Chapter 3
Australian Hearing and NDIS
Introduction
3.1
The introduction of the NDIS in 2013 included a decision by the
government to transition existing Commonwealth programs providing support for
people with disability to the NDIS. One of these programs is the Hearing
Services Program, which is scheduled to be transitioned to the NDIS nationally
by 2019-20.[1]
3.2
As noted in Chapter 2, the Hearing Services Program has two components:
the CSO program and the Voucher program. According to the Hearing Services
Program FAQ website, both the CSO program and the Voucher program will be
transitioned to the NDIS.[2]
3.3
The information on the Hearing Services Program FAQ website was
originally published on 7 May 2015, and updated on 17 June 2015.[3]
As noted in Chapter 2, Mr Renwick, Acting First Assistant Secretary in the
Department of Finance, told the committee that the scoping study had in part
revealed that 'there were a number of issues that still needed to
be resolved under the NDIS...'[4]
3.4
Witnesses at the committee's 10 July 2015 hearing raised a number of
unresolved issues around the transition of the Hearing Services Program to the
NDIS. In particular, witnesses informed the committee that there was confusion
around the effectiveness of privatising Australian Hearing and transitioning
the Hearing Services Program into the NDIS. This chapter examines the issues
raised by witnesses and submitters in relation to the transition of the Hearing
Services Program to the NDIS, in the context of the proposed privatisation of
Australian Hearing.
Transition of Hearing Services Program to the NDIS
3.5
Many witnesses supported the NDIS, and had only limited concerns
regarding the transition of the Voucher Program to the NDIS. The fact that
Australian Hearing competes with other providers to service clients in the
Voucher Program means that a transition to the NDIS may be relatively
straightforward as the NDIS is also structured as a competitive service area.
3.6
The chief cause of concern for witnesses and submitters was the
transition of the CSO Program to the NDIS, because clients would move from a
sole provider situation to a competitive market. The Department of Finance explained
that the scoping study found that stakeholders were confused about the Australian
Hearing transition to the NDIS.[5]
However, Mrs Ann Porter, CEO of Aussie Deaf Kids, explained:
I guess the pathways and really the interface with the NDIS:
how Hearing Services would interface with the NDIS, which we have found
difficult to conceptualise. The Office of Hearing Services seems to feel that
parents do not understand the NDIS. We do actually understand the NDIS, but we
do not understand how the NDIS and the Hearing Services Program will actually
interface and how that will work.[6]
3.7
Issues identified by witnesses relating to the proposed transition of
the CSO Program to the NDIS included:
-
difficulties for parents of newborns and young children in
accessing assistance under the NDIS;
-
vulnerable groups covered by the CSO Program would face difficult
decisions over which providers to access;
-
given the importance of early, quality, intervention for young
children with hearing impairment, witnesses had concerns over the ability of
the market to deliver consistent standards of care; and
-
concerns about how the privatisation of Australian Hearing would affect
CSO Program clients, on top of transition to the NDIS.
Accessing assistance
3.8
A number of witnesses told the committee of their experiences trying to
access assistance for their hearing impaired children. Mrs Porter of Aussie
Deaf Kids explained that:
It is just such an incredibly stressful and difficult time
when your baby is diagnosed with a hearing loss. I have a deaf daughter. She is
now 26. She first of all had a unilateral hearing loss, but then she lost her
hearing overnight in her other ear. So I went from having a hearing child to a
deaf child overnight, which is basically what happens with newborn hearing
screening, where parents feel they have a hearing child and the next day they
find that their baby is [deaf]. It just leaves you rudderless, I have to say.
It is an incredibly challenging experience.
I am an occupational therapist. I worked within developmental
clinics and in the assessment and follow-up of NICU [Neonatal Intensive Care
Unit] babies at Westmead Children's Hospital. I could speak English. We had
just incredible troubles navigating the system because she came at a time when,
really, there were no pathways. We anticipate the same thing happening [under
the NDIS].[7]
3.9
Mrs Porter told the committee that the present situation, with
Australian Hearing as sole provider of the CSO Program, provided a clear
pathway for families in urgent need of assistance:
We have seen some of the issues in the NDIS—with the
introduction of the NDIS and the issues that families have around choosing
early intervention services and before the NDIS with Better Start. If we then
add in trying to navigate finding the right hearing services, we really do
think we are going to lose a lot of people. We have a less than two per cent
loss to follow-up after newborn hearing screening because we have this pathway
that is so clear. In the [United] States, I think it is nearly 50 per cent loss
to follow-up. We can see it particularly in families from migrant backgrounds.
As parents of deaf children, we do not really have much contact with Aboriginal
and Torres Strait Islander families, but we do have a lot of contact with
migrant families and the challenges that they face. So we are really fearful of
the loss to follow-up with those families if we do not have very clear pathways
and good information for those families.[8]
3.10
In its submission, the Deafness Forum of Australia compared the referral
pathway under the NDIS to that currently used under the Australian Hearing CSO
Program. The forum noted that the Australian Hearing pathway is more
streamlined:
The pathway for accessing support under the NDIS is to
confirm eligibility, develop a plan with an NDIS planner, choose supports,
implement the plan and review the plan. The pathway for accessing hearing
services under the CSO Program is more streamlined and therefore clients are
able to access the support they need without delay. Currently Australian
Hearing has arrangements in place to ensure that infants diagnosed with hearing
loss through newborn hearing screening programs and older children diagnosed
with hearing loss are seen urgently so they are provided with amplification and
other support as quickly as possible. The eligibility checking is immediate and
the planning is done with the service provider, i.e. Australian Hearing, so
there is no delay between diagnosis and treatment. The arrangement where there
is only one Provider nominated to deliver services to infants and children
minimises the risk of them being lost to follow up.[9]
3.11
In contrast to the issues raised by witnesses, the information publicly
available from the Office of Hearing Services (within the Department of Health)
in the FAQ on the transition to NDIS states:
The early months for newborns diagnosed with hearing loss can
be critical for the whole family and it is recognised that the existing
referral pathways work well in ensuring that there is a minimal delay between
the time of diagnosis and the delivery of hearing services.
It is important that the NDIS does not act as a barrier to
this pathway and the NDIA will be consulting with stakeholders on how this can
best be achieved...[10]
3.12
Ms Gina Mavrias, the Operations Director of Australian Hearing
summarised the issues faced by parents of hearing impaired children, and underlined
the importance of simple pathways to access hearing services:
It is a very difficult period for the families. One of the
challenges will be: 'Where do I go and who will have the skills to help my
child?' At the moment, they come to Australian Hearing and they know that the
person they see has the skills to provide the services. Whatever service
arrangement is around that needs to consider how parents quickly access
services. Speed is really important in this time—we know speed is important for
that child getting the best possible outcome. They need to know where to go and
how to get in quickly, and there are also the challenges around what the best
solution is for their child. Again, there is the need to walk them through the
options—whether it is a hearing aid or a cochlear implant or something else—and
knowing that they can make those decisions and that it is not a cost decision;
it truly is a question of: 'What is the best outcome for my child?'[11]
Committee view
3.13
The committee believes that the evidence clearly demonstrates that an
essential part of the CSO Program is ease of access to services. Having a
single pathway provides certainty, particularly for parents of children who
have just been diagnosed with hearing impairment. The committee considers that
a clear referral pathway to services should be maintained in the transition of
the CSO Program into the NDIS.
Vulnerable groups
3.14
Deafness Forum of Australia noted that the CSO Program covers a number
of other vulnerable groups in addition to providing services for children with
hearing impairment. As described in Chapter 2, these groups include Aboriginal
and Torres Strait Islander peoples aged over 50 years and under 65 years and
those participating in the Remote Jobs and Communities Program, and adults with
complex hearing rehabilitation needs aged under 65 years.[12]
3.15
For these CSO clients, currently there is a simple pathway to access
assistance. Deafness Forum of Australia described this situation:
Currently, if people qualify for the NDIS at the pilot sites
and require hearing assistance, they are streamed to Hearing Services Providers
through the Australian Government Hearing Services Program. If they meet the
eligibility criteria for the CSO Program they are seen by Australian Hearing.
Otherwise they have a choice of Providers under the Voucher Program. This
ensures that the more complex clients are seen by Audiologists with the
required expertise and receive the program of services and devices that are
appropriate for their needs.[13]
3.16
With the transition to the NDIS and the introduction of contestability,
Deafness Forum of Australia argued that clients in the CSO Program will be
required to make decisions about service providers. Deafness Forum of Australia
questioned whether there has been any assessment of the market for providing
contestable services to CSO Program clients. Further, Deafness Forum of
Australia, Deaf Australia, and Independent Audiologists Australia all told the
committee that audiology was an unregulated profession in Australia, with difficulties
around policing standards. For example Ms Leonie Jackson, Chief Executive
Officer, the Deaf Society of NSW told the committee of her own experiences with
private audiologists:
I personally have experienced going to a private audiology
service, where I have been ripped off. They have tried to sell me a $10,000
hearing aid that I did not need. They tried to charge me $250 for the moulds,
and I know it only costs $60 at the most. So I have been very wary of private
audiologists because of the experience that I have had previously myself.[14]
3.17
It is arguable whether consumers believe contestability and increased
choice really is a benefit. The Deafness Forum of Australia submitted that it
had tested through consultation the argument that contestability was a main
benefit of moving the CSO Program to the NDIS. The results of these
consultation were:
...while parents understand the potential benefit of having a
choice of provider, they believe it is far more important to preserve the
existing benefits available through having the Government Provider as the sole
provider of services to children and their families. Issues relating to
expertise, unbiased information and advice, and trust were more valued by
families than having a choice of provider. Families believe this will ensure
the best outcome for their child. There is also concern that families who are
very vulnerable at the time their child is diagnosed with hearing loss and know
very little about hearing impairment are not in a position to make an informed
choice about different providers. The current arrangements provide a safety net
for children and their families to ensure that the child’s outcomes are not
compromised.
The Deafness Forum consultation highlighted that families do
not support contestability in the delivery of services to Deaf and hearing
impaired children.[15]
Committee view
3.18
The evidence heard by the committee appears to indicate that the more
choice or contestability in the market, the more difficult the decisions which
need to be made by the individual seeking help. For vulnerable groups, this may
result in being overwhelmed by the options available. The situation may also
leave vulnerable groups open to exploitation if there are not adequate
safeguards in place.
Consistent standards of care
3.19
A major concern of witnesses, relating to both the transition of the
Hearing Services Program to the NDIS and the proposed privatisation of
Australian Hearing, was maintaining consistent standards of care.
3.20
Mrs Porter of Aussie Deaf Kids told the committee that Australia is a
world‑leader in standards of care for children with hearing impairment,
in large part thanks to the work of Australian Hearing. However, although
Australian Hearing has world-leading expertise, Mrs Porter argued that there is
little evidence of the market having providers of services for children with
the same standard of service:
Parents have been enthusiastic supporters of the NDIS, as we
can see the opportunities the scheme will provide for our children throughout
their lives. However, the contestability of the Hearing Services Program is not
one we support. It is a model that is untested for this group of clients in
Australia. The UK has made adult hearing services contestable but has refrained
from doing so for children's services. As parents, we are all too aware of the
issues and burdens faced by parents in the US, where the process is
contestable. This is not one that we want to see replicated here.
There is no evidence that there are providers with the
skills, equipment, facilities and coverage to effectively deliver the hearing
services required by children and their families. It is our contention that
contestable hearing services have the potential to compromise the principles of
good practice and put at risk the future of deaf and hard-of-hearing children
and their families. We have identified numerous areas of concern that must be
addressed to ensure that the system we transition to complies with the
principles of best practice and continues to provide the services and support
that the child and family need to optimise their potential.[16]
3.21
Deafness Forum of Australia also argued that 'the private market does
not currently provide services to Deaf and hearing impaired children.'[17]
Even if the private sector was to begin to provide services for children, and
for other vulnerable groups of CSO Program clients, Deafness Forum of Australia
asked what safeguards exist to ensure the quality of the service and the access
of the service in rural and remote areas.[18]
3.22
Deafness Forum of Australia also observed that the quality of the
service has a significant impact on the outcomes for the person seeking help:
Research indicates the expertise of the service provider has
a significant impact on client outcomes. Consumers need certainty that they are
accessing services from a clinician with the appropriate skills. If new service
delivery arrangements are introduced, consideration needs to be given to the
mechanism that would be used for clinicians to attain the competencies needed
to deliver services to CSO clients in the future, and for consumers to be able
to recognise that practitioners have the skill level required to provide these
services.[19]
3.23
Deafness Forum of Australia argued that before the CSO Program moves to
the NDIS, safeguards need to be in place to protect CSO clients and to ensure
adequate service delivery. The safeguards recommended by Deafness Forum of
Australia state that services:
-
Are available in urban, rural and remote areas of Australia
-
Are within a reasonable travel distance for clients
-
Are delivered by professionals with an appropriate level of
expertise
-
Are delivered fairly and equitably
-
Are delivered in a culturally sensitive way
-
Are focussed on the best interests of the client and their family
-
Are delivered consistently across service locations
-
Are delivered according to international best practice
recommendations
-
Are available for all clients regardless of their age, level of
disability, socio economic background or requirements for interpreter and
translation services[20]
3.24
In relation to services for children, the Deafness Forum of Australian
suggested the following additional safeguards:
-
The program allows for a family centred response, giving families
time, information and support to allow them to make an informed decision for their
baby or child
-
The child receives an individually tailored program to meet the
needs of the child and the family
-
The child receives the services and devices they needed to
achieve the best outcome
-
There are strong relationships between audiological services,
educational services and other support services including referrers
-
The service is provided by highly skilled clinicians
-
The clinical programs are research based and supported by
clinical protocols
-
The programs are provided with the focus on the best outcome for
the child rather than a sales focus
-
Services are equitable and not based on the family’s ability to
pay
-
Information and guidance is impartial and unbiased
-
Services are well located to minimise the need for travel[21]
Consultation on NDIS transition
3.25
As discussed in Chapter 2, the paucity of information provided by the
department has led to stakeholder groups being confused and uncertain about the
transition of Australian Hearing to the NDIS.[22]
As a result of the government's announcement to defer its decision on the
scoping study, the Department of Health and the Department of Finance undertook
further consultations with the hearing community about the transition to NDIS.
3.26
The consultations, called 'NDIS Transition Information Sessions', were
conducted in Canberra, Sydney, and Melbourne in June 2015.[23]
The information sessions were run by the Office of Hearing Services (Department
of Health) and included information from the Department of Finance regarding
the findings of the scoping study into the privatisation of Australian Hearing.[24]
3.27
The Office of Hearing Services is has also conducted 'NDIS Transition Planning
Workshops' in August (10–18 August 2015), as well as at unspecified dates in
September 2015.[25]
The workshops are described as being held to 'help identify and discuss the key
activities and steps to support a successful transition to the NDIS, including
options for implementation'.[26]
3.28
Interestingly, representatives from Australia Hearing were not part of
the NDIS Transition Information Sessions, as Ms Mavrias indicated to the
committee.[27]
3.29
Witnesses expressed confusion over the purposes of the information
sessions and the planning workshops. There was also confusion about how these
activities relate to the transition of the Hearing Services Program to the NDIS
and the outcomes of the scoping study. For example, Ms Margaret Dewberry,
Deafness Forum of Australia, told the committee:
We would like to see what the blueprint is [for transition of
the Hearing Services Program to the NDIS]. I thought the Office of Hearing
Services had made an offer for people to attend a transition planning workshop,
which I had interpreted to mean that we would be part of developing that
blueprint. But it seems that the blueprint is there. So I do not [know] whether
that is just a consultation process now or quite what it represents. So yes,
there is this feeling of always playing catch-up on what is happening.[28]
3.30
Mr Mark Wyburn of the PODC told the committee that his organisation were
similarly confused about the process:
...the overall umbrella framework we do not know. Someone
talked about a blueprint. We do not know where this is all fitting in.
Consultation has been changed on the run. There was a framework request for
comment on service delivery. That was then service delivery for voucher
service. That now encompasses audiology, and now we have been asked to provide
paediatric input into that from a parent. So, it has gone from voucher system
delivery to CSO...[29]
3.31
Mrs Porter of Aussie Deaf Kids also submitted that many groups were not
informed of the effect of the NDIS transition, let alone the impact of the
privatisation of Australian Hearing:
I guess we knew that with the NDIS clearly there was always
going to be the issue of possible contestability if hearing services went under
the NDIS. But we were not really aware that the hearing services were going
under the NDIS. We did see that there was a COAG agreement a number of years
ago that we were not really aware of. As parents we were not aware that that
had occurred. We were under the impression that the NDIS and hearing services
would remain separate. But the sale of Australian Hearing was where the alarm
bells first started to ring for us. We have really been told only in the last
few weeks that hearing services will go under the NDIS. We are just trying to
catch up all the time.[30]
3.32
Ms Catherine Rule, First Assistant Secretary of the Medical Benefits
Division in the Department of Health, told the committee that she was 'not
aware of a formal document that exists that is called a blueprint'.[31]
Ms Rule stated that the purpose of the information sessions was:
...talking to the stakeholders about not just the scoping
study—that was probably actually the smaller part of the discussion—but the
transition to the NDIS and trying to flesh out the issues and the things we
need to think about and the processes and the policy issues. It may have been
mentioned in that context, but I am not aware of the existence of a document
called a 'blueprint'. [32]
3.33
Ms Tracey Duffy, the National Manager of the Office of Hearing Services
in the Department of Health expanded on the point made by Ms Rule. Ms Duffy
told the committee that while the term 'blueprint' may have been used at the
information sessions, nothing had been developed:
CHAIR: Okay. Is there anything that could be conceived
to be anything like a blueprint, or a finger painting perhaps?
Ms Duffy: What was explained was that, over the coming
months, we are required to develop up a transition plan. I would have used the
language 'a blueprint', which sets out the types of activities and the timing
for things going between now and when we do full national rollout or
transition. I have used that term 'blueprint', but it is a way of describing a
transition plan of being able to segment and give people an idea of critical
points in time for things to occur.
CHAIR: Is that transition plan under development or
developed?
Ms Duffy: It is not developed. We are just starting to
gather the information, and the information sessions were a starting point. We have
also received a number of submissions that identified the important areas that
we need to consider as part of the transition, which were all raised earlier
today as well as being raised in the scoping study that will form a transition
plan. So it is in the early stages.[33]
Privatisation and transition to
NDIS
3.34
Other concerns regarding the privatisation of Australian Hearing and the
transition of the Hearing Services Program to the NDIS included the possible
gap in timing resulting from both processes. Mr Kyle Miers, Chief Executive
Officer of Deaf Australia told the committee that if Australian Hearing were to
be privatised in the short term—that is in 2016—there would be a gap from that
date to the full roll out of NDIS:
Just looking at the time line, from the establishment of the
NDIS to the actual full rollout, we have a three-year gap from the sale. From
the end of this financial year, 2015, to the full rollout of the NDIS, which
will not be happening until 2018, there will be a three- or four-year gap. What
will be happening in the interim? If the sale is made, then what happens?
People are in a bit of a twilight zone, so to speak. Those people will be
impacted, because they will not have access to services if Australian Hearing
Services is sold or privatised and the NDIS has not been fully rolled out,
where do people go? They are in limbo. That will affect people nationally. They
are left in limbo until about 2018, so what are people to do? They are left
without services in that time frame, so who will be supporting them? There will
be no support. There will be nothing. It will make the situation far worse, and
it is not allowing for a proper transition.[34]
3.35
Information from the Department of Finance about what might happen
should Australian Hearing be privatised with a gap of three to four years notes:
The Office of Hearing Services in the Department of Health is
responsible for hearing services policy and managing the funding for the
Hearing Services Program, including the CSOs. The consideration of future
ownership options for Australian Hearing will not impact on the eligibility
for, or the funding of, the Hearing Services Program. People with a hearing
loss who currently receive (or are eligible to receive) CSO services will
continue to receive those services, either as NDIS participants or clients of
the Hearing Services Program.[35]
3.36
Mr Stephen Williamson, the CEO of the Deafness Forum of Australia raised
an issue related to privatisation—what would happen if Australian Hearing's
private sector ownership changed its priorities for service delivery:
The introduction of contestability introduces significant
risks in terms of access, expertise, quality and standards. Additionally, as
you know, the government is still to make a decision regarding the sale of Australian
Hearing. If the sale proceeds and the new owner decides to withdraw from
providing services to these more costly and challenging client groups then the
safety net of the government provider will be lost. Deafness Forum of Australia
has developed a paper outlining the issues that need to be addressed in the
transition plan and has made it available to the committee.[36]
Committee view
3.37
Australian Hearing has provided services to deaf and hearing impaired
Australians since 1947. In conjunction with its research arm, the NAL,
Australian Hearing is a world-leading source of 'expertise, unbiased information
and advice, and trust' for clients of
the CSO Program.[37]
For its submission to the PWC scoping study, Deafness Forum of Australia
consulted with its members, other stakeholders, and interested parties across
Australia. The main finding was that clients of the CSO Program, particularly
families supporting hearing impaired children, valued Australian Hearing as a
sole provider for the security it provided:
While consumer choice is often seen as an important issue,
parents of hearing impaired children did not raise this as a concern with
current arrangements. Many families indicated their relief at knowing there was
a single organisation that was highly regarded for its expertise in working
with children and their families and provided unbiased information and advice,
so they were not required to undertake research into finding an appropriate
Provider particularly at the time of diagnosis when the parents are feeling
high levels of anxiety and stress. Families felt a high degree of trust in
receiving services and advice from an agency that was not making a profit from
these services.
Issues relating to expertise, unbiased information and
advice, and trust were more valued by families than having a choice of
provider.[38]
3.38
If the Hearing Services Program, including the CSO Program serviced by
Australian Hearing, is to transition to the NDIS, then a core element which
must be maintained is access to 'expertise, unbiased information and advice,
and trust' for vulnerable clients.[39]
3.39
The committee believes that there has been a lack of structured
consultation around the transition of the Hearing Services Program to the NDIS.
This situation is of significant concern given that the CSO Program provides
services to vulnerable clients, and to newborns and young children whose future
lives depend on accessing quality assistance in a timely manner.
3.40
The evidence heard by the committee shows that clarity is desperately
needed around the arrangements to transition the Hearing Services Program to
the NDIS. Further, there needs to be transparency around the development of any
'blueprint' or arrangements for the transition to ensure that the concerns of
all stakeholders have been considered and adequately addressed.
3.41
The transition of the Hearing Services Program to the NDIS is also being
unnecessarily complicated by the uncertainty around the future of Australian
Hearing. A government decision about the privatisation of Australian Hearing
has been deferred. This is despite the overwhelming evidence that selling
Australian Hearing would cause significant negative impacts to its clients, who
are often amongst the vulnerable Australians. By delaying its decision on
privatisation, the government has effectively forced the Departments of Health
and Human Services to consult on the Hearing Services Program's transition to
the NDIS under two scenarios: a privatised Australian Hearing and a status quo
Australian Hearing. The committee considers that it is little wonder
stakeholders have complained of confusion and uncertainty.
3.42
If the Hearing Services Program is to successfully transition to the
NDIS in a way which ensures all stakeholder groups are considered, the
government needs to immediately guarantee the retention of Australian Hearing
in government hands.
Recommendation 2
3.43
The committee recommends that the government provide clarity around the
work already done on the transition of the Hearing Services Program to the National
Disability Insurance Scheme. Any 'blueprint' or implementation plan should be
made public as soon as it is finalised, so as to reassure stakeholders that the
quality services provided by Australian Hearing continue to be available in
order to ensure that hearing impaired Australians can live the life they
deserve.
Senator Deborah O'Neill
Chair
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