Submission 55 — Cora Barclay Centre Attachment 1 (55.2 Supplementary to submission 55) — The provision of hearing services under the National Disability Insurance Scheme (NDIS)

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Submission to the Joint Standing Committee on the National

Disability Insurance Scheme

Enquiry into the provision of hearing services under the National Disability

Insurance Scheme

Cora Barclay Centre

Submitted by:

Amanda Haskard

Acting CEO, Cora Barclay Centre

185 Melbourne Street

NORTH ADELAIDE SA 5006

Tel: 08 8267 9200 Email: ahaskard@corabarclay.com.au 24th August 2017

About the Cora Barclay Centre

The Cora Barclay Centre has been teaching children to listen and speak for over 70 years and is the oldest oral deafness centre in the southern hemisphere. Our mission is to help guide children who are deaf or hearing impaired and utilise assistive hearing devices to learn to speak and reach their full potential, through intensive early childhood intervention, school years and early adulthood support, psycho-social development and ongoing assessments.

These outcomes are achieved through family-centred practice and professional expertise in

Auditory-Verbal Therapy, Teaching of the Deaf, Child and Family Counselling, Speech

Pathology, Listening and Spoken Language, and Peer Support and Youth

Engagement/Empowerment. The Centre’s services are delivered by South Australia’s most diverse and highly qualified hearing & habilitation team.

This inquiry is welcomed by the Cora Barclay Centre. As things currently stand we are deeply concerned about the impact NDIS policies and funding are having on the exceptional outcomes for hearing-impaired children that are currently being achieved by multi disciplinary, listening and spoken language early intervention providers and their families. The Centre is committed to working collaboratively with all relevant stakeholders in the transition of children’s hearing services to the NDIS to ensure that the outcomes of current and future generations of hearing-impaired children are not diminished under the NDIS.

Submission response

The Cora Barclay Centre has made a number of submissions to the Joint Standing Committee on the National Disability Insurance Scheme. This response should be read alongside the evidence provided in earlier submissions.

The Cora Barclay Centre thanks the committee for the opportunity to submit evidence regarding:

  1. The impact the delay to the introduction of baseline reference packages for early intervention supports has on access and provision of adequate supports and services for deaf and hard of hearing children, their families and carers.

  2. The proposed guidelines for determining access to the NDIS and reasonable and necessary supports for hearing impairment.

The Cora Barclay Centre has been working closely with the National Disability Insurance Agency to have these matters considered further and has been involved in providing models for consideration, trialing approaches and giving feedback on proposals. The Centre welcomes the enquiry however is concerned regarding the time taken to implement.

Delay to baseline reference packages

The Cora Barclay Centre has been a participant in the NDIS since the scheme’s inception in

  1. Over that time, the Cora Barclay Centre has suffered considerable losses due to:
  • Delays with participants getting access to the scheme

  • Insufficient plan funding, with a shortfall of between $4k and $10k per participant per annum depending on the package value

  • Lack of dedicated funding to hearing loss, requiring participants to “share” funding between multiple providers without sufficient funding to cover all requirements

  • Components of the Cora Barclay Centre program (such as Group programs) being denied funding by the NDIS

  • Eligibility issues for children with lower levels of loss being denied access to the scheme

On top of these losses, the Cora Barclay Centre has also suffered from substantially higher administration costs due to the billing and support requirements of the scheme, requiring an additional 3 FTE to support the NDIS.

Since the introduction of the scheme, the Cora Barclay Centre has been 100% committed to ensuring that all participants continue to have access to a full range of services with the belief that no child should be disadvantaged due to having insufficient support through the NDIS. Because of this commitment, the Cora Barclay Centre has borne the financial burden of providing full services despite receiving insufficient funding from the NDIS. Government funding for the Centre has gone from 60% prior to the NDIS to below 40% in the most recent financial year.

The Cora Barclay Centre is currently incurring losses in the order of $40,000 to $50,000 per month. This (calendar) financial year, the full extent of the losses are projected to reach $650,000. In discussions with NDIA, the predicament of the Cora Barclay Centre has been consistently raised. It is understood that the implementation of baseline reference packages will go a substantial way to relieving the pressure the Cora Barclay Centre is under. Under independent audit, the size of the loss of the Cora Barclay Centre from August 2015 to May 2017 directly attributable to the NDIS has been verified at $1.3m.

On top of the financial losses of $40k to $50k per month due to the delay in introduction, the Cora Barclay Centre also suffers increased administration overhead. Of primary concern however is the irreparable damage being inflicted on the parents of children with hearing loss as they navigate a confusing scheme that leaves them substantially underfunded, confused, and in fear for continued service.

It is the position of the Cora Barclay Centre that the release of baseline reference packages must be escalated quickly, and in order to provide a sustainable solution for providers, must also consider:

  • Quarantined funding for hearing loss

  • An appropriate billing mechanism that allows for administratively easy access to the funding

  • A re-evaluation of all active plans to be brought into line with the baseline packages (rather than being brought into line upon review) with a clear and supported explanation to parents of the re-evaluation.

Eligibility criteria

The Cora Barclay Centre welcomes the policy change to provide access for children with a hearing loss at greater than or equal to 25 decibel in either ear, and applauds the NDIA in recommending such a change. However, the Centre would like to make the following observations in relation to the policy:

  1. There is a lack of clarity in the proposed changes to the Operational Guidelines that Section 8.3.3 pertains to adult hearing loss only

  2. The NDIA first discussed this pending policy change with the Cora Barclay Centre in June 2017. The length of time it has taken to implement this change (which is currently still not known) is excessive for such a clear and necessary policy change. In the meantime, many children continue to be affected by ineligibility to the scheme, and providers such as the Cora Barclay Centre continue to bear the brunt of providing services without funding to children in need.