intervention approaches is necessary to effectively serve all children with hearing impairment.

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It is critical that this functionality can be maintained by organisations across the community. Due to small numbers, the NDIS puts the sustainability of these highly specialised, resource-intensive services at threat. The diminution of augmented forms of communication is being seen across Australia as many service providers (particularly in the education sector) continue to disinvest in these types of specialised programs and services.

With this information in mind, RIDBC submits that there can be no single approach to early intervention that is applied to all families under all circumstances. Effective early intervention involves rigorous assessment of children’s and families’ needs and the provision of programs that that seek to match those needs. For most children, intervention based on auditory-verbal/auditory-oral intervention strategies will be the most appropriate approach. However, for other children the most viable access to social, cognitive, and language development will continue to be via sign language or some form of manual supplement to their use of spoken language.

The important point here is that early intervention programs should be responsive and able to identify children’s communication access needs at the earliest possible time. Waiting until children fail to achieve language and communication skills in spoken language before providing access to an alternative communication mode will create a delay in access to language and learning that will mean that the benefits offered by newborn hearing screening and early identification of their of hearing loss will have been squandered for some children. Regardless of the language that a deaf child will ultimately develop; the consequences of early versus later intervention and the provision of language learning opportunities in that language (spoken or signed) are significant.

Currently Australian Hearing undertakes a critical role of ensuring children with newly diagnosed hearing loss are informed and directed to a range of early intervention services. It is imperative that this functionality is maintained and time spent before receiving services is minimised.

Recommendation:

That the critical Newborn Hearing Screening Pathway is maintained, particularly with potential changes to Australian Hearing and within the bounds of the new NDIS era.

That mechanisms are implemented that ensure the ongoing sustainability of alternate communication programs in an NDIS environment.

Submission by Royal Institute for Deaf and Blind Children Page 11

The adequacy of funding for hearing services under the NDIS RIDBC believes that the current level of access, support and funding for hearing services are at significant risk in the NDIS era.

Currently, decisions on service types and funding levels that are available to deaf and hard of hearing people are being made by NDIA planners who in most cases have little or no knowledge of a deaf or hard of hearing person’s requirements and do not typically have relevant clinical expertise with this population. This has resulted in wide levels of funding availability for children and adults with similar needs and stands to compromise the quality and adequacy of available services.

For the purposes of ensuring the ongoing viability of high quality programs, decisions regarding service provision and funding that are made by NDIA planners should require that services are only included in individual plans when they are consistent with international best practice and are demonstrably able to be comprehensive of the needs of deaf and hard of hearing children and their families in terms of their particular communication requirements. In this regard, consideration should be given to a formal process of accreditation of providers to ensure both the comprehensiveness of service capacity and their adherence to quality indicators such as minimum levels of staff qualification and the use of evidence-based practices.

Despite the significant evidence supporting the positive outcomes associated with comprehensive transdisciplinary early intervention programs, the current NDIS sessional reimbursement model fails to recognise the actual costs of validated and effective comprehensive transdisciplinary early intervention programs.

The low level of public resources made available to agencies providing comprehensive transdisciplinary early intervention services, results in a reliance on charitable fundraising in order to prevent passing on additional costs to families, or market failure as a result of service closures.

As families await access to the NDIS and development of a Plan, early intervention providers are delivering services without receiving payment, as previous funding arrangements are being phased out. NDIA planning and funding are not responsive to the urgent need for access to specialist hearing service providers and the critical therapy required by children recently diagnosed with hearing loss and their families.

RIDBC provides habilitation and educational services to children from the age of identification of their hearing impairment until 18 years of age. In addition, the recently implemented transitional arrangements for the provision of Early Childhood Early Intervention (ECEI) have resulted in RIDBC being appointed as an ECEI transition provider to support these children and families to access the NDIS.

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There is no additional funding provided to providers for this function despite the significant additional responsibilities. Further, the NDIA’s national approach to ECEI will not be fully implemented until July 2018.

There is a clear and urgent need for consideration to be given to new and more adequate means of public funding of comprehensive transdisciplinary early intervention services for deaf and hard of hearing children. Any change to funding models, however, should ensure that services that are funded operate in line with identified best practice and are comprehensive of the needs of deaf and hard of hearing children and their families. Under any such models, consideration should be given to a formal process of accreditation to ensure both the comprehensiveness of service capacity and adherence to quality indicators such as minimum levels of staff qualification and the use of evidence-based practices.

As previously mentioned, the sustainability of alternate forms of communication are at risk as a result of small volumes and the high level of input required for children and their families.

Another issue to be considered in regard to funding is access to hearing devices. The Listen Hear! Report estimated that for the 26-65 year old cohort with hearing loss, only 15% have hearing aids, despite obvious cost effectiveness of hearing aids ($/QALY— Quality Adjusted Life Years). The cost of hearing aids for many in the population, particularly in the 26-65 year range ensures they remain prohibitive. For those with the means to obtain hearing aids, the rehabilitation element required to convert to successful lifelong usage, appears to be a relatively low priority, resulting in poor compliance.

Access to cochlear implantation is currently a state responsibility. It is accepted that access for children is universal for unilateral implants, but bilateral implantation is not funded in all states, despite growing and compelling evidence of the benefits of bilateral hearing for development and in a range of situations including, but not limited to, educational and work-place environments.

Access for adults remains poor, with only 10% of the population with severe to profound hearing loss accessing cochlear implants, across both private and public health systems. The reasons for this are multifactorial including Government rationing, lack of awareness of a cochlear implant as a legitimate option by both the general public and healthcare professionals, and incentives preferencing hearing aid use over cochlear implants.

As a provider of assistive technology for hearing services through our cochlear implant program we have been providing upgrades for implants and other accessories to improve functional capacity for many of our clients. Throughout the NDIS trial period and up until November 2016 these were funded through the NDIA following the provision of information on technology and cost. As at December 2016 the information required for approval of such technology in Plans is inconsistent across NDIA regions.

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A new process for Assistive Technology appeared on the NDIA website in November 2016 indicating that the provision of hearing equipment now required a detailed assessment, quote and recommendation. However, it is evident from our experience that the application of these new requirements are being inconsistently applied dependent on which NDIA office is managing the Plan. The documentation for the recommendation of assistive technology is onerous and is resulting in delayed access for assistive technology due to the additional workload associated in providing this information to the NDIA. For participants fortunate enough to have their assistive technology approved by the NDIA the ability for Providers to make a service booking on the myPlace portal for ‘cochlear implant speech processor and coil’ is no longer available resulting in further delay for those with approved funds.

Equitable access to hearing solutions would ensure that there is a more level playing field for people with hearing impairment, and would contribute to positive impacts across all aspects of society.

Recommendation:

That packages developed for early intervention for hearing loss are reflective of actual costs associated with access to proven comprehensive transdisciplinary early intervention services and hearing device requirements.

That there is a streamlined and consistent approach to the determination of assistive technology needs and funding through NDIS.

The accessibility of hearing services, including in rural and remote areas

RIDBC believes that there are significant risks for vulnerable populations associated with the intended move of the Hearing Services Program into the NDIS.

The ongoing delivery of hearing services (i.e., audiological assessment and access to hearing devices) required for vulnerable client groups differs according to their specific needs. Specifically, there are particular considerations for each of these groups that need to be taken into account in any transition from the current Hearing Services program to a new model under the NDIS. Specifically, there are issues that require consideration for each of these groups, as follows:

Newborns and the very young – Under the National Framework for Neonatal Hearing Screening , Australian Hearing currently plays a pivotal role in the pathway for newborns and the very young that have undergone screening and an initial audiology assessment and found to have hearing loss. Australian Hearing acts as a gateway service to re conduct the audiology assessment and refer clients to early intervention services and beyond. This gateway is a vital component that needs to be replaced in any new model.

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It is essential that this important role continues at world class standards and that, following this important gate-keeping step, opportunities are given for choice of service provider at strategic points of articulation in the service pathway (e.g., at the point of referral from the audiological services currently provided by Australian Hearing to early intervention).

Children – The ongoing provision of quality, accessible, and locally delivered services for children with hearing loss is a major driver for RIDBC. It is important that core capability in paediatric audiology is maintained in any new model through:

 economies of scale and maintaining an ongoing training, quality and safeguards, and competence framework in paediatric audiology across the country by having an obligated provider of hearing services for 0-25 year olds;  careful and considered planning to ensure that choice of associated service provision is assured for all clients who come to Australian Hearing for hearing assessment and hearing aid-related services.

Young adults under 26 – Any change to eligibility criteria will necessitate that the Government consider alternative arrangements for those young adults (under 26) with less complex hearing needs who are currently CSO Clients. Such clients who are eligible for services under the Hearing Services Program may not be eligible for services under the NDIS. This is an issue that requires Government policy consideration in light of its promise that no current recipients of Hearing Services would be worse off under the transition from the Hearing Services Program to the NDIS.

Adults with complex hearing needs – Adults (26 to 64 years) with complex hearing support needs will likely be fully eligible for services under the NDIS. It is recognised that there will likely be a range of service provider to this group under the auspices of the NDIS. However, the eligibility of people in this age group who have hearing loss to access hearing services is currently unclear and warrants immediate consideration and clarification.

Aboriginal and Torres Strait Islanders – it is essential that there is ongoing capacity to deliver specialised services to Aboriginal and Torres Strait Islanders (ATSI communities) under any transition of Hearing Services to the NDIS. It is acknowledged that for some members of this population who are currently eligible under the Hearing Services Program, there will be the opportunity to transition to service delivery under the NDIS in a fully contestable market, but potentially not for others. Again, this issue requires urgent clarification. In either case, there is a need to ensure a seamless continuation of services for this vulnerable group.

Service recipients residing in regional and remote locations – it is noted that, under any alternative to the current Hearing Services Program, there needs to be a continuing principle of delivering hearing services of equal quality and availability regardless of location.

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Specifically, there is a need to invest in new permanent and visiting sites for service delivery, as well as tele-delivery of services to meet demand in these areas in financially sustainable ways.

Recommendations:

That the Government takes steps to ensure that the societal and economic benefits of access to hearing solutions are provided in an equitable way to all Australians irrespective of ability to pay.

The principle of choice of hearing service provider Government’s current policy has enabled the establishment of a high standard of hearing healthcare to CSO Clients, including 0-25 year olds. RIDBC believes that the introduction of full contestability to this cohort will erode those standards.

Children who are deaf or hard of hearing and their families are among those most at risk under a fully contestable market that will emerge under current plans to transfer the responsibility for delivering their services from the Australian Government Hearing Services Program to the NDIS.

Under the NDIS there will be a choice of service provider for CSO clients including children, for the first time. Personal choice is a concept we would all support, however it is concerning in this instance because the private market is untested in the delivery of services to children with hearing loss. The introduction of contestability introduces significant risks that must be understood and managed in terms of access, expertise, quality, informed choice, standards and client outcomes. 3

Despite the roll-out of the NDIS, it is the fundamental position of RIDBC that there should continue to be one single obligated provider for the CSO Client market.

3 Break the Sound Barrier Campaign, Deafness Forum of Australia

(http://breakthesoundbarrier.org.au/about-our-campaign/)

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The single obligated provider would continue to be obligated to deliver services to all current CSO Clients, regardless of complexity, geography, or cost of service delivery. Capacity to maintain service standards, clinical capability and availability that is tailored to CSO Clients would be sustained through this single obligated provider model.

Recommendation:

That, despite the roll-out of full contestability under the NDIS, there should continue to be one single obligated service provider appointed to meet the needs of the current CSO client market, including 0-25 year olds.

The liaison with key stakeholders in the design of NDIS hearing services, particularly in the development of reference packages

RIDBC has been supporting children with deafness or hearing loss for 155 years and over the past three years has expanded its offering to include a range of services for adults with hearing loss.

As the leading non-government provider of services for children, adults and families impacted by hearing loss in Australia, and as an educator of professionals specialising in sensory disability, RIDBC is acutely aware of the need to raise awareness about the impact of deafness and hearing loss and the importance of early intervention across the lifespan.

The NDIA has introduced the Early Childhood Intervention Approach (ECEI) to enable providers to continue to work with children and families during the transition to NDIS. While this approach acknowledges existing service and referral arrangements, providers are now required to undertake information gathering through assessments to develop individual support plans.

The reference packages should provide an expected consistent annual funding level for participants with similar support needs and characteristics and reflect the development of the individual support plans. The reference packages should ensure that services are available from identification through screening. Regrettably, analysis of actual experience compared with this expected experience is showing inconsistency of the NDIS planning process, allocated funding of packages and direct access to specialised services.

With these inconsistencies it is challenging to develop individual Plan packages that allow for continuous provision of service and/or an appropriate level of support.

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Recommendation:

That direct access to an assessment package is provided for all children identified through screening to determine ongoing service requirements.

Investment in research and innovation in hearing services Ensuring that future hearing health services continue to be delivered to all Australians efficiently, affordably, and to a world-class quality standard must be a priority for Government. The opportunity to maintain and build Australia’s global leadership role in technical and service innovation, ground-breaking research, and innovation in the hearing health field must be realised.

With the potential privatisation of Australian Hearing and the transition of the Hearing Services Program into the NDIS, there is an emergent issue associated with the management, recording, and analysis of data associated with hearing loss (particularly childhood hearing loss). Currently, Australia leads the world in regard to the quality and completeness of data relating to paediatric hearing loss. The database provided by Australian Hearing is as comprehensive as any data set anywhere in the world and has provided the opportunity for research such as the Long Term Outcomes for Children with Hearing Impairment (LOCHI) study to set a world-wide benchmark for research of this type.

A further emergent need is to ensure that the quality of data capture and data treatment is not diminished under any transition of hearing services from the Hearing Services Program to the NDIS. Specifically, there is a need to ensure that there is ongoing capability vested somewhere in Government-funded initiatives to ensure that the country maintains its preeminent positon as the world’s leader in hearing loss demography and associated research. By maintaining the high standards of demographic data collection, management, and analysis through such a body (potentially within the National Acoustic Laboratories — NAL), the Government can ensure that Australia (in both public and private sectors) maintains an ability to understand the population dynamics of hearing loss and the trends and patterns that exist in the population of people with hearing loss. Further, such initiatives can ensure that researchers and public policy-makers can continue to link demographics, research outcomes, and public policy initiatives with service delivery and clinical practices. Indeed, such demographic management and associated research can be seen as being “mission-critical” for informing Government policy initiatives as they relate to hearing loss and hearing health care.

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To this end, RIDBC urges the Committee to recommend the development of a Centre (or other definable capability) within NAL (or elsewhere) to function as a National Centre for

Hearing Loss Demography and Outcomes Research. As a Government-funded initiative,

such a Centre is deemed to be essential to provide:

In regard to innovation, RIDBC maintains that there is an opportunity to expand the current service model for people with hearing loss, to deliver stronger prevention, treatment and rehabilitation outcomes. Specifically, we advocate for the creation and development of a Total Service Model, which can provide:

 Specialist audiology and diagnostic services;  Hearing assessments;  Child and family needs assessment, family counselling and support;  Cochlear implants (CI) pre- and post-surgery support;  Early intervention/learning services (intensive therapy for speech, language, psycho-social & physical development);  Allied health services (speech and occupational therapy, psychology, access technology assessment and training);  Tele-diagnostic and telehealth services;  Specialist preschool, school and school support services;  Life-stage transition support (school, post school, career, work and leisure);  Lifelong audiology, diagnostics, allied health support, device mapping and maintenance and upgrades;  In-service education for allied professionals/continuing professional education (CPE) for direct-care professionals/research opportunities.

In proposing such a broad-ranging and closely articulated service model, RIDBC is not proposing an expansion of Government funding policy. Indeed, under such a model, people with hearing loss would still need to self-fund (or use private health insurance) to pay for any services they receive that are not funded under the Hearing Services Program, the NDIS, or Medicare.

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RIDBC’s strong advocacy is for the development of an integrated Total Service Model, offering all Australians with hearing loss a range of potential services in an articulated and co-located manner so as to capitalise more effectively on the investment by Government in the range of current service components (e.g., newborn hearing screening, hearing assessment, hearing device provision, and cochlear implantation, to name just a few of the Government-funded initiatives that are not currently well-coordinated in service delivery terms).

Recommendation:

That the Committee endorse the concept of a Total Service Model of hearing health care that is capable of ensuring the articulation and potential co-location of a broad range of services; so as to facilitate maximum return on Government’s investment in a range of hearing services that are not currently well-coordinated or articulated.

Any other relevant matter – the proposed transfer of Australian Hearing into non-Government ownership

In 2014 the National Commission of Audit recommended that Australian Hearing be transferred out of public sector ownership, prompting many clients, organisations and sector bodies to consider the significant impacts this would have on the wellbeing of Australians with hearing loss.

In February 2016, RIDBC, Cochlear Limited and Macquarie University formed a Consortium who put forward a proposal to Government for the future governance and ownership of Australian Hearing.

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The Consortium’s key driver is the wellbeing of Australians with hearing loss and its position is that if Government decides to move Australian Hearing out of public ownership, the Consortium approach provides a future for Australian Hearing that will preserve, protect and extend vital hearing services for all Australians.

If, on the other hand, Government decides to retain Australian Hearing the Consortium asserts that Government must invest in it, improving hearing services for vulnerable Australians, including children, older adults and people living in rural and remote communities.

Should Government pursue the commercialisation of Australian Hearing, it is critical that the provision of high quality comprehensive services as provided through the CSO remain accessible for all vulnerable Australians.

At the time of lodging this submission there is no further update on the Government’s position with regard to the transfer of Australian Hearing out of Government ownership.

Recommendation:

That the Committee explore the likely future for Australian Hearing, in the context of the NDIS era, with a particular focus on:

 Safeguarding the delivery of services currently made available through the CSO requirements of Hearing Services Program, particularly with changing eligibility criteria under the NDIS;  Addressing areas of service growth and unmet need;  Providing an enhanced service and improved hearing health outcomes for all Australians;  Building on Australian leadership in hearing health and keeping ownership of Australian Hearing in Australian hands;  Furthering the work of Australian Hearing’s research division, the National Acoustic Laboratories (NAL);  Extending Australian Hearing’s service offering, ultimately providing a total end-to end service for people with hearing loss, including: integrated assessment; diagnostics; hearing aids; cochlear implantation; therapy; education; rehabilitation & support services.

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