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.
- 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
- 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
- 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
- The NDIA needs to open registration for hearing services providers so they can complete the process prior to 1 July 2020
- 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
- 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
- The future arrangements for the CSO Program need to be communicated to consumers and the hearing health sector.
Captel to be axed from National Relay Service in 2020
More than 4,000 people with hearing difficulties around Australia will be without the CapTel phone service from 2020 when an American company takes over the National Relay Service.
The Commonwealth Government has awarded Concentrix Services a contract to deliver the National Relay Service (NRS). Concentrix will axe the CapTel handset service on 1 February 2020. It will replace CapTel with alternatives that are cumbersome and slow.
What is a CapTel captioned telephone? It works like any other telephone with one important addition: it displays every word the caller says throughout the conversation. CapTel phone users can listen to the caller and can also read the written captions in the CapTel’s display window.
Deafness Forum of Australia, Deafblind Australia, Deaf Australia (the group that represents people who communicate in Auslan) and Australian Communications Consumer Advocacy Network have been collaborators for several years to support the National Relay Service and ensure that its services are not degraded but improved.
This group of advocacy organisations met in July 2019 with officers of the Department of Communications (the department that is responsible for the National Relay Service) and its soon to be appointed contractor Concentrix.
The Department representatives made it clear that the axing of CapTel was not negotiable.
Deafness Forum argued that the notice period was far too short and would have a profound effect on the 4,000 users of CapTel, many of whom are aged and vulnerable citizens. We strongly recommended that the Department negotiate a 5 year transitioning period with the company that owns the licence in Australia to sell CapTel units. The department said it wasn’t able to make a deal with the company but couldn’t explain why due to commercial confidentiality.
Where does this leave CapTel users? The department will not be dissuaded, so we must take our case to the politicians. It is very important, in our experience, that the decision-maker hears directly from the people that a decision will affect. In this case, the decision-maker is the Minister for Communications, Cyber Safety and the Arts, Paul Fletcher MP.
Paul.Fletcher.MP@aph.gov.au T: (02) 9465 3950. Level 2, 280 Pacific Highway Lindfield NSW 2070
Comments from our members
“Captel is for the chop despite the harm this decision will cause. I cannot believe that this government which my mother has voted for all her life would treat her in such a poor and cavalier fashion and ignore the basic need for human contact and socialisation. It is imperative that the Federal Government continue to fund the CapTel service and reverse its decision to axe the service!”
“It is indeed a big shock to many Australians, and myself, who rely and need the Captel handset. It seems to me that this section of people with a hearing loss have been sacrificed in a big way so that the TTY can be ‘re-introduced’ and then plunge those who went deaf later in life and whom can speak, right back in the dark ages. Many of our members have spoken of their dismay and disgust, particularly being isolated and the loss of their independence. In the long run, this move will cost the Australian government much more than it does now.”
“I cannot believe that the government wants to save money at the expense of people who have the disability of deafness and who depend on this service. You are not even replacing it with an alternative. My mother at her age, uses this phone service as an aid to fill in the numerous requests of places like Centrelink, make appointments to see doctors, specialists etc. and to communicate with her remaining friends and family. I am totally shocked that you as a government don’t see this as a problem.”
Future of hearing services in Australia
Good news about hearing assistance in aged care
Deafness Forum of Australia is deeply concerned about the continuing, widespread lack of recognition and effective management of hearing loss in aged care services.
This is despite government accreditation requirements, overseen by the Australian Aged Care Quality Agency, having been in place for two decades.
70% of Australians aged over 70 have some hearing loss. This increases to around 85% in residential aged care. However, staff of age care service providers and in hospitals are seldom adequately trained to assist those with hearing loss.
Deafness Forum has highlighted the absence of necessary hearing assistance training for aged care staff – from registered nurses to direct carers and the teams of Quality Surveyors employed by the Australian Aged Care Quality Agency to monitor aged care facilities.
Deafness Forum has, over the past few years, achieved inclusion of hearing assistance in the relevant VET qualifications and has developed a wide range of free training resources – https://www.deafnessforum.org.au/resources/training-resources-in-hearing-assistance-in-aged-care-services-and-hospitals/
However, it is obvious to us that education alone will not overcome the widespread indifference to the needs of hearing impaired ‘consumers’. Enforcement by the Australian Aged Care Quality Agency is crucial. Deafness Forum’s position is that it is crucial that the latest Aged Care Quality Standards must make very clear that hearing assistance is an essential requirement and must be taken seriously by providers and quality surveyors.
In August 2018, the Australian Aged Care Quality Agency released its ‘Guidance and Resources for Providers’ to support the new Aged Care Quality Standards which will come fully into effect in July 2019. The guidance materials are the practical guidelines for aged care service providers and a reference for those that audit the providers.
For the first time, hearing loss has been specifically addressed in the Guidance and Resources for Providers materials. Hearing references are to found throughout this new Guidance material (view the document here). Deafness Forum’s ‘Hearing Assistance in Aged Care Best Practice Manual’ is a cited source.
Hearing matters will now be built into the compliance rules, linked to the legislation. It’s not the solution to all problems in addressing hearing loss in aged care centres and in home care – auditors need to dig deep in their assessments, but every party will know that programs and procedures in relation to hearing will be examined in the process of certification and therefore Commonwealth funding for providers. Deafness Forum’s resources and community monitoring will still be needed. We also need to educate the auditors to ensure proper reviews are done.
Deafness Forum thanks the Minister for Aged Care Ken Wyatt AM and the Australian Aged Care Quality Agency for responding to our concerns. We acknowledge the tireless voluntary efforts of our members Basil Turner and Emma Scanlan in making a very real difference to the health and wellbeing of Australians in residential aged care.
Hearing health and wellbeing a national health priority
Hearing health doesn’t get the priority needed to address the massive social, health and economic costs of hearing impairment to individuals and society in Australia.
With an ageing population, hearing loss is projected to increase to one in every four Australians by 2050.
In 2017, a parliamentary committee conducted an inquiry into the hearing health & wellbeing of Australia. In August 2018, the Federal Government announced its response to the 22 recommendations made in the inquiry’s report. The Government supports only one of the 22 recommendations. Read the report here
Hearing loss ranks as a major cause of years of healthy life lost due to disability. A study of the burden of disease by the Australian Institute of Health and Welfare found that adult-onset hearing loss was the fifth highest cause of years of healthy life lost due to disability.
A significant component of acquired hearing loss 37 per cent is due to excessive noise exposure from inappropriate listening behaviours. Spending money on education to prevent hearing loss could be effective in reducing the projected increase.
Hearing loss is associated with increasing age, rising from less than 1% for people aged younger than 15 years to three in every four people aged over 70 years.
Given that a significant component of hearing loss is preventable, there is a clear argument for identifying hearing loss as a national health priority; and for a cross-jurisdictional approach to awareness and preventing and remedying hearing loss.
- hearing health needs to be dealt with as a mainstream health issue.
- hearing loss increases risk of depression, dementia, blood pressure and heart conditions.
- the Government, in cooperation with all state and terriritory governments, must create a national strategy to address the enormous social and economic costs of hearing loss, estimated at $15billion every year and growing.
- this will raise public profile, education, prevention, supports, and research to direct smart, integrated government policy.
You can read our submission to the Government on why hearing heath and wellbeing must become a national priority.
Hearing services in the National Disability Insurance Scheme
Current issues are explored in the following submissions made by Deafness Forum to various inquiries.
- submission to a parliamentary inquiry into hearing services within the NDIS
- submission to the Productivity Commission regarding costs of hearing services in the NDIS.
The issue of eligibility
Eligibility for the National Disability Insurance Scheme depends on a person’s age, residency status and disability. To access the NDIS you must satisfy the following 3 conditions:
- be aged under 65 years AND
- live in Australia and are an Australian citizen or hold a permanent visa or a Protected Special Category visa AND
- have a permanent impairment that significantly affects your ability to take part in everyday activities or have a developmental delay.
The first two criteria are straightforward. The third point requires further explanation. The NDIA has provided guidelines to clarify the access arrangements in relation to point 3, the disability requirements.
The easiest way to look at the requirements relating to disability is firstly by age and then by hearing loss.
1. Children and young people aged 0-25 years
Access is streamlined for people in this age group in recognition of the evidence that shows that early intervention supports up to age 26 is critical for people with hearing impairment as the developing brain requires consistent and quality sound input and other support over that period to develop normally and ameliorate the risk of lifelong disability.
For this age group the evidence from an audiologist that shows…
- auditory neuropathy or hearing loss equal to or greater than 25 decibels in either ear at 2 or more adjacent frequencies, which is likely to be permanent or long term; and
the hearing loss necessitates the use of personal amplification
…should be sufficient to satisfy the access requirements without the need for further assessment.
But what if a person has no auditory nerves? For participants under 25 years who have a permanent hearing impairment the NDIS operational guidelines states: “The hearing loss of the person necessitates the use of personal amplification.” It’s confusing but the NDIA said that it does not mean the child has to wear personal amplification. So, if a child has no auditory nerve and cannot wear a hearing device they will still meet the access criteria.
2. People aged 26 – 65 years
The level of evidence required to support an access request for people in this age group varies according to the degree of hearing loss. The NDIA has developed a list of conditions which are designed to streamline the access process. A person with a permanent hearing impairment of greater than 90 decibels in the better ear (pure tone average of 500Hz, 1000Hz, 2000Hz and 4000Hz) is eligible to join the NDIS without the need to prove that their disability has substantially reduced their functional capacity. It is accepted that this degree of hearing loss will have a significant impact on the person’s functional capacity.
For people with hearing loss less than 90 decibels, the NDIA has given further guidance on what information is required of the applicant:-
- People with a permanent hearing impairment of 65 decibels or greater in the better ear must provide evidence that the disability results in substantially reduced functional capacity to undertake communication, social interaction, learning or self-management activities.
- Hearing impairments of less than 65 decibels in the better ear in conjunction with other permanent impairments (which meet the NDIS access requirements for example vision or cognitive impairments), or where there is evidence of significantly poorer than expected speech detection and discrimination outcomes, may also be considered to result in substantially reduced functional capacity to undertake relevant activities. People in these circumstances may also be eligible to join the NDIS.
Providing good evidence will help the NDIA make the right decision about your eligibility for the NDIS. The evidence should demonstrate the functional impact of your hearing impairment on different areas of your life. It could relate to the communication challenges you experience in relation to your employment, education and training, social participation, independence or health and well-being. Your audiologist may be required to provide the evidence to support your NDIS Access Request, so you need to ensure your audiologist fully understands how your hearing loss is impacting on your daily life.
People have expressed concern about providing ongoing services to people who are not eligible for the NDIS. It isn’t yet clear if there will be any changes to the way the services are delivered. It is also not clear whether all existing groups, including Aboriginal and Torres Strait Islander people, will continue to be able to access services under the Australian Government Hearing Services Program in the longer term such as children who need hearing assessment services.
There will still be people who will miss out on government funded hearing services. People whose hearing loss isn’t considered to have a significant functional impact will not meet the criteria for the NDIS. Unless these people hold a Pensioner Concession Card they will not be eligible for the Australian Government Hearing Services Program either. People on low income – unemployed people, people in part time employment or those with low paying positions – will still have to fund their own hearing services. They generally can’t afford to update their devices, so they may miss employment opportunities due to the lack of financial support for hearing services.
The NDIS and the Australian Government Hearing Services Program are great programs for those who qualify, but there will be people in need who are left behind as they don’t qualify for any funded supports.
Issues about the sale of hearing aids
The Australian Competition and Consumer Commission (ACCC) released a report in March 2017: Issues relating to the sale of hearing aids.
The ACCC report found that commissions, incentives and other mechanisms designed to drive sales can create a conflict with clinical independence, professional integrity and the primary obligation to consumers.
“Some hearing clinics encourage clinicians to sell more expensive hearing aids by setting sales targets, paying commissions to clinicians, having arrangements that favour certain brands or are owned by companies that manufacture hearing aids. Commission-based selling can provide incentives to clinicians to supply hearing aids that are unnecessary or more expensive than a consumer needs. This has the potential to lead to consumer harm where trusted advice is being given to patients, many of whom may be vulnerable or disadvantaged,” ACCC Commissioner Sarah Court said.
commissions, incentives and sales targets are pervasive in the audiology industry
sales practices might be misleading or unconscionable – if proven would raise serious concerns under the Australian Consumer Law
some clinics are in relationships with finance providers
ACCC urges industry to make changes
ACCC has “strong view” that giving more information to customers won’t protect consumers
governments can look at regulatory models that might limit or remove commission based sales
clinics can look at separating the provision of health services from the retail environment.
We note that the ACCC report highlights a lack of transparency that puts the consumer at risk at a time when they are most vulnerable.
The practice of upselling, commissions and bundling the cost of a device with follow-up rehabilitation service is an area of risk for consumers who may have no objective way of knowing whether the device recommended by an audiologist is best suited for their individual needs. The arrangement where a hearing care professional receives a financial payment for promoting a particular product brings in a level of uncertainty to a relationship that needs to be built on trust. Consumers don’t want the advice they receive to be any way influenced, or compromised by the payment of a financial incentive to the clinician.
While acknowledging that not all hearing clinics have this practice, we believe that audiologists would prefer to be rewarded for their expertise and the results they achieve for their clients.
We support the recommendations of the ACCC and would like to work with the hearing industry to help it develop alternative remuneration structures that reward quality and outcomes over sales.
Hearing assistance in aged care
Seven in ten older Australians have hearing loss, but the staff of age care service providers and in hospitals are seldom sufficiently trained to help.
It’s often not realised that even a slight to moderate hearing impairment, if not managed, can inhibit social interaction resulting in significantly reduced quality of life and may also increase depression and dementia.
The long-standing lack of adequate hearing assistance to residents who need it, has resulted in a common misconception that addressing this need is largely a matter for residents and their families. The fact that some care staff do however provide effective hearing assistance in the course of their normal duties demonstrates that this assistance can be provided as part of normal personal care. There is also a common misconception that attending to the needs of hearing impaired residents increases the already heavy workload of care staff. In fact, hearing assistance, if undertaken systematically and competently, adds little additional work and brings enormous benefit for both staff and residents. Home care staff will need the same training as their residential counterparts.
An effective hearing assistance program will benefit staff as well as those they care for and if performed systematically should not be time consuming.
We have a range of free training resources in hearing assistance for nurses and other care staff in aged care services and hospitals. The resources include learning modules, a good practice guide and an instructional video.
The resources are also useful for carers and volunteers who work with hearing impaired people in the community.
You can find these resources on our training resources page