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Audiology Australia views on recommendations of the PwC Review

The Review identifies 13 major recommendations associated with the current service delivery model under the Voucher Scheme (VS) component of the Department of Health’s Hearing Services Program (HSP). The Government has indicated that it will be responding to the Review by September 2018.
Please note that this document represents a summary of AudA’s views on the Review based on member feedback received to date.
A more detailed response is under preparation to be provided to AudA members.

Recommendation 1 - Accelerate the transition towards an outcomes focused model.
AudA supports this recommendation in principle. We consider that the meaning of
‘outcomes’ needs to be focused on all levels of services and non-hearing aid outcomes such as client wellbeing and teaching clients how to interact with their families.

AudA looks forward to working with Government to develop a comprehensive approach to achieving a standardised approach to measuring, collecting and reporting on clinical and lifestyle outcomes of all aspects of a client’s diagnosis and treatment, including the impacts of any intervention on the client.

Recommendation 2 - Review the MHLT - The MHLT should be formally reviewed with the intention to investigate aligning the MHLT with international practice definitions of hearing loss; mandating the measurement and reporting of hearing loss via international and industry practice (4 FAHL) and applying the outcomes of such a review to prospective clients.

While AudA supports mandatory 4FAHL as this is industry best practice, AudA is strongly opposed to the proposal of the World Health Organization’s definition of disabling hearing loss (40dB) being the entry threshold for the VS. The WHO definition was created as a guide for developing countries and not the Australian context.

The evidence strongly supports early intervention rather than leaving hearing loss to reach a disabling level. This proposal also does not address the psychosocial aspects of hearing loss.

AudA considers that, while raising the MHLT may result in initial savings to government, the delay of early intervention is deleterious and risks significant and higher social and economic costs over the longer-term.

Recommendation 3 - Improve the information about hearing services and AHT, and dissemination of this information to clients in the VS
AudA supports this recommendation. It will help improve clients’ hearing/health literacy and knowledge about the VS.

Recommendation 4 - Investigate the scope and cost of providing a range of additional services through the VS.
AudA supports this recommendation in principle but considers that more detail is required. The range of additional services to consider providing through the VS should be expanded to include other items such as community work - education programs in regards to hearing loss.

Recommendation 5 - Change the name of the VS
AudA supports this recommendation.

Recommendation 6 - Adopt the simplified and unbundled model for the schedule of service items
AudA supports simplified claiming in principle because this idea benefits both clients
and providers but, at the same time, more information is needed. In particular, the pricing structure underlying this model is currently unknown.

Simplifying and unbundling the schedule of service items improves the transparency of the VS and enables clients to better understand where the expenses of the VS lie – with the device.

Unbundling also gives improved recognition of audiology as a profession because it takes away the focus from the device and – by reducing the number of service items from 48 to 4 - gives clinicians greater professional autonomy to run their own appointment program.

AudA also seeks clarification about what ‘bundling’ and ‘unbundling’ means in the context of the HSP, and the associated implications for practitioners, clinics and clients. While AudA is keen to increase transparency of the value of audiology services and improve client understanding of costs, we consider that the Review does not provide enough detail about what is meant by bundling and unbundling in the context of hearing services, nor does it explore the impact of unbundling.

Recommendation 7 - Adopt a new pricing structure for the simplified and unbundled model of service items
AudA supports this recommendation in principle but considers further detail about how the model will work in practice is needed. In particular, further information is needed about PwC’s modelling assumptions that underpin the proposed ‘simplified model’.

Recommendation 8 – Remove the subsidy applicable to partially subsidised AHT (but retain the partially subsidised AHT schedule)
AudA supports this recommendation in principle but believes it needs to be carefully managed in such a way that does not undermine client choice.

More information is needed about the intent of this recommendation, how it would be linked with Recommendation 9 and how consumer choice would be affected.

If it is implemented, it will also be critical for the fully subsidised range of hearing devices to be constantly reviewed to ensure it is delivering the best devices for client’s clinical needs.

Recommendation 9 – Review the minimum specifications
AudA supports this recommendation.

Recommendation 10 - Investigate the viability of including cost recovery levies
AudA has no comment on this recommendation.

Recommendation 11 – Implement additional AHT listing rules
AudA supports this recommendation and considers that it would need to be considered together with Recommendation 9.

Recommendation 12 - Mandate the disclosure of the price and features of AHT
AudA supports this recommendation in principle as it will help improve transparency of information about the VS and enable clients to make informed decisions.

Recommendation 13 – Rename the AHT schedules
AudA supports this recommendation.

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