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Second supplementary submission to the Joint Standing Committee on the National Disability Insurance Scheme inquiry into the provision of hearing services under the NDIS, March 2017
Dr Jim Hungerford, CEO
Summary
This is a second supplementary submission made by The Shepherd Centre, subsequent to the hearing of the Joint Standing Committee on the National Disability Insurance Scheme inquiry into the provision of hearing services under the NDIS, held in Melbourne on 24th March 2017.
Key issues arising from the hearing on 24th March are:
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Need for a new guided referral pathway to early intervention, not Australian Hearing Australian Hearing is not currently a referral pathway for children to proceed to early intervention. It cannot provide this referral service under current plans as it would have an untenable conflict of interest position both due to its own moves to provide early intervention and with the future contestability of paediatric audiology services. A new referral service is required.
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Need for funding to achieve outcomes, not to only incentivise inputs Current NDIS funding is for direct services only, which only part-funds the complex services needed to enable children to achieve good language. The NDIS funding system must move from input funding (direct service hours) to outcome funding (achievement of good language) otherwise children will not achieve outcomes and future costs will rise dramatically.
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Need to provide NDIS support for children with unilateral or mild hearing loss Support for children with single-sided deafness or mild hearing loss was not addressed. These children are very likely to develop deficits once they are in the more challenging environment at school. A small early intervention investment will ensure that this future cost is avoided.
Guided referral pathway There appeared to be the suggestion during the hearing that retaining Australian Hearing’s current role would address the guided referral pathway requirement. This is not correct. A new pathway, replicating the ones previously provided by some of the States, is needed.
Australian Hearing is currently a destination in the pathway (it receives children after diagnosis); it does not refer children through to Early Intervention. Australian Hearing is not funded to refer children to early intervention and it sees this as something that is outside its scope of service. The guided referral pathway must be all the way to Early Intervention services and so a new function is required. This is covered in the submissions that have previously been made to the Committee.
Also, Australian Hearing must not be the monopoly provider of paediatric audiology services if it continues its current plan to also provide early intervention services (currently it is trialling this). Australian Hearing would be in an untenable conflict of interest position.
This is particularly important if the privatisation of Australian Hearing is still being pursued. It is inevitable that anyone who is in a monopolistic position will automatically prefer its own other services – so if Australian Hearing stays in that role then it should be prevented from also providing early intervention services.
The alternative is for the guided referral pathway to be entirely separate from Australian Hearing; and for paediatric audiology to only be provided by selected authorised providers (with quality controls as per the other submissions made to the Committee).
Need for the NDIS to fund outcomes for children with hearing loss There was considerable discussion during the hearing about the importance of adequate early intervention funding for children with hearing loss. It is critical to ensure that this funding is oriented so that children can achieve outcomes; however currently the funding only incentivises inputs.
The current funding is for direct inputs (number of direct service hours). This is less than the overall cost of an effective service, so in the short-term it reduces costs to the NDIS (by up to 50% over 3 years). However it will more than double the mid- to long-term cost, with the increased cost over the rest of childhood being much greater than the short-term gain.
Children need a package averaging up to $20k for 4 years to develop age appropriate language (requiring extensive non-direct support as well as direct support – so is not achieved with $175 x direct hours). However, once good language is achieved, the required level of funding drops dramatically for the rest of their life (down to a maintenance level of only a couple of thousand per year).
In contrast, funding inputs – direct hours x $175 – will cost about $10-12k per year, but then the child won’t achieve good language and so will stay in the disability system permanently, which will cost the NDIS much more within just a few years.
This is dramatically exemplified by comparison of the supports that a person with good language will need, versus one with poor or inadequate language. With good language a child can succeed well at school, receive a tertiary education, and go on to be an economically contributing member of society. A person with poor language will struggle academically, will probably get a low-paid job if employed at all, and may be dependent on social security payments. Ensuring children grow up with good language is a massive financial opportunity not a cost.
I see the easiest way to enable this funding, without creating unacceptable precedents, is to link full funding to the necessity of each service to demonstrate outcomes that achieve a post cost benefit ratio.
The Shepherd Centre 2nd supplementary submission to the inquiry into hearing services under the NDIS, March 2017 Page 2 of 3
The ‘Quality & Safeguards’ approaches do not assist with this – they definitely do not include the outcomes part of quality; so outcomes need to be separated prescribed. This same approach of linking extra funding to the achievement of outcomes which provide a cost benefit could then be applied to any other disabilities where this evidence exists.
The secondary advantage to funding for outcomes is that a specific service methodology isn’t being prescribed (which is what occurs when specific inputs are required; and this is the way the references packages are heading) and so you can encourage innovation and future cost reductions.
Eligibility of children who are unilaterally deaf or have bilateral mild loss This was not discussed at the hearing, however there is solid published evidence of the deficits that become visible once children with single-sided deafness (unilateral hearing loss) or mild hearing loss are at school. This is demonstrated by the recent experience at Cora Barclay where I believe they now have approximately 50 school-aged children with unilateral hearing loss. These children had not received any early intervention support and now have significant and expensive issues.
In accordance with the insurance approach, the provision of a small amount of EI to these children when they are young prevents the larger cost in their future.
The Shepherd Centre 2nd supplementary submission to the inquiry into hearing services under the NDIS, March 2017 Page 3 of 3