Sydney ∙ Macquarie ∙ Liverpool ∙ Wollongong Canberra ∙ Online & Telepractice Website: www.shepherdcentre.org.au
ABN: 61 000 699 927
Submission to the Joint Standing Committee on the NDIS inquiry into the provision of hearing services under the NDIS – response to request for submissions 18th August 2017
Dr Jim Hungerford
Submission on behalf of:
First Voice (as member of the Board); and The Shepherd Centre (as CEO)
August 2017
This submission is in response to the Committee’s request of 18th August 2017 regarding:
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The impact on access and provision of adequate supports and services for deaf and hard of hearing children, their families and carers due to the delay in establishing reference packages which were due in April; and
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The guidance for determining access to the NDIS [for people with a hearing impairment].
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Impact of delay in establishing reference packages The Committee has previously been provided with extensive evidence on the shortfall in the funding provided for children with hearing loss. This shortfall is due to the NDIS not having established reference packages that appropriately fund the specialised and integrated services that children with hearing loss require to achieve age-appropriate language.
Despite the previous assurances to the Committee and to the sector, these reference packages are still not available.
The impact of this delay is demonstrated by the situation of The Shepherd Centre, which has been providing NDIS-funded services for children with hearing loss since its commencement in the Act in 2014. In 2014 and 2015 the quotes for service provided by The Shepherd Centre to the NDIS were accepted based on the evidence provided on both the needs of the child and the effectiveness of the therapy.
The evidence for this effectiveness is the same as that previously provided to the Committee. For example, for the children with hearing loss alone who ‘graduated’ from The Shepherd Centre in 2016 (that is, completed their early intervention program prior to entering school), the language and vocabulary of the
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children equalled that on children without loss (an average language score of 99 versus a population average of 100; and an average vocabulary score of 103 versus a population average of 100).
This is in contrast to the typical outcomes for children with hearing loss in Australia, where many of these children fall below the normal range for language (data from the LOCHI study).
However with the onset of the national roll-out, the NDIS revoked the previous commitment to fund these evidence based therapies and commenced restricting funding.
The impact of these restrictions has been well publicised, with the Cora Barclay Centre (which has been participating in the NDIS since inception) losing $1.5 million to date (based on an independent audit) and with The Shepherd Centre suffering a financial loss of over $900,000 in 2016 alone, substantially due to the NDIS.
The funding situation has not improved in 2017. The following two graphs are for the NDIS plans approved in 2017 for the children attending The Shepherd Centre, depicting a comparison of the cost of the plans versus the amount funded; and the % funding of services for each of the plans approved.
$40,000
Early Intervention
$35,000 School Aged
LinearLinear trendline(Early Intervention)
$30,000 amount $25,000$20,000
$15,000 Funding $10,000
$5,000
$0
$0 $5,000 $10,000 $15,000 $20,000 $25,000 $30,000 $35,000 $40,000
Cost of plan
100%
80% funded 60% cost plan 40% of % 20%
Early Intervention
School Aged
0%
Jan 17 Feb 17 Mar 17 Apr 17 May 17 Jun 17 Jul 17 Aug 17
Date of plan approval
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Overall, for the 62 plans approved so far this year for children in our early intervention program, the average cost of the service was $16,700 and the average funding was $10,500. In the extreme, one child’s plan had a shortfall of $24,100 (some children with extreme needs required plans costing up to $35,500). The average shortfall of $6,200 per child is the equivalent of $2.1 million dollars a year for the 340 children who participated in our EI program in 2016.
For the 15 children of school age who have received plans so far this year, the average cost of service was $11,200 and the average funding was $7,600; with an average shortfall of $3,600. For the 55 school aged children we supported in 2016 this equates to $0.2 million.
The Shepherd Centre cannot sustain losses of $2.3 million a year.
So far The Shepherd Centre, as with the other charities in the sector, has funded the services these children need through drawing down on their financial reserves. This has enabled the children to be shielded from the impact of the funding restriction. However this cannot continue and very soon, as charities exhaust their reserves, services must be cut. We have already seen one major charity in the sector conclude that this is not sustainable and it has decided to be absorbed into a larger charity. This reduces the choice and options available to parents, a market failure that is in direct contrast to the aim of the NDIS.
Once effective programs such as the one provided by The Shepherd Centre cease we will rapidly see an increase in the number of children and then adults with delayed language and potentially with no functional spoken language at all.
The future negative impacts of this will be massive, for the child; for society; and also for the NDIS (with the need to then provide life-long support due to the permanent disability that should have been avoided).
The draft National Reference Packages that have been presented to the sector do not address the financial shortfalls currently being incurred.
Recommendations: the NDIA immediately:
- establish National Reference Packages; that
- fund the cost of programs that have been shown to be effective.
- Guidance for determining access to the NDIS The NDIA has recently stated its new guidance for ‘automatic’ access to the Scheme (that is, without requiring further assessment against the requirements in the Act).
In summary the new guidance is:
A. Early Intervention eligibility requirements (restricted to people aged from birth to 25 years old)
- Hearing loss of ≥ 25 dB in either ear at 2 or more adjacent frequencies (or hearing loss due to auditory neuropathy); that necessitates the use of personal amplification
B. Permanent disability eligibility requirements (for all people)
- Hearing loss of ≥ 65 dB in both ears averaged over 4 frequencies The guidance notes that for permanent disability, a lower level of loss may be assessed to be sufficient for eligibility, if combined with other impairments (such as to vision or cognition); or if there is evidence of significantly poorer than expected speech detection and discrimination outcomes.
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2.1 Early Intervention access requirements These access requirements are appropriate and reflect the current practices of Australian Hearing.
However:
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Appropriate National Reference Packages are still required to ensure that the required early intervention support is funded as required (as above)
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The NDIA currently limits EI support to a maximum of 7 years. A child’s language develops over many more than 7 years and hearing loss will impact throughout this development. As a result routine support (at a mostly significantly lower and decreasing level) is required through the school-age years
Recommendation: the NDIA ensure that the National Reference Packages fund the cost of the programs that are required for children of school-age.
2.2 Permanent disability access requirements The effect of the eligibility threshold is that a person who is profoundly deaf in one ear (that is, cannot hear anything at all on that side) and has a hearing loss of 60dB in the other ear (often referred to as severe hearing loss) would not be automatically eligible.
A person with this level of hearing loss is totally dependent on devices for their functional access to sound – either hearing aids or cochlear implants. If these devices are appropriately provided and fitted the person should have sufficient access to sound to be able to hold spoken conversations and to be able to participate through their hearing in society and the workforce.
However if the person does not have these devices they will probably not be able to have effective spoken conversations or be able to participate in society or the workforce through their hearing.
This creates a major risk for a working adult using hearing devices – if they lose their job they will not be able to pay to maintain their devices; without their devices they may not be able to hear well enough to get a job. They may drop out of the workforce permanently and become reliant on social benefits.
A system to support adults to be able to afford to maintain their hearing devices is required so that the above scenario does not occur.
Recommendation: the Government to establish a mechanism to support the maintenance of hearing devices by adults, such as through making these expenses tax deductible.
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