Recommendations for paediatric hearing service delivery under the NDIS | External submission

Joint Standing Committee on the

National Disability Insurance Scheme

Submission to:

The Joint Standing Committee inquiry into the provision of hearing services under the NDIS

On behalf of:

Australasian Newborn Hearing Screening Committee

(a subcommittee of Deafness Forum of Australia)

Contact person for further information:

Professor Greg Leigh, AO, PhD, FACE

Chair, Australasian Newborn Hearing Screening Committee

Summary Recommendations

The Australasian Newborn Hearing Screening Committee recommends that

Joint Standing Committee Inquiry should conclude that:

Due to the complexity of the delivery of paediatric hearing services, such services should only be funded by the NDIS when they are provided by audiologists with training and appropriate expertise in assessing, fitting of amplification and rehabilitation working with infants and young children with complex hearing rehabilitation needs.
When the CSO component of the Hearing Services Program has transitioned to the NDIS, the Agency should designate and obligate a single national provider of hearing services for children under a national contract. We propose that Australian Hearing should continue in that role as the obligated national provider, subject to appropriate standards to safeguard the quality of service delivery. However, if Australian Hearing does not retain that role, then any other organisation so contracted should similarly be obligated (and funded) to ensure the delivery of (a) universally available hearing services across a geographic network equivalent to no less than that currently provided by Australian Hearing under their current Community Service Obligations, (b) professional capability in paediatric hearing services that is sustained at the highest possible level by the economies of scale in professional training that is afforded by their status as a national provider, and (c) hearing device provision and fitting services that preserve Australian Hearing’s current economies of scale in device purchase and distribution but ensure that families of newly diagnosed children are not exposed to the pressures of direct marketing of hearing devices in the vulnerable post-diagnostic period.
There should be a National Centre for Hearing Loss Demography and Outcomes Research developed as a Government-funded and administered 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 process for national data collection and management in regard to paediatric hearing services programs (i.e., including both newborn hearing screening, infant diagnostics, hearing device provision under the NDIS, and early intervention provision under the NDIS);  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 all interventions for hearing loss.

Background In the absence of intervention, children with permanent congenital hearing loss will typically experience delayed or disordered communication and language abilities, with consequential impact upon their educational achievement (Leigh, Schmulian-Taljaard, & Poulakis, 2010). The capacity to ameliorate the effects of congenital hearing loss is enhanced greatly by intervention being provided at the earliest possible time. This is because there is a highly sensitive period for the development of a range of cognitive and linguistic abilities that commences before birth and continues through very early childhood (particularly during the first 12-18 months).

Because of the critical nature of this period of early development, it is extremely important that congenital hearing loss is identified and intervention is commenced at the earliest possible time. Current international research, including the Long-term Outcomes for Children with Hearing Impairment (LOCHI) (Ching, Leigh, & Dillon,

study being undertaken in Australia under the auspices of the National Acoustic Laboratories, indicates that babies whose permanent bilateral hearing impairment is diagnosed early have significantly better developmental outcomes than children identified later. There is a significant relationship between the age at which children’s hearing loss is identified and their levels of language and communication ability later in childhood. In the LOCHI study, for example, children whose hearing loss was identified earlier have been shown to have, on average, better language and communication skills at 5 years of age (Ching, 2014).

The Australasian Newborn Hearing Screening Committee (hereafter, “the ANHSC”)

has been active in advocacy for the introduction and subsequent development of newborn hearing screening since 2001. At that time, the ANHSC was responsible for the development, wide endorsement, and dissemination of the first Australian Consensus Statement on Universal Neonatal Hearing Screening.

The ANHSC (as a sub-committee of Deafness Forum of Australia) comprises a broad range of professionals representing the fields of Otolaryngology, Paediatrics and Child

Health, Education of the Deaf, Audiology, and Nurse Audiometry. The Committee’s

membership includes a Coordinator/Director (or equivalent role) from every Australian state/territory-based Universal Newborn Hearing Screening program, as well as representatives from the Deafness Forum, Australian Hearing, the Newborn Hearing Screening Programme of the National Screening Unit in New Zealand, and representatives of parents of children with impaired hearing, including Aussie Deaf Kids.

The initial goal of the ANHSC was to advocate for the introduction of newborn hearing screening programs across Australasia (i.e., Australia and New Zealand). Since its inception, however, the ANHSC has also advocated for the maintenance of standards and the advancement of good practice in newborn hearing screening programs, and

the development and application of a national quality and reporting framework for such programs. To these ends, the ANHSC has:

 Provided support for a national working party on the development of standards for newborn hearing screening under the auspices of subcommittees of the Australian Health Ministers Advisory Council (AHMAC);  Collated information about protocols and practices associated with the various state screening programs with a view to advocating for acceptable minimum nationals standards of care in regard to UNHS; and  Strongly advocated for a national approach to data collection and management.

In addition, the ANHSC:

 Continues to advocate for the achievement and maintenance of full national population coverage by universal newborn hearing screening programs; and  Has staged eight National Conferences on Universal Newborn Hearing

Screening. The 9th Australasian Newborn Hearing Screening Conference will

be held in Melbourne in May 2017.

Response to the Terms of Reference (TOR) This submission directly and indirectly addresses issues pertaining to terms of reference 2, 4, 5, 7, and 8, those being:
Delays in receiving services, with particular emphasis on early intervention services;
The accessibility of hearing services, including in rural and remote areas;
The principle of choice of hearing service provider;
Investment in research and innovation in hearing services;
Any other relevant matter. Specifically, this submission addresses the status of newborn hearing screening in Australia and the critical importance of maintaining the integrity of the neonatal screening pathway to ensure that there is a seamless progression available to children with hearing loss (and their families) from the identification and diagnosis of their hearing loss to engagement with early intervention services.

3.1 The status of UNHS in Australia

In July 2009, the Council of Australian Governments (COAG) resolved that universal and standardised neonatal hearing screening should be available in all states and territories by the end of 2010.

In all state and territory health jurisdictions in Australia where Universal Newborn Hearing Screening UNHS has been implemented, the age of confirmation of permanent childhood hearing loss and commencement of appropriate early intervention have been significantly reduced. In the years following the introduction of the State-wide Infant Screening for Hearing (SWISH) program in NSW, for example, the average age of full diagnosis of children with permanent bilateral hearing loss fell

from approximately 18 months to just 1.6 months (New South Wales Health Department, 2006; Leigh, Schmulian-Taljaard, & Poulakis, 2010).

3.1.1 Current coverage of the Australian population by UNHS

At the time that the ANHSC was formed in 2001, there were no whole-of-population UNHS programs in Australia. In the period between 2001 and 2009 when COAG made its commitment to the introduction of UNHS, five of the eight states and territories had achieved what could be described as full population coverage (i.e., that all newborn babies are offered the opportunity to have their hearing screened and greater than 95% of those babies complete the hearing screening process in a timely manner). In 2009 the ANHSC estimated that approximately 84% of children born in Australia were completing a screen for hearing at birth.

Since 2009, the final three states and territories (Northern Territory, Victoria, and Western Australia) have competed the roll-out of their UNHS programs—the last being Western Australia in 2015. On the basis of available information, the ANHSC estimates that Australia has now reached a point where all, or close to all, newborn children have the opportunity to have their hearing screened at or soon after birth.

3.2 Maintaining the integrity of early identification and intervention systems

3.2.1 The need for national standards, and quality assurance

According to the international literature, there is a clear need for systematic evaluation and monitoring of early identification and early intervention programs for children with hearing loss to ensure quality and effective outcomes. In the United States, the Joint Committee on Infant Hearing (JCIH, 2000, 2017, 2013) has produced a set of guidelines that provide substantial advice in this regard.

At the centre of the JCIH’s standards are goals that are recognised internationally as a minimum for effective early identification and early identification and intervention programs. Specifically, those goals are that:

“the hearing of all infants should be screened at no later than 1 month of age. Those who do not pass screening should have a comprehensive audiological evaluation at no later than 3 months of age. Infants with confirmed hearing loss should receive appropriate intervention at no later than 6 months of age from health care and education professionals with expertise in hearing loss and deafness in infants and young children. (JCIH, 2007, p. 898)”

“(and)…regardless of prior hearing screening outcomes, all infants who demonstrate risk indicators for delayed onset or progressive hearing loss should receive ongoing audiologic and medical monitoring for 3 years and at appropriate intervals thereafter to ensure prompt identification and intervention. (JCIH, 2000, p. 798)”

As part of the COAG commitment to the introduction of newborn hearing screening in 2009, the Australian Health Ministers’ Advisory Council (specifically, the Australian

Population Health Development Principal Committee), undertook the development of a National Framework for Neonatal Hearing Screening. As part of that initiative there was also a commitment to national data collection relating to newborn hearing screening.

At that time (and still) the ANHSC argued that a national system was required to ensure that screening, diagnostic, and intervention services:

are carried out to a high standard;
are carried out in a timely fashion;
communicate with families effectively and in a timely manner;
provide comprehensive support post-diagnosis in transition to intervention;
have systems to ensure that recording, reporting, and improvement of system performance occurs across the screening pathway; and
capture and report data accurately and efficiently.

In 2009, the Australian Population Health Development Principal Committee

(APHDPC) established a Neonatal Hearing Screening Working Group for the purpose of developing the National Framework and associated standards. The ANHSC provided extensive input into the development of a draft Framework and a set of draft standards for neonatal hearing screening which were completed in 2010. That draft document included 77 potential performance indicators for the operation of UNHS programs.

The “National Framework for Neonatal Hearing Screening” (Department of Health,

was finally endorsed by the Community Care and Population Health Principal Committee (CCPHPC) and released officially by the Department of Health in 2013.

According to the website of the Department of Health (http://www.health.gov.au/internet/main/publishing.nsf/Content/neonatal-hearing-screening), the National Framework was developed with the aim of achieving harmonisation of the efforts to implement UNHS of the various state and territory jurisdictions. Specifically, the Framework was described as “a resource for jurisdictions to use when developing neonatal hearing screening services”. The 77 quality standards that were included in in the draft framework were included in the final document “for guidance only” with the stated intention that they “not be collected or reported”. It was acknowledged, however, that the AIHW had “refined” the original indicators, resulting in a limited set of just seven quality and performance indicators.

The final seven indicators of quality and performance for UNHS programs were published by the AIHW in 2013 as “National performance indicators to support neonatal hearing screening in Australia” (AIHW, 2013). The stated intention of that AIHW document was “to provide the Australian neonatal hearing screening community with a national reference point for monitoring of neonatal hearing screening activity” (AIHW, 2013, p. 1). The document detailed the seven performance indicators and provided the technical specifications and data elements that would be required in order for jurisdictions to calculate and report against those indicators.

The ANHSC has advocated strongly for the adoption and implementation of the “National performance indicators to support neonatal hearing screening in Australia” (AIHW, 2013). Specifically, the ANHSC made the following recommendation to the

recent House of Representatives Standing Committee on Health, Aged Care, and Sport Inquiry into the Hearing Health and Wellbeing of Australia:

That the Inquiry endorse the “National Performance Indicators to Support Neonatal Hearing Screening in Australia” (published by the Australian Institute of Health and Welfare, 2013) and recommend that those standards become part of a national monitoring and reporting initiative under the auspices of AHMAC (i.e., through Standing Committee on Screening). Specifically, it was recommended that all state and territory health jurisdictions be required to report on all seven performance indicators as a basis for ensuring the quality and integrity of UNHS programs nationally.

In addressing the current Inquiry of the Joint Standing Committee on the National Disability Insurance Scheme, the ANHSC seeks to add to address a significant and related concern.

Given the very considerable work that has gone into ensuring that there is a viable system for identification of, and intervention in, infant hearing loss in Australia; and, given the existence of the National Framework for Neonatal Hearing Screening and

the associated National Performance Indicators to Support Neonatal Hearing

Screening in Australia, it is a matter of grave concern to the ANHSC that critical components of the national neonatal screening pathway described by those documents are at risk as a consequence of the proposed transition of the Hearing Services program to the National Disability Insurance Scheme (NDIS). Specifically, it is of concern to the ANHSC that the current functionality fulfilled by Australian Hearing under the National Framework for Neonatal Hearing Screening is not assured under the plans for the transition of paediatric hearing services to a contestable market under the NDIS. Specifically, the ANHSC holds concerns for the integrity of assessment, device fitting, and referral functions currently fulfilled by Australian Hearing in the hearing screening and intervention pathway under any new system of contestable services under the NDIS.

3.3. The benefits of a preserving a dedicated Hearing Services Provider for the

Neonatal Screening Pathway

Under the National Framework for Neonatal Hearing Screening, Australian Hearing

plays a pivotal role in the pathway from screening to engagement with early intervention services and beyond (Department of Health, 2013). Currently, the services of Australian Hearing ensure that the families of children with newly diagnosed hearing loss are provided with timely and supported access to high quality hearing assessment and fitting with appropriate high quality hearing devices (hearing aids). Further, Australian Hearing serves to ensure that families are informed about and directed to a range of early intervention services. These important services are delivered nationally to a level of capability that is the envy of the developed world. Under the Community Service Obligations (CSO) placed on Australian Hearing under the terms of the Hearing Services Program, these services are delivered by Australian Hearing to a uniformly high standard across the country, regardless of families’ geographic locations.

The ANHSC advocate that it is imperative that the level of capability in the early assessment of hearing loss, early fitting of devices, and onward referral to other intervention services that is currently provided by Australian Hearing is maintained in any new system for the delivery of paediatric hearing services in Australia. In particular, it is imperative that time spent by families in receiving these services and moving to the next stage in the hearing screening and intervention pathway is minimised by the ready availability and accessibility of those services. The ANHSC contends that the current role of Australian Hearing as a dedicated and obligated national provider of paediatric hearing services is critical to the integrity of the national neonatal hearing screening pathway as described under the National Framework for Neonatal Hearing Screening.

If the current paediatric CSO services of Australian Hearing (i.e., as a sole national provider) role are to be replaced by a range of contestable services under the NDIS, the ANHSC argues that there are very considerable risks to be addressed on several fronts. Not least among these risks is the potential for commercial imperatives to introduce variability in the quality and professional capability of such services and, in particular, variability in the quality or availability of appropriate services in rural and regional areas.

The ANHSC is deeply concerned that the delivery of best practice in paediatric hearing services (i.e., of the type that has been delivered to newly diagnosed children with hearing loss and their families by Australian Hearing) will not be well served by allowing free market dynamics to dictate the provision of such services under the auspices of the NDIS.

The ANHSC contends that process of transition of children and families from diagnostic audiology to early intervention that is currently overseen by Australian Hearing’s paediatric services must be underpinned by highly skilled and readily available services for all Australian children regardless of their physical location. Currently, the manner in which these services have been provided nationally by Australian Hearing (in cooperation with State UNHS programs) has seen Australia become the envy of rest of the world in regard to securing uniformly positive outcomes from UNHS, including world-leading low levels of “loss to follow-up” in the screening pathway.

Given these concerns, the ANHSC recommends that, regardless of whether Australian Hearing is privatised OR the Hearing Services Program is transferred to the NDIS, there should continue to be a single national provider obligated to provide audiological assessment, device fitting, and onward referral to children diagnosed with hearing loss in Australia. Such a provider, whether or not that continues to be Australian Hearing, should be funded and obligated under the terms of the NDIS to provide services to a uniform standard in all locations currently served by the Australian Hearing under the CSO component of the current Hearing Services program. To do anything less than this puts at risk a neonatal screening, diagnosis and intervention system that is currently one of, if not the, most successful in the developed world.

There are multiple reasons why ensuring that Australian Hearing (or another designated and obligated hearing services provider) should be maintained to ensure

the continuation of Australia’s world-leading paediatric hearing services. Those reasons include the need to provide:

Unbiased, independent service provision and advice: Currently, Australian Hearing is an unbiased and independent organisation without a profit motive.

Parents know the least about hearing loss when their child is first diagnosed. Australian Hearing (or other designated and quality assured national provider) can continue to provide a buffer between parents and providers (particularly service providers who are also commercial purveyors of hearing aids and equipment) where parents feel they can receive independent information regarding early intervention and communication options and the fitting of devices without the associated need for “shopping around” and being exposed to the sales and marketing processes that are commonly associated with the “for-profit” audiological services and hearing aid industries.

The period of time from identification of hearing loss to device fitting and engagement with early intervention services is far too vulnerable a time in the life of children and families for them to be exposed to product marketing.

To date, Australian Hearing as a funded and obligated provider has protected parents from having to make important decisions regarding their children’s hearing health at a vulnerable time in a commercialised and highly competitive market.

Technical competency and consistency in paediatric services: Paediatric audiology and the provision of other hearing health services to paediatric clients require highly specialised skills. As an exclusive provider to newly diagnosed children, Australian Hearing (or potentially another obligated national provider) will continue to have the scale of paediatric cases and the depth of specialist experience to ensure the ongoing training and expertise of staff. In a country the size of Australia, staff capability in such a low incidence area like paediatric hearing services can only be guaranteed by the economies of scale associated with a national approach to such service provision. In a contested market, it is extremely unlikely that multiple providers will all be able to develop the necessary expertise or deliver the necessary level of professional capability in all geographic locations across the entire country.
Prioritised entry to services: Currently Australian Hearing’s obligation to provide services ensures the minimisation of the time between identification, diagnosis, detailed audiological assessment, and engagement with intervention services for newborns with hearing loss and their families. This is because Australian Hearing is obligated under the Hearing Services program to provide a prioritised service for such children to ensure that there is no delay in services and to ensure that all such children receive regular and frequent follow ups.
Data management and research capability: As a dedicated and sole provider of hearing services to early-identified children, Australian Hearing, through the National Acoustic Laboratories, is able to collect and manage data that enables world-leading research which is aimed at improvements in service and outcomes. In a contestable market, a national database to track children’s outcomes will still

be needed but will require a separate Government-sponsored initiative that will incur additional establishment, maintenance and operational costs.

In contrast to these observable benefits of the continuation of Australian Hearing (or other such provider) as a national obligated provider under the NDIS, the effect of competition in paediatric hearing services has the potential to erode our current national capability and drive negative outcomes for children in the post-UNHS stages of the early identification and intervention pathway.

These are not purely theoretical concerns. In 2012 the UK Government opened the hearing services market up under an “any qualified provider” scheme (i.e., contestable service delivery of the type envisaged for hearing services under the NDIS). Boots Pharmaceuticals and Specsavers quickly dominated the device and service delivery markets, in many cases undercutting the incumbent National Health system’s services.

More than four years on, there are good examples of how the competitive market has led to market failure. North Staffordshire Health (an NHS service), for example, stopped providing hearing services for many clients who were previously eligible for government funded services. Subsequently, Boots announced their withdrawal from the “any qualified provider” scheme altogether for commercial reasons, leaving a gap in the service delivery system. Nevertheless, Boots continue to serve the more commercially attractive retail audiology market across more than 485 locations nationally. Overall, the standard of services that existed under the National Health Scheme has, according to many colleagues in the early intervention field, been lost.

Similar effects should be expected here in Australia if there is a transition to a commercially determined and contestable market for hearing services—particularly paediatric hearing services. A totally free-market approach to paediatric hearing services may, according to the worst held fears of the ANHSC, lead to service availability being diminished and failure of the system to provide the much needed and currently much lauded levels of paediatric service delivery nationally. The economics of a contestable NDIS will, we believe, lead to inadequate provision of services by private operators, and the lack of the current safety net that exists in the form of a nationally obligated provider operating across all geographic areas. Replacing the current CSO components of the Hearing Services program with a totally contestable free-market approach will lead to services failure.

It is logical and predictable that, under a contestable services system, many geographical areas, and hence many newly diagnosed children with hearing loss, will be under-served because of the relative economics (i.e., lack of economy) of providing the critically necessary services in those locations. For many commercially-oriented hearing service providers that will come into the market for the first time in Australia, adult services and higher volume services for older children will present the largest and most attractive segments of the hearing services market. Pursuing low revenue, high complexity cases of the type that present in the post-newborn hearing screening sector is not likely to be an attractive or economic prospect for many private operators. Even if NDIS packages are more generous than the funding that is currently available under the CSO component of the current Hearing Services Program, the small size of

this market will make the profitability of investing in highly skilled and highly available services right across the country very unlikely.

The ANHSC is aware that there are provisions under the NDIS Act to monitor the market and intervene where there is market or system failure. In the case of paediatric hearing services, however, there is clearly already a system for delivery of publicly funded services in place and working effectively. It would appear to be highly faulty logic to replace a working system with a new system that is likely to be less cost effective and less effective in terms of population coverage and efficacy, and then to wait for that system to fail before predictably needing to intervene to support the market. To be clear, the current system for the delivery of publicly funded early identification and intervention services in regard to infant hearing loss is effective, efficient, highly successful, and the envy of the world in regard to the provision for children with hearing loss.

3.3.1. Recommendation

The ANHSC recommends that Joint Standing Committee on the National Disability Insurance Scheme conclude that:

Due to the complexity of the delivery of paediatric hearing services, such services should only be funded by the NDIS when they are provided by audiologists with training and appropriate expertise in working with infants and young children with complex hearing rehabilitation needs.
When the CSO component of the Hearing Services Program has transitioned to the NDIS, the Agency should designate and obligate a single national provider of hearing services for children under a national contract. We propose that Australian Hearing should continue in that role as the obligated national provider, subject to appropriate standards to safeguard the quality of service delivery. However, if Australian Hearing does not retain that role, then any other organisation so contracted should similarly be obligated (and funded) to ensure the delivery of (a) universally available hearing services across a geographic network equivalent to no less than that currently provided by Australian Hearing under their current Community Service Obligations, (b) professional capability in paediatric hearing services that is sustained at the highest possible level by the economies of scale in professional training that is afforded by their status as a national provider, and (c) hearing device provision and fitting services that preserve Australian Hearing’s current economies of scale in device purchase and distribution but ensure that families of newly diagnosed children are not exposed to the pressures of direct marketing of hearing devices in the vulnerable post-diagnostic period.

3.4 The need for national data collection and management

In addition to the issue of ensuring hearing services as part of the national neonatal screening pathway, there is an additional issue associated with the transition of the Hearing Services Program to the NDIS. That issue concerns the maintenance of Australia’s world-leading edge in regard to capturing and managing data on childhood hearing loss.

It is worth noting here that the JCIH (2007) have argued that “…information systems should be designed to interface with electronic health records and should be used to measure outcomes and report the effectiveness of (early identification and intervention) services at the community, state, and federal levels.”

Combining data from UNHS programs with data already available from Australian Hearing (and potentially other data sets) would offer the potential for Australia to be the world’s leading source of demographic data on deafness in paediatric populations (quite apart from offering the opportunity to monitor outcomes of government investment in UNHS, and other Hearing Services programs including those delivered under the NDIS). There is a patent need for attention to the issues of data management and information sharing in the Australian context in regard to paediatric with the hearing services.

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.

There is a pressing need to ensure that the current capability for data capture and analysis that is made possible by the existence of Australian Hearing a single obligated paediatric hearing services provider is not diminished under any transition of 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 Australia maintains its world leading positon 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 paediatric 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.

To this end, the ANHSC urges the Inquiry 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:

3.4.1 Recommendation

The ANHSC urges the Inquiry to conclude that there should be a National Centre for Hearing Loss Demography and Outcomes Research developed 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:

Conclusion There is a very clear imperative to ensure that the achievements of Governments at both State and Federal levels in early identification and intervention in infant hearing loss Australia are sustained and improved upon in the context of any movement of hearing services into the NDIS. Without appropriate caution, the ANHSC believes that there is every chance that the standard service provision for children with hearing loss in Australia will diminish for the first time in a 70-year period of uninterrupted service improvement. It behoves everyone that is associated with this field to work to ensure

that the integrity of all aspects of Australia’s excellent hearing screening, diagnosis, and intervention systems are maintained and improved.

The ANHSC would be pleased to provide additional information and evidence to the Inquiry around the content and recommendations in this submission (or any other related issue) and would very much welcome the opportunity to address these issues in more detail through personal presentation to the Inquiry.

References Australian Institute of Health and Welfare (2013). National Performance Indicators to

Support Neonatal Hearing Screening in Australia. Canberra: Author. (Available

for download from: http://www.aihw.gov.au/publication-detail/?id=60129545439)

Ching, T. Y. C. (June, 2014). Longitudinal outcomes of children with hearing impairment (LOCHI): 5-year outcomes. Paper presented at HEAL 2014 HEaring Across the Lifespan Conference, Cernobbio, Italy.

Ching, T Y. C., Leigh, G., & Dillon, H. (2013). Introduction to the Longitudinal Outcomes of Children with Hearing Impairment (LOCHI) study: Background, design, sample characteristics. International Journal of Audiology, 52 (Supplement 2), S4-S9.

Community Care and Population Health Principal Committee (Standing Committee on

Screening) (2016). Population based screening framework. Canberra: Author. Department of Health (2013). National Framework for Neonatal Hearing Screening. Canberra: Author. (Available for download from: http://www.health.gov.au/internet/main/publishing.nsf/Content/neonatal-hearing screening)

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C. Driscoll, & B. McPherson (Eds.), Newborn Screening Systems: The Complete Perspective (pp. 95-115). San Diego: Plural Publishing, Inc. New South Wales Health Department. (2006). Ministerial standing committee on hearing annual report 2004–2005. (Available for download from: http://www.health.nsw.gov.au/hearing/pdf/annual_report.pdf)