NDIS transition and future of CSO Program

The in-kind arrangements between the Hearing Services Program (HSP) and the National Disability Insurance Scheme (NDIS) are due to cease on 30 June 2020. The hearing health sector has been advised that there is an inter-departmental committee that is planning the transition arrangements and the future of the Community Service Obligation (CSO) Program but as yet the Sector has not been informed or consulted on the proposed new service delivery models. Given the significant impact that the new program arrangements will have on consumers, providers, support groups and researchers, it is concerning and disappointing that the Sector will be given no chance to review or comment on arrangements prior to implementation.

The hearing health sector has provided many discussion papers and submissions and appeared at various Government Inquiries to highlight the major issues that need to be addressed as part of the transition process.  The Sector needs time to review the new arrangements to ensure that the identified issues have been addressed and that the integrity of the services will not be compromised under the new systems.

In particular, the new arrangements need to be tested to ensure that there is no detrimental impact on:

  • Timeliness of service
  • Referral pathways
  • Client pathway
  • Accessibility in terms of location
  • Accessibility in relation to cultural and linguistic diversity
  • Availability of expertise and ability to recognise expertise
  • Services quality and standards
  • Device provision
  • Potential thin markets or market failure
  • Data collection

Over the last 4 years the Sector has been told my many government Ministers and departmental representatives that consumers will not be disadvantaged by the transition arrangements.  Consumers need time to test that commitment before the new arrangements are put into place.

Hearing services providers need time to:

  • undertake modelling to determine whether service provision under the NDIS is financially viable
  • meet the NDIS registration and accreditation requirements
  • develop referral pathways
  • develop marketing materials
  • develop clinical standards and protocols if they are taking on new clinical work
  • recruit expertise if it doesn’t already exist within the business
  • train staff in the new arrangements

As the NDIS has not yet consulted with hearing services providers, providers are in no position to know whether they will register to deliver services under the NDIS.  Therefore, the NDIA cannot know whether it is creating market failure with the planned service delivery arrangements.  This is a significant risk and needs to be addressed urgently. If services become competitive then there is no obligation on Hearing Australia to act as a safety net to ensure services continue to be available in all current locations.

Additionally, the sustainability of the Community Service Obligations (CSO) program needs to be investigated once the transition arrangements are determined to ensure that services to clients who remain within the CSO program are not compromised.  In particular services to:

  • Children requiring audiological assessment who are not fitted with devices
  • Children fitted with devices who do not transition to the NDIS due to having a minimal hearing loss or a conductive hearing loss, particularly Aboriginal and Torres Strait Islander children fitted due to chronic otitis media
  • Aboriginal and Torres Strait Islanders aged over 50 years or those accessing the Community Development Program
  • Aboriginal and Torres Strait Islanders through a cultural appropriate outreach program
  • HSP eligible adults with complex hearing rehabilitation needs
  • HSP eligible adults living in remote areas of Australia

need to be provided to the same or an improved standard.

If it is decided that the CSO Program will not continue in its current form and that alternative arrangements will be put into place, the hearing health sector needs to be consulted prior to the final decision being made on how the program will operate post 30 June 2020 so it can prepare for the changes.

The implementation of the new arrangements is now 7 months away (Readers please note: this post was published on 18 Nov 2019).  Approximately 4-6 weeks of that time will be lost due to expected leave and other commitments over the Christmas/New Year period.  That leaves less than 6 months for the hearing health sector to be consulted, for any changes to be made to the proposed arrangements prior to implementation, for support groups, providers and researchers to undertake whatever needs to be done to prepare for implementation, and for consumers to be informed of the new arrangements

The Hearing Services Program legislation relating to the Voucher Program has already been amended to incorporate the new arrangements from 1 July 2020 so it would be extremely difficult to defer the implementation date for NDIS transition at least for adults.  It may be possible to defer the start date for children as the legislation relating to services to children and eligible Aboriginal and Torres Strait Islander adults would still allow services to be provided through the CSO Program.

Parent groups have made it very clear in their various written submissions and appearances at Government Inquiries that they want Hearing Australia to remain as the sole provider of services to infants and children at least while they are still at school.  If the proposed arrangements allow that to occur then it would be possible for the consultation in relation to services to children to be completed in time for a 1 July 2020 implementation as any changes would be minimal.  It is difficult to know if other proposed models for the delivery of services to children could still be achieved by the deadline without some knowledge of what is being considered.

It is critical for the new arrangements to be communicated to the hearing health sector well before 1 July 2020 so that any issues can be addressed prior to implementation.  The system has to operate effectively from Day 1. If children and adults with hearing loss are not given the appropriate standard of service, and it is not delivered by people with the necessary skills, knowledge and expertise then it could have a detrimental impact on their lives.

Next steps

  1. Consultation with the hearing health sector on the proposed service delivery models is required as a matter of urgency particularly in relation to services to adults as the implementation date for the new arrangements of 1 July 2020 is already incorporated in legislation
  2. Advice to the Sector on whether the implementation date for transition of children with devices to the NDIS will remain as 1 July 2020 and what model of service delivery will apply from that date
  3. The NDIA needs to provide information on the fee schedule for hearing services and device supply arrangements so that providers can begin business modelling to determine whether it will be financially viable for them to register as a provider under the NDIS
  4. The NDIA needs to open registration for hearing services providers so they can complete the process prior to 1 July 2020
  5. The NDIA needs to advise the Sector of its plans for an education campaign to inform consumers, providers, referrers, support groups and researchers of
    • the new service delivery arrangements
    • the access pathway
    • the way that consumers can identify clinicians with the appropriate expertise
    • the clinical standards that will apply
    • the device standards that will apply
  6. The NDIA needs to identify and address any thin markets or potential market failure prior to 1 July 2020 so that consumers are not left without a service once transition has been completed
  7. The future arrangements for the CSO Program need to be communicated to consumers and the hearing health sector.