Report on the regulatory framework for hearing services

Focusing on the administration of the scheme

Review of the efficiency and effectiveness of the regulatory framework for hearing services July 2012. The Report was prepared for the Office of Hearing Services by MP Consulting

Page last updated: 28 November 2012

I. Is the scheme being administered efficiently and effectively?

This review did not include a detailed assessment of OHS processes. As such it is not appropriate to draw conclusions regarding the overall efficiency and effectiveness of the administration of the scheme.

However, the following general observations (based on discussions with stakeholders and a review of the regulatory scheme) may be made:
  • While stakeholders were not directly asked about the efficiency and effectiveness of the administration of the scheme or the performance of the OHS, most stakeholders volunteered positive comments about the OHS and the efforts that the OHS has made over the last year to try to improve and streamline the system.
  • Consistent with these observations, it is also evident from a comparison of the 2011-12 service provider contract and Rules of Conduct with the­ 2012-13 service provider contract and Rules of Conduct, that there have been significant improvements which will make some processes more efficient.
  • Data published by the OHS suggests that the efficiency of some processes is improving. For example, as reflected in the following tables, the processing time for vouchers has improved over the past year.
      Application TypeVouchers IssuedAverage Weeks
      Application TypeVouchers IssuedAverage Weeks
In terms of areas for improvement, mpconsulting considers that:
  • the structure of the regulatory system, its complexity and lack of clarity is likely to create administrative inefficiencies for the OHS. For example:
      • staff should theoretically be trained in both administrative law decision making and also contract interpretation and administration
      • policies and procedures should exist to support each of the processes required to be undertaken by the OHS
      • auditors should be familiar with all of the service provider obligations and should theoretically audit in accordance with a risk-based hierarchy (but it is unlikely that this is the case given that the regulation does not support this approach)
  • there are a large number of processes, many of which are manual. Consideration could be given to automating these systems.
  • there are some processes which do not necessarily need to be undertaken by the OHS. For example, clients must apply to the OHS for a voucher in order to access services. This is a manual process which involves the client, a medical practitioner, the service provider and an assessment by the OHS. Given that the eligibility criteria are relatively clearly defined and that there is a high rate of approvals by the OHS, consideration could be given to enabling the service provider to assess eligibility and this being audited by the OHS.
    Further consideration would need to be given to:
      • the cost of administering the voucher scheme (in terms of time and resources) compared to the cost to government should service providers inappropriately assess eligibility
      • the actions that would be available to the Commonwealth in the event that inappropriate assessment of eligibility is made by the service provider.