Submission 45 — Vicdeaf — The provision of hearing services under the National Disability Insurance Scheme (NDIS) | External submission

Vicdeaf submission on the provision of hearing services under the National Disability Insurance Scheme.

Vicdeaf welcomes the opportunity to submit information and recommendations to the Joint Standing Committee on the NDIS.

Vicdeaf is a progressive, iconic community organisation that builds pride in being Deaf, improves social, economic, cultural and civic participation, supports people to communicate and connect with the world, and advocates for the needs and aspirations of those we service. Established in 1884, Vicdeaf currently offers a range of services including employment, community engagement, NDIS supports, audiology, devices, interpreting and Auslan training. Vicdeaf supports a diverse range of people to achieve its vision “our clients and our community live in an accessible, inclusive society with equal opportunity in all areas of life”.

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

The NDIS eligibility criteria currently presents a number of barriers for Deaf and hard of hearing individuals wishing to access the service. Three specific areas are pertinent.

a. Individuals over the age of 65 are ineligible for the NDIS and this impacts the capacity for those aged over 65 to live an ordinary life. Members of the Deaf community have historically had insufficient access to a variety of services to better their lives. For areas such as Auslan interpreting in instances that fall outside of the Government funded schemes for medical and employment interpreting, the onus of cost has defaulted to the Deaf individual. Due to the high costs involved in regular use of Auslan interpreting services, many have simply gone without. Many Deaf and hard of hearing individuals have been waiting decades for better access to, and more funding for, services to enrich their lives.

b. There are currently disparities in scheme rollout, with some areas of the country not rolling out until 2019. For Deaf and hard of hearing individuals who live in certain areas, such as outer suburban Melbourne, and who are aged 63 years or older, they will be ineligible for the NDIS by the time of rollout. Vicdeaf believes that many Deaf and hard of hearing people will be precluded from entering the scheme due to their present postcode and proximity to the age cut-off. A similar situation exists within Tasmania, where rollout periods relate to age brackets.

c. Deaf and hard of hearing individuals from migrant backgrounds represent a significantly disadvantaged cohort, yet many are ineligible for NDIS due to not presently meeting residency or special visa criteria within the application process. Many of these migrants are presently accessing vital services through Department of Health and Human Service (DHHS) block funded programs. As this funding slowly dwindles with more rollout zones occurring within years to come, if no provisions are put in place, a disadvantaged sub-community

within the Deaf and hard of hearing cohort may go without access to any supports or services.

Vicdeaf recommends that further consideration be made to the continuity of support provisions under the bilateral agreements between the state and Commonwealth governments to safeguard those who will be put at service risk due to their age.

Delays in receiving services, with particular emphasis on early intervention services; Deaf and hard of hearing individuals are current experiencing delays in receiving NDIS related hearing services. This is primarily due to the lengthy time periods involved in the NDIS process and, as has been observed in the North Eastern Metropolitan Area (NEMA) and Barwon, with a wait time of many months before a participant receives an approved plan. This has a significant impact on both participants in the program, and service providers.

Participants in need of vital services, which would have been accessed with a much quicker turn around under DHHS block funding, simply have to wait to receive said services until plans have been approved. On the other side of this, there is an expectation on service providers to provide necessary services to participants on a ‘pro-bono’ arrangement until plan approval, as services cannot be claimed in arrears. As example of this, in the Barwon region, support workers have had to deduce which client needs were most pressing to provide pro-bono support for; evidence of this is beginning to become apparent in NEMA. This is unreasonable and unsustainable for service providers, and completely removes the choice and control elements of the NDIS program for participants.

Concerns regarding the NDIS application and access process of have arisen for Deaf and hard of hearing individuals. Access to the NDIS currently occurs in two ways; via the Access Request Form (ARF) process for new NDIS participants and via an automatic rollover process for participants presently on state funding packages. The rollover process is much simpler and quicker for the individual, however it is a phoned-based process in Victoria and this has caused issues for many people:

The NDIA contact the participant via mail to inform them of the automatic rollover process that is to occur, and advised them they will be telephoned for more information. The participant is telephoned a number of times over a seven day period. If the participant does not answer the NDIS telephone calls within that period, they are mailed an ARF and are forced to go through the lengthy application process that initially they are not required to do.

Many Deaf and hard of hearing people are unable to use telephone or mobile devices for calls, and for many Deaf people written English is not easily understood. Skype is a preferred method of contact and communication for the Deaf community and the integration of Skype into the NDIA service processes would be ideal.

Vicdeaf recommends a review into NDIA policies around contacting clients with a hearing loss and implement language appropriate solutions, including text and email communication and the use of video remote interpreting, and that a Skype service be available for Auslan users to contact an Auslan using NDIA representative.

The adequacy of funding for hearing services under the NDIS; Whilst Vicdeaf acknowledges funding packages for each individuals should look different, taking into account the individuals personal circumstances and other barriers to life, a disparity in funding packages for what we believe to be reasonable interpreter supports has arisen. These disparities often lead to lengthy appeals processes, which although are largely successful, delay the participant’s access to services and supports. Vicdeaf believes these disparities stem from three key areas:

a. Lack of understanding from the planner on key issues that effect a Deaf or hard of hearing person’s quality of life.

b. A disparity between what a planner or plan partner recommends, and what is seen to be reasonable and necessary by the authorising delegate (who lacks the narrative which informed the original recommendation).

c. That provision of an interpreter in planning meetings is provided only at the participant’s request. When an NDIS applicant’s is primary language is listed as Auslan, it is preferable that an interpreter be provided automatically. Vicdeaf has observed planning meetings whereby no interpreter has been provided, and the Vicdeaf staff member is required to provide communication support. To enable a comprehensive understanding of the nuances of the NDIS planning process and to ensure the most appropriate NDIS plan is developed, an interpreter should always be provided for Deaf applicants (unless the applicant specifically requests not to have one present).

Vicdeaf recommends:

 More training for planners relating to Deaf and hard of hearing issues, requirements, needs and services.  That funding delegation be moved to plan partner organisations, noting that this will be trialled shortly within Tasmania.  Mandating interpreter use in planning meetings when Auslan use is indicated (and that this is not left to applicant request).

The accessibility of hearing services, including in rural and remote areas; Regional and remote citizens are often at a disadvantage when accessing specialist hearing services. This is due to a decrease in service options available in rural areas, further travel distances required to reach specialised services, and inflated service costs in rural areas whereby the professional has travelled to the area, as these travel costs are often incorporated into the service fee.

The NDIS currently only offers remote and very remote funding allowances for individuals living in regions such as the Northern Territory. For deaf and hard of hearing cohorts who live in regional areas considered remote by distance, but not by NDIS definition, there are no provisions in place. Participants are having to use additional funding from their packages to cover inflated fees and travel costs (for example, paying 3 hours from their package for a 1.5 hour appointment to cover the travel and cost inflation involved). This is unreasonable and unsustainable.

Technology can play a part as a key enabler in these instances. For example, Vicdeaf offers a Video Remote Interpreting service (VRI) which is funded by DHHS to provide services via video to iPads, computers, laptops etc. This is to reach those who cannot access interpreting onsite, however, more awareness and promotion needs to take place to advertise these alternative services.

Vicdeaf recommends consideration for NDIS packages to cover travel to support for participants in regional areas for specialist service provision.

The principle of choice of hearing service provider; Following on from point four, participant choice becomes increasingly restricted the further a Deaf or hard of hearing participant lives from a major metropolitan area.

For Deaf participants who use Auslan, the lack of staff with sign language proficiency at providers in general severely reduces the principle of choice. Although the use of Auslan interpreters can correct this to some degree, it should be noted that communication through a language intermediary can affect rapport building and the development of trust, and for some participants this limits choice.

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

There is currently insufficient information regarding Deaf and hard of hearing reference packages – to our knowledge a Deaf specific reference package are not yet in existence.

Vicdeaf recommends that Deaf and hard of hearing reference packages be created as a matter of priority.

Investment in research and innovation in hearing services; Vicdeaf is a partner with the Hearing Cooperative Research Centre Association, and will continue this research partnership in the future. However, it is imperative that funding be provided to ensure research conducted is relevant, insightful and beneficial to the continuing development of hearing services, particularly under the NDIS.

Vicdeaf recommends further research into hearing loss, prevention, causes, treatments, regimes and potential new technologies.

Any other relevant matter; Early intervention for Deaf children requires further consideration. It is important that approaches and strategies for early intervention fully consider the linguistic needs of the Deaf child and the family environment; that more effective and timely information is provided to enable families to exercise informed choice with regard to early intervention; and that Auslan acquisition programs are more readily available to families of Deaf children (programs which combine social, cognitive and linguistic development).

The multiple Auslan interpreter funding schemes currently in place require urgent resolution as they are increasingly intersecting with the NDIS. Three funding schemes presently exist; the Employment Assistance Fund (EAF) for employment interpreting, National Auslan Booking Service (NABS) for medical interpreting, and the NDIS for social interpreting and community inclusion. Planning around NABS and the NDIS is well advanced, but already concerns are being raised within the sector around access and eligibility.

Vicdeaf recommends consideration be given to:

Combining workplace (EAF), medical (NABS) and social/community access interpreting (NDIS) into a single fund under the Department of Social Services, without precluding eligibility (for example to those over 65 years of age).
Creating an interpreter needs assessment which allows for flexibility of funding, including ease of reallocation of package amounts between social, medical and employment as needs change.
Basing funding packages for interpreters on what is reasonable and necessary for each individual.