Document reviewThis review has predominantly focused on analysis of the legislation, contracts and administrative guidelines that comprise the regulatory framework for the hearing services scheme. Documents reviewed have included:
- all relevant legislation
- all contracts and Deeds including the service provider contract and the Deed of Standing Offer with device suppliers
- administrative documents
- stakeholder information available on the OHS website such as: information for clients, FAQs, service charter for OHS clients
- reports of parliamentary committees and responses (including the Response to the Senate Community Affairs Reference Committee Report, Hear Us: Inquiry into Hearing Health in Australia, May 2011)
- documents provided by the OHS.
ConsultationsOn the advice of the OHS, mpconsulting has consulted with:
- the Department of Veterans Affairs
- the Hearing Care Industry Association (HCIA) - HCIA represents hearing healthcare retailers including AudioClinic, Bay Audio, Connect Hearing, HearingLife Australia, National Hearing Care, The Neurosensory Unit and Widex Australia.
- professional bodies - Audiological Society of Australia, Australian College of Audiology and Hearing Aid Audiometrist Society of Australia
- Australian Hearing – the Australian Government provider of hearing services (the largest provider of services)
- Deafness Forum of Australia - the peak overarching body for deafness and hearing impairment in Australia.
Advice was sought from all stakeholders about:
- whether they had a clear understanding of the regulation and the extent to which the regulation achieves its objectives. Stakeholders were asked if they viewed regulation as merely establishing a framework for funding service providers or if it was also a framework for: setting minimum standards for the delivery of services; encouraging continuous improvement; ensuring quality services; and prohibiting certain unacceptable conduct
- the risks that the program is intended to mitigate and the likelihood that these risk could be realised
- the strengths of the existing scheme
- the extent to which the legislative framework meets the objectives of good regulation
- any areas for improvement. In particular, whether there are any unnecessary elements of the framework or any processes which stakeholders consider impose unnecessary administrative burden on government, service providers, device suppliers or clients.
Industry groups were also asked about:
- any perceived risks to business posed by the current regulatory framework
- the level of understanding, among service providers, of responsibilities under the legislation.
The representative of Deafness Forum Australia was also asked about:
- whether the voucher program met the needs of clients
- whether the voucher program is easily understood by clients
- the key concerns expressed by clients in relation to the scheme
- the main risks to clients including risks that may arise from any changes to the nature and/or level of regulation of service providers.
The representatives of the professional bodies were also asked about:
- the role that membership bodies play in ensuring that their members provide quality services for clients
- whether professional membership bodies have mechanisms for supporting the integrity of the Commonwealth hearing services program (i.e. do they play a role if members are making inappropriate voucher claims?)
- whether professional bodies will have a monitoring program in place to ensure that practitioners meet their obligations under the hearing services legislation
- any key challenges for practitioners in navigating/administering the scheme.
The results of the stakeholder consultations are reflected in this report.