Australasian Newborn Hearing Screening
Committee
A subcommittee of Deafness Forum of Australia
13th June, 2017
To: Copy to:
The Hon. Kevin Andrews, MP Committee Secretariat
Chair Joint Standing Committee on the
Joint Standing Committee on the National Disability Insurance Scheme
National Disability Insurance Scheme PO Box 6100
PO Box 6100 Parliament House
Parliament House Canberra ACT 2600
Canberra ACT 2600
Dear Mr Andrews,
Re.: Information additional to the submission and personal evidence provided to the Inquiry provision of hearing services under the National Disability Insurance Scheme
In February, the Australasian Newborn Hearing Screening Committee (hereafter the
ANHSC) made a written submission to the above Inquiry. We are aware that the Inquiry is in its final stages of deliberations. Nevertheless, the Committee seeks to ensure that, in light of the announcement in the Federal Budget that “the Government has decided to retain full ownership and control” of Australian Hearing, we inform the Inquiry of our ongoing concerns and offer some further information for consideration.
The ANHSC notes that, 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). The ANHSC contends that the role of Australian Hearing as a comprehensive national provider is a critical component in the integrity of the National Framework.
The ANHSC further contends that there is a critical need to ensure that there is an obligated provider of paediatric hearing services (whether that be under the auspices of the current Hearing Services program or under the auspices of the NDIS) to ensure that there remains the capacity for high quality, highly accessible, and locally delivered
Chair: Greg Leigh (greg.leigh@ridbc.org.au)
Secretary: Zeffie Poulakis (zeffie.poulakis@rch.org.au)
Correspondence: c/- Private Bag 29, Parramatta, NSW, 2124
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assessment and referral services for all children with hearing loss, regardless of where they may live or present for audiological management beyond UNHS diagnosis.
In our original submission, the ANHSC sought to ensure that the Inquiry was aware of the manifold ramifications for the country’s various universal newborn hearing screening (UNHS) programs of any plans to create a fully contestable market for government funded paediatric hearing services (i.e., as part of the transition of the Hearing Services Program to the NDIS and/or of the potential privatisation of Australian Hearing). Given that the Government has announced that it intends to retain control of Australian Hearing, the ANHSC is now keen to ensure that the Inquiry understands that the decision to retain Australian Hearing in government control raises significant questions in regard to the nature of the future of paediatric hearing services in Australia.
Among others, these open questions include:
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How will Australian Hearing operate as a government-owned and controlled entity in the context of an openly contested market for paediatric hearing services?
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What will the existence of a multiplicity of paediatric hearing service providers mean for the quality and availability of services on regional and remote areas if there is no obligation placed on provider/s to serve all children in all locations?
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Given that Australia currently has arguably the best set of data on paediatric hearing loss anywhere in the world, where will responsibility for data collection and management relating to infant hearing loss rest in a fully contestable service environment? If not with Australian Hearing then where? What will compel other competing providers to contribute information to such a data set, and which agency will have responsibility for the collection, management, analysis, and interpretation of that data in the manner that is currently carried out by Australian Hearing?
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If not constrained by the requirements of sole provision under the Hearing Services program, will the service delivery profile of Australian Hearing change and how?
In this brief additional submission, we seek to address some grave concerns around each of these important questions regarding the future of hearing services following that decision.
Re. Question 1:
The ANHSC submits that it is entirely inappropriate for the Government to retain control of Australian Hearing and contest for government funding to deliver services in competition with other providers in either the commercial or not-for-profit sectors. It is the recommendation of the ANHSC that Australian Hearing should remain as the dedicated (i.e., obligated and exclusive) provider of hearing services for children and young people in Australia. This could be effected by having Australian Hearing (a) continue to be the exclusive and obligated provider of services under the existing Children’ Hearing Services program (thereby excising hearing services from the NDIS, or (b) become the exclusive (sole) obligated provider of children’s hearing services under the NDIS.
Re. Question 2:
It is critical that Australian Hearing’s capability in the early assessment of hearing loss, early fitting of devices, and role in onward referral to other intervention services are all maintained into the future. It is imperative that time spent by children and families in receiving these services and moving to the next stage in the hearing screening and
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intervention pathway is minimised by the ready availability and accessibility of such services. Currently, children who are identified through the newborn hearing screening pathway are seen by Australian Hearing within two weeks of that diagnosis occurring. This timeliness is a critical component of ensuring children’s’ engagement with hearing technologies and, importantly, with early intervention 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 Community Service Obligations of Australian Hearing (i.e., as a sole national provider of services to children) are to be replaced by a range of contestable services under the NDIS, the ANHSC argues that there are very considerable risks on several fronts. Not least among these risks are (a) the potential for unacceptable delays in regard to the time taken to get access to hearing services (i.e., because of the processes associated with planning and contestability under the NDIS), and (b) the potential for commercial imperatives to introduce variability in the quality and professional capability of such services. Further, we contend 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. 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 “hearing device sales market”.
Re. Question 3: As a dedicated and sole provider of hearing services to children with hearing loss, Australian Hearing is able to collect and manage data that enables both effective public policy development and the conduct of world-leading research. In a contestable market, a national database to track demographics and outcomes will still be needed. However, it is entirely unclear what obligations could be placed on the numerous service providers that may seek to enter the market under a contested system to contribute information to such a data set. It is also unclear which agency would have responsibility for the collection, management, analysis, and interpretation of data in the manner that is currently carried out by Australian Hearing. In the absence of Australian Hearing another government-sponsored initiative will be required, incurring additional establishment, maintenance, and operational costs.
Re. Question 4: It is unclear whether, as a service provider in a contestable market, Australian Hearing may extend its service brief to new areas such as the delivery of early intervention services or other services under the NDIS. Such a move would prevent Australian Hearing from fulfilling a critical role as an independent source of information and guidance for families on the pathway from diagnosis to engagement with early intervention services for children with hearing loss. The ANHSC contends that, were Australian Hearing to remain as the obligated and sole provider of hearing services, it could also serve a critical additional role as an obligated provider of guided referral services (i.e., serving to assist parents of children who have been identified with hearing loss to identify and engage with one of the range of early intervention providers that present under the terms of the NDIS).
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Conclusions/Recommendations:
The ANHSC shares the widely held view that Australia enjoys a position as the world leader in delivery of services for children with hearing loss. From our perspective, however, that position is under severe threat. Relative to our currently high standards, there is the potential for significant regression in the quality and availability of services.
The ANHSC welcomes the decision to retain Australian Hearing in government ownership and control but urges the Inquiry to conclude that the interests of all Australian children with hearing loss and their families will be best met by ensuring that Australian Hearing:
continues to be the sole obligated provider of hearing services to children up to at least the age of 18 years (i.e., either under the existing Hearing Services Program or under the NDIS as a designated service provider); does not then seek to compete within the disability services market as a provider of early intervention or other services beyond its current remit as a provider of hearing services; and is funded under the NDIS or through an extension of the Hearing Services program to be the obligated provider of guided referral services for children who are in transition from diagnosis of their hearing loss to engagement with early intervention services under the terms of the NDIS.
This position was discussed and endorsed by the Australasian Newborn Hearing Screening Committee at its most recent meeting, which was held in the context of the 9th Australasian Newborn Hearing Screening Conference, and we commend it to the Inquiry.
We would be pleased to expand upon these views and to provide such additional information as may be required.
Yours sincerely,