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2March 2016

Special edition
Future of Australian Hearing
Services in Australia
Clients of the Australian Government Hearing Services
Program who meet the eligibility criteria for the National
Disability Insurance Scheme (NDIS) will transition to the NDIS
by 2019-20.
The Office of Hearing Services has released a Hearing
Services Program/NDIS Transition Plan which describes the
activities, dependencies and timeframes that need to take
place to effectively support the transition of eligible Hearing
Services client from the Hearing Services Program to the
NDIS.

Future of Australian Hearing


A consortium comprising non-profit service provider, Royal
Institute for Deaf and Blind Children, Macquarie University
and Cochlear Limited, has bid for ownership of Australian
Hearing.1
Deafness Forum interviews the consortium in this One in Six.

We acknowledge the traditional owners of country throughout Australia, and their


continuing connection to land, sea and community. We pay our respect to them
and their cultures, and to elders both past and present. We acknowledge the
challenge that faces Indigenous leaders and families to overcome the unacceptably
high levels of ear health issues among first Australians.

FUTURE of HEARING SERVICES in Australia


Clients of the Australian Government Hearing Services Program who meet the eligibility
criteria for the National Disability Insurance Scheme (NDIS) will transition to the NDIS by
2019-20.
Read

Fact

Sheet

prepared

by

Office

of

Hearing

Services

http://www.deafnessforum.org.au/images/pdf/Hearing%20Services%20Program%20and%20NDIS%20Fact%20Sheet.pdf

The group most affected by this change is hearing impaired and Deaf children and their
families. This client group is currently under the care of Australian Hearing which is the
sole provider of services to children with hearing loss and their families. Under the NDIS
there will be a choice of service provider for the first time.
The concept of client choice in service provider is not at issue. What is concerning, is the
private market is untested in the delivery of services to children with hearing loss. The
introduction of contestability introduces significant risks in terms of access, expertise,
quality, standards and client outcomes.
The paediatric client group is quite small. If services are spread across multiple providers it
will be difficult for the clinicians to maintain their skill level which puts the client outcomes
at risk. A study by McCreery, Bentler and Roush (2013) which investigated the accuracy of
infant fittings across 15 U.S. States, showed that despite the availability of fitting guidelines
and prescriptive formulas in that country, 26% of the children were shown to have suboptimal fitting that resulted in reduced access to speech. A significant predictor of suboptimal fittings was the audiology clinic the child attended. Clinics with low client volumes
and infrequent engagement with babies and very young children as would be the case
with contested paediatric hearing services are likely to be prone to poorer fitting
outcomes.
Also, the Government is still to make a decision on the future ownership options for
Australian Hearing so it is still not clear whether the safety net of the Government hearing
services provider will continue to be available.

Deafness Forum of Australia has developed a paper outlining the issues that need to be
addressed in the transition plan.
Read Deafness Forums Transition of the Australian Government Hearing Services CSO
Program to NDIS -- issues paper June 2015
http://www.deafnessforum.org.au/images/pdf/Transition%20of%20the%20Australian%20Government%20Hearing%20Se
rvices%20CSO%20Program%20to%20NDIS--%20issues%20paper%20June%202015.pdf

The Office of Hearing Services has released a Hearing Services Program/NDIS


Transition Plan which describes the activities, dependencies and timeframes that need to
take place to effectively support the transition of eligible Hearing Services client from the
Hearing Services Program to the NDIS.
The following is an extract from the Australian Government Hearing Services Program
website - Hearing Services Program NDIS Transition Plan
As part of the introduction of the National Disability Insurance Scheme (NDIS) in 2013, the
Australian Government agreed to transition existing Commonwealth programs that provide
support to people with disability to the NDIS. One of these programs is the Australian
Government Hearing Services Program (the Program), which will be transitioned in part to
the NDIS by 2019-20.
This means that a portion of clients under 65 years of age currently receiving services
through the Voucher Scheme or the Community Service Obligations (CSO) component of
the Program will transfer to the NDIS.
Partners and stakeholders have had the opportunity to provide early input to the transition
design process to ensure that those elements of the current system that work well for
stakeholders are identified and not lost. The transition of eligible clients is a complex
process with many moving parts, and it involves multiple Commonwealth agencies. A
clear, early transition plan will minimise unintended consequences, including impacts on
clients.

Who is involved and how?


Stakeholder

How they are involved

Program clients eligible for the Until the NDIS reaches full roll out the usual
NDIS
arrangements for the Voucher Scheme and the
Community Service Obligations component of the
Hearing Services Program will apply. At full roll out
clients will generally have the option to choose a
provider, or continue to receive services from their
current provider. Clients may also be able to receive
a broader range of benefits that they did not receive
before based on an individualised plan.

Stakeholder

How they are involved

Parents and carers of Program Parents and carers will need to become familiar with
clients who can access the NDIS
the new individualised planning and funding
approach to hearing services under the NDIS.
Existing Program clients, including These clients will continue to receive hearing
parents and carers who cannot services through the Program.
access the NDIS because they do
not meet the threshold for
permanent hearing loss as a single
disability
Existing and potential future CSO Responsibility for providing services to clients who
clients who do not have a do not have permanent hearing loss needs to be
permanent hearing loss (e.g. reviewed.
monitoring
of
children
with
transient hearing loss due to
chronic ear infections)
Service Providers who are currently Service providers will need to consider their capacity
unable to deliver CSO services
to deliver services to new client groups. Service
providers do not currently need to register with the
NDIA, unless they wish to provide services in
addition to those available under the Program.
Future potential Hearing Services Access to the Hearing Services Program for people
Program clients under 65 years under 65 years who do not qualify for the NDIS will
who cannot access the NDIS.
need to be reviewed.
Practitioner Professional Bodies The PPBs will need to identify the scope for, and
(PPB), representing audiologists their role in, supporting the practitioner workforce.
and audiometrists
Disability and hearing loss advocacy These groups need to have the capacity and
groups
capability to engage in consultation processes and
represent the views of their membership (noting
that many rely on voluntary support).
Organisations delivering services to New models of service delivery may be required to
rural and remote clients
ensure that there is no reduction in access to
services.
Department of Health (Office of Health will be responsible for leading on a range of
Hearing Services)
transition work in addition to ensuring ongoing
operational requirements for the Program.
Department
(DSS)
National
Agency

of

Social

Disability

Services DSS has lead policy responsibility to ensure there


are no barriers to a successful transition.
Insurance NDIA will be responsible for leading on several timecritical work packages while balancing other
priorities.

Stakeholder
Department
(DHS)

How they are involved


of

Human

Services DHS is responsible for providing input to aspects of


changes required to the legislation governing
Australian Hearing to allow delivery of hearing
services via the NDIS.

Australian Hearing (AH)

AH will operate in a more contestable environment


for hearing services funded by the NDIS.

Service Providers of private clients

Service Providers will need to ensure that their


business model supports the potential change to
their client base, as a portion of private clients are
expected to be able to access the NDIS.

Read the entire document, Hearing Services Program NDIS Transition Plan February 2016
http://www.deafnessforum.org.au/images/pdf/NDIS%20Transition%20Plan%20Feb%202016.pdf

Australian Hearing
The Government is investigating the privatisation of Australian Hearing. Australian Hearing
is highly regarded internationally as the provider of high quality hearing services,
particularly to Deaf and hearing impaired children. The National Acoustic Laboratories (a
part of Australian Hearing) is regarded as a world leader in hearing research.
A consortium comprising non-profit service provider, Royal Institute for Deaf and Blind
Children, Macquarie University and Cochlear Limited, has bid for ownership of Australian
Hearing.1
The Consortium has proposed what it described as a unique partnership model that will
honour Australian Hearings original intent; safeguard clients of the Community Service
Obligation (CSO) program; address areas of service growth and unmet need; and provide
enhanced service and improved hearing health outcomes for all Australians.
Deafness Forums advisory group on this topic asked a set of questions of the consortium.
The advisory group members include representatives of Aussie Deaf Kids, Parents of Deaf
Children, Deaf Australia and Deafness Council Western Australia.

Statement by the RIDBC led consortium


In 2014, the National Commission of Audit recommended the privatisation of various
Government bodies, including Australian Hearing. When the potential privatisation was
originally announced, Royal Institute for Deaf and Blind Children (RIDBC), along with many
other service providers and stakeholders were interviewed as part of the Governments
scoping process and RIDBC recommended three possible scenarios:

Cochlear Ltd and Royal Institute of Deaf & Blind Children are financial contributors to the work of Deafness
Forum.

1. Should Government decide to sell, Australian Hearing should not be sold to a private
equity firm, or to a commercial entity, whose motive would likely be driven by service
consolidation and profit.
2. Should Government decide to sell, the services of Australian Hearing should not be
broken up, as this would pose considerable risk to the ongoing provision of the
Community Service Obligation (CSO) program, the important work of the National
Acoustic Laboratories (NAL), and for people living in rural and remote communities.
3. Should Government decide to retain Australian Hearing, there is a need for greater
investment to maintain and extend the service offering, to address areas of service
growth and unmet need.
In 2015, Government changed its approach and discussion on the "sale" of Australian
Hearing was focused on the CSO program forming part of the National Disability Insurance
Scheme (NDIS). This position advocated the full contestability of the hearing services
environment inclusive of CSO and existing Voucher Program clients.
Choice is recognised as a fundamental of the NDIS, however under the NDIS, there is a
very real risk of market failure for vulnerable groups and service providers, particularly in
rural and remote areas of Australia. There is also a risk of de-specialisation of services for
children without a clear service pathway from diagnosis to intervention and ongoing
support. Additionally critical paediatric and hearing health data may be at risk should full
contestability of the market commence in the absence of a centralised research body such
as NAL.
In February 2016, Government announced its intention to formally examine a proposal put
forward by a Consortium comprising RIDBC, Macquarie University and Cochlear Limited, for
the possible transfer of Australian Hearing into non-Government ownership.
The Consortiums driver is the wellbeing of all Australians with hearing loss. We have
formed the view that, if Government intends to move Australian Hearing out of public
ownership, consideration needs to be given to a model other than the sale of the
enterprise as a for-profit entity.
Given the NDIS environment, the Consortium believes that Government now has two clear
choices to consider:
1. Retain Australian Hearing in Government ownership and invest in it to provide a full
service to all existing CSO clients, as well as providing services to the full client market
inclusive of other important technologies and service offerings, or
2. Transition Australian Hearing into a non-government environment where the focus is on
improved services for all Australians with hearing loss.

The Consortium believes both of these options are worthy of Government consideration. In
our opinion, the premise that Australian Hearing "stay as it is" in a fully contested
environment may not be viable in the long term.
We are convinced that, as an alternative to government ownership, the Consortium model
provides a governance and ownership structure for Australian Hearing that will preserve,
protect and extend upon hearing services for all Australians.

Q&A with the consortium


Deafness Forum: Are you able to provide further details on the proposal that the
Consortium has put to Government regarding Australian Hearings ownership
arrangements?
Consortium: The Consortium proposal centres around three key principles preserving
Australian Hearings original intent; protecting Australians with hearing loss, especially
those most in need; and extending upon Australias world-leading hearing services. Please
refer to the Consortium document titled The future of hearing services for all Australians
for further detail on the Consortium proposal.
Deafness Forum: The media release refers to a transfer of ownership rather
than a sale. Is the arrangement a commercial transaction or is Australian
Hearing being gifted to the Consortium with certain terms and conditions
attached?
Consortium: There is no clear direction on this issue from Government. In Governments
press release dated 12 February 2016, regarding the future of Australian Hearing, they said
that the Government has been exploring the right future ownership options for Australian
Hearing.
While Government has been clear that Australian Hearing is not currently for sale, it is the
Consortiums understanding that any arrangement regarding the transfer of ownership
would involve a detailed description of the proposed process by the Government and a
comprehensive due diligence process by any potential acquirers of the Australian Hearing.
No such process has been announced by the Government nor described to the Consortium
or, to the best of our knowledge, any other parties.
Deafness Forum: If the Government accepts the proposal, what would be the
timeframe for transferring ownership to the Consortium? Would it occur prior to
201920 when hearing services clients transfer to the NDIS?
Consortium: The Consortium has not been advised of any specific timeframe for transfer of
ownership of Australian Hearing. In this regard we note again that the February 2016 press
release stated that the Government has not yet made a decision to transfer Australian
Hearing into non-government ownership. We are aware that some stakeholder groups are
concerned that Government intends to make a further announcement regarding Australian
Hearing as part of the May Federal Budget, however we are not aware of any intention
from Government to rush through a formal due diligence and assessment process.

Deafness Forum: What long term vision does the Consortium have for Australian
Hearing should the proposal be accepted by Government?
Consortium: The Consortiums driver is the wellbeing of all Australians with hearing loss.
Should Government decide to transition Australian Hearing into non-Government
ownership, the Consortiums intention would be to work with, and build upon Australian
Hearings significant achievements, continuing to improve services for Australians with
hearing loss while also minimising the significant health and social impacts of hearing loss.
We believe our unique partnership model will maintain and extend services, whilst ensuring
continuity of service provision, safeguarding clients of the Community Service Obligation
(CSO) program, addressing areas of service growth and unmet need, and providing an
enhanced service offering leading to improved hearing health outcomes for all Australians.
Deafness Forum: What are the potential benefits and challenges for the
Consortium partners if the proposal is accepted by Government?
Consortium: The key benefit of the model proposed by the Consortium partners is the
ability to preserve, protect and extend upon the services of Australian Hearing. We believe
this model has the potential to ensure that current and future generations of Australians
including those people whose specialised needs are served by the current Community
Service Obligation (CSO) programwill continue to have access to world-class hearing
services.
We are particularly cognisant of the benefits to the community to be derived by Australian
Hearing continuing to meet the needs of rural and remote clients, as well as the highly
specialised needs of children and adults with complex support requirements. These groups
include clients who may not be served well in a fully contested market. How their needs
can continue to be met is one of a number of open questions. Critically, much depends
upon the Governments intentions in regard to the Community Services currently delivered
by Australian Hearing and the programs that fund the delivery of those obligated services
under current arrangements (i.e. the Hearing Services Program) in the context of the rollout of the National Disability Insurance Scheme (NDIS).
The Government has signalled its clear intention that CSO clients will continue to receive
those services, either as NDIS participants or clients of the Hearing Services Programme.
At this stage, however, the manner in which that intention will be given effect is not clear.
Deafness Forum: Australian Hearing would be able to provide services to a
broad range of client groups under new ownership arrangements. How would
this work be prioritised?
Consortium: Clients of the CSO program would continue to hold the highest priority within
the consortium model. It is expected that the intricacies of service delivery and specific
operating models including prioritising those who qualify for services under NDIS, will be
explored during due diligence.
Deafness Forum: What improvements would the Consortium introduce to
Australian Hearing? For example, will the new arrangement provide opportunity
to improve access to appointments?

Consortium: Under the NDIS and through the Consortium approach, it is envisaged that
services would be made available to clients at every stage of their hearing loss journey,
from birth through to their senior years. Our ambition would be to provide integrated
assessment, diagnostics, hearing aids, cochlear implantation, therapy, education and
additional rehabilitation and support services. Opportunities to improve operational issues,
such as improving access to appointments will be explored during due diligence.
STRUCTURE
Deafness Forum: What will the structure of the Consortium be?

Will Australian Hearing and NAL remain as separate business entities


within the consortia?

What will be the equity arrangements between each party?

How will corporate governance be structured?

Who will be on any Board formed?

What will be the financial structure of each entity within the Consortium
and of any new entities formed?

Consortium: The Consortium comprises RIDBC a leading not for profit organisation,
Macquarie University an educational institution, and Cochlear Limited a commercial
entity. It is this unique combination of partners that makes our proposal very different to
those likely to come forward from for-profit entities such as companies in the hearing
device industry and private equity groups.
It is recognised that a new entity will need to be created if a transfer of ownership to the
Consortium is to occur, however the structure of the new entity is yet to be determined.
The Consortium members agree that it is important that the new entity has a non-profit
orientation and that any profits be reinvested in the entity in order to provide continuous
improvement and access to hearing services for all Australians.
A key component of the Consortium proposal is to ensure that the future of Australian
Hearing stays focussed on world class hearing outcomes, and not on the generation of
profits for shareholders. This will require a governance structure that is representative not
only of the Consortium partners, but crucially, includes significant representation from
independent board members, committees, reference groups, and opportunities for industrywide representation and advocacy.
Deafness Forum: The Consortium consists of a charity, a company and an
educational institution, what type of business entity will Australian Hearing
become?

What are the proposed governance arrangements?

How would the profit be used?

Will profits go to the provision of better hearing appliances and audiology


services or to the shareholders as dividends or company as revenue?

Consortium: Please refer to question 8, where this response is covered.

Deafness Forum: What interaction will there be between Australian Hearing and
the Consortium partners? For example, will Australian Hearing centres become a
one stop shop for hearing services including cochlear implant services and
early intervention services? Will Australian Hearing provide all of the
supervision needed by audiology students at Macquarie University?
Consortium: Although the detail is yet to be determined, there is a strong desire for
Australian Hearing to provide a seamless integration of aligned services, as well as
providing a selection of stand-alone services, so that clients can choose to work with other
service providers to meet their individual needs. A commitment to the free exercise of
choice is core to the Consortium model and we would expect this would extend to all
aspects of Australian Hearing, for example providing choice for supervision of audiology
students.
Deafness Forum: How will the government know it is getting value for money
from the service provision of the CSO by the Consortium?
Consortium: This is yet to be determined, and wont be clear until the Governments
approach to CSO under the Hearing Services program is known but we would expect that
cost of service delivery and service pricing would be explored during due diligence and may
be subject to NDIS pricing models and/or operating terms of reference. In addition, we
would anticipate a continuation of high quality services and the opportunity for service
improvement, providing greater value for money for government, for clients and for the
public.
Deafness Forum: How will the public know it is getting value for money from the
service provision of the CSO by the Consortium?
Consortium: Please refer to question 11, where this response is covered.
Deafness Forum: What performance metrics will be placed on the Consortium
for service delivery?
Consortium: This is yet to be determined, and wont be known until the Governments
approach to CSO under the Hearing Services program is known, but we would expect
performance indicators to be included in the operating terms of reference.
Deafness Forum: How will the government ensure that the value of funding
currently allocated for provision of the CSO will not be diverted away from
audiology and hearing appliance provision and services, to other services within
the Consortium or to other cost centres in the future?
Consortium: At this stage it is simply not possible to address questions relating to if or how
Australian Hearing, in any form of ownership, will address the provision of the CSO
program currently imposed on it by Government. The capacity for Australian Hearing to
effectively deliver services to clients with low incidence but highly specialised needs is
precisely what the Consortium is interested in preserving and extending if the ownership of
Australian Hearing is to move out of government hands.

Deafness Forum: Excluding the NAL, why is a university involved in a


commercial enterprise involving disability service provision and the commercial
production of cochlear implants which is outside of education and research.
Macquaries involvement could solely be with the NAL and totally separate to
the other two members of the Consortium, whilst still maintaining a research
relationship.
Consortium: Clearly, NAL and Australian Hearings service arm are linked for the purposes
of translational research. The collaboration of member organisations at the Australian
Hearing Hub already provides a connection between the three Consortium partners and
other Hearing Hub members. The Consortium would also seek to preserve the important
research relationships between NAL and other service and research organisations.
Deafness Forum: How will RIDBC maintain its charity status if it is operating
with a publicly listed company such as Cochlear?
Consortium: The creation of a strategic alliance between organisations within the hearing
health sector, in a new entity for the delivery of particular services does not inhibit RIDBCs
charity status. Indeed, the important work that RIDBC does, and will continue to do, in a
range of related and unrelated areas will require the continuing contribution of donors and
supporters.
Deafness Forum: Why would people donate to RIDBC as a charity in the future if
it is operating as commercial entity providing services the government
previously supplied? People donate to a charity because the charity fills the gap
in services that the government does not provide
Consortium: There are many precedents for Government services being transitioned to
non-Government management under not-for-profit models. RIDBC would continue to
ensure that gaps in other areas of service delivery (i.e. areas of market failure) are relieved
through our charitably supported service offerings.
Deafness Forum: The inclusion of a notforprofit in the proposal is a potential
soft transition to the full privatisation or eventual absorption into the publicly
listed company of the Consortium, after divestment of Australian hearing by the
government. Would there be any conditions attached to the transfer of
ownership to prevent this from occurring?
Consortium: We see this scenario as not probable or possible, and would expect there
would be operating conditions in place to prevent this.
POTENTIAL CONFLICTS OF INTEREST AND MARKET DOMINANCE
Deafness Forum: Given the interests of the Consortium partners, Australian
Hearing will lose its position of providing independent advice in relation to
educational services and cochlear implant programs.
How will this be managed prior to services becoming contestable? Where will
families go for this advice? How will new referrals be managed under the
Consortium arrangement, particularly referrals from newborn hearing screening
programs?

Consortium: We intend to uphold the important principle of client choice and be


transparent in our pursuit of this for all aspects of service delivery. This would be an area in
which we would expect there to be extensive consultation with a wide range of other
stakeholders in the field.
Deafness Forum: The Consortium, through RIDBC, have clearly listened to the
concerns of consumer groups and providers about the need for a smooth
pathway from newborn hearing screening to diagnostic audiology, hearing
services and early intervention. But inherent in our concerns about timely access
to these services was the rights of parents to have choices and make informed
decisions.
It is not apparent that the Consortium's model of "access to integrated
assessment, diagnostics, hearing aids, cochlear implantation, therapy, education
and additional rehabilitation and support services" is one that understands or
endorses the importance of informed choice on outcomes of deaf and hard of
hearing children. Could the Consortium address how the model they propose will
ensure the principle of informed choice is maintained?
Consortium: We cant at this stage, however, the Consortium intends to uphold and
advocate for the continuation of choice for all stakeholder groups within the hearing
services field. We seek to be transparent in our discussions, in the management of
operations and to uphold the principles of client choice. Please refer also to our response to
question 19.
Deafness Forum: How can parent groups assure parents that their ability to (a)
make informed choices, (b) choose the options that are important to their child
and family, and (c) their ability to change services when they choose, will not be
compromised by the Consortium's integrated model of service delivery across
the lifespan?
Consortium: Please refer to previous responses to questions 19 and 20.
Deafness Forum: Has the Consortium included an assessment of the impact on
business and charitable support on other early intervention hearing service
providers as a result of this proposed business model?
With a vertically integrated business, the Consortium will unlikely refer Early
Intervention services to other providers after initial testing by Australian
Hearing.
Consortium: Again, we seek to uphold client choice and give clients the option to choose
from a selection of stand-alone services or to use services in an integrated manner.
Deafness Forum: Will families be able to access hearing services from Australian
Hearing and early intervention services from an agency other than RIDBC?
Consortium: Absolutely yes. Our model will comprise stand-alone services, as well as an
integrated service offering, so that clients have the option to work with a range of other
service providers/agencies.

Deafness Forum: How will the government prevent the likely loss or
concentration of service provision if other Early Intervention service providers
go out of business as they cannot compete against this large Consortium, losing
choice and diversity as is the aim of the NDIS?
Consortium: There is a real risk of these sorts of changes under an NDIS landscape. We
believe the NDIS gives service providers an opportunity to work together to better meet
client need and fulfil the ambitions of choice and diversity.
Deafness Forum: If hearing services are to be contestable under the NDIS, how
does this proposal ensure the smooth transition from diagnostic audiology to
hearing rehabilitation services? Consumer groups and the Australasian Newborn
Hearing Screening Committee have been of the opinion that Australian Hearing
should remain the sole provider of hearing services for children up to the age of
18 years. However in this model, many of the features of independence, equity
and choice are removed from the model of service provision. As a result, the
model of Australian Hearing that parents and other consumers have valued will
no longer be in place. How will the concerns we have expressed about moving
hearing services to a contestable market be addressed?
Consortium: We are not clear on the Governments approach to this important area of NDIS
management, however, our ambition remains to maintain the best articulated set of
services that can possibly be. We acknowledge these are important issues and want to
work with all stakeholders to provide a comprehensible and clear strategy for everyone
involved in the hearing services field.
Deafness Forum: Australian Hearing holds the only national data set related to
hearing loss in children. The ANHSC have advocated for a national database for
many years and, although a national database is a recommendation of the
National Framework for Neonatal Hearing Screening, this has not been
implemented. How will this proposal ensure the crucial national collection of
data continues? Who will have access to the data? Will the data to be available
for research purposes by researchers outside the Consortium partners?
Consortium: We share the ambition that there should be no loss of integrity of data in
regard to hearing services. Again, should the Government decide not to retain Australian
Hearing, we would seek to work closely with the field to ensure that data continues to be
captured and used to effect, for the benefit of improving services and service delivery
systems across the field.
Deafness Forum: How will other cochlear implant manufacturers have access to
clients if all testing is done by Australian Hearing and there is strong influence
to buy the inhouse Cochlear product?
Consortium: We believe that any tender process would be transparent and appropriate to
ensure the alignment of the right technology with the client need. Australian Hearing would
be run as a separate entity to that of Cochlear Ltd should the Government decide not to
retain Australian Hearing.

Deafness Forum: What will happen if Cochlear decides to become a hearing aid
manufacturer and there is strong influence to buy the inhouse product?
Consortium: Again, we would uphold the principle of client choice and be transparent. As a
core principle, the full range of cochlear implant devices would be available according to
client choice and need.
Deafness Forum: How will other cochlear implant services gain business if the
Consortium does the initial audiology testing, and RIDBC/SCIC and Cochlear are
the majority owners of the audiology testing business?
Consortium: This is a broad issue and we are currently not clear of the approach
Government will take. Again, we expect that the principle of providing choice would apply
at all stages of the hearing loss journey, as well as applying to hearing device options.
Deafness Forum: Is this all part of a CSO transition to NDIS plan, that suits this
proposal/model, to open up paediatric audiology services to all service providers
in the guise of this not being a closed business model and anticompetitive? If so
this would place at risk the future of deaf and hard of hearing children in a vain
attempt to give the air of open competition, with uneducated consumers (new
parents) unwittingly going away from the level of skill, knowledge and
experience in paediatric audiology that Australian Hearing has into an
unregulated system with no registration requirements or paediatric
qualifications. Please advise who will be providing paediatric audiology services
following transition of CSO to NDIS.
Consortium: Under the Consortium approach, Australian Hearing would continue to have an
appropriate transparent recruitment process to ensure the best professionals are engaged.
Deafness Forum: Has consideration been given to the effects on other
universities that provide audiology courses if Macquarie has a dominant position
in the audiology education market as a result of this Consortium as graduates
have a better chance at employment because of the Consortium.
Consortium: Please refer to question 30, where this response is covered.
NAL
Deafness Forum: Will NAL remain part of Australian Hearing or will it be a
separate entity?
Consortium: The Consortium aims to ensure that the important research undertaken by the
National Acoustic Laboratories (NAL), a division of Australian Hearing, will continue and
grow over time. The Consortium intends to support and further develop the work of NAL,
however at this early stage of discussions it is not possible to speculate on any specific
program or funding outcomes. Specific arrangements for existing research contracts will be
considered throughout the due diligence process.
Deafness Forum: Will the research contract with the Department of Health be
transferred to the Consortium? Would there be any changes to that contract?

Consortium: Please refer to question 32, where this response is covered.


Deafness Forum: NAL currently receives a significant amount of its funding
through the Australian Government Hearing Services Community Service
Obligations Program. Will that funding stream continue with the Consortium? If
not, how will NAL be funded in the short and long term?
Consortium: To be determined by Government.
Deafness Forum: The research that NAL undertakes is specified in the Australian
Hearing Services Act 1991. Will those limitations on the scope of research that
NAL can do continue?
Consortium: To be determined by Government.
Deafness Forum: How will the independence of NALs research be protected?
Does the presence of RIDBC as a member of the Consortium present a conflict in
relation to the LOCHI study?
Consortium: Transparency is key, as it currently is in regard to the collaborative
involvement of a range of service providers (including Australian Hearing itself) as members
of the Hearing Cooperative Research Centre.
Deafness Forum: How will research projects be approved?
Consortium: To be determined as part of due diligence.
Deafness Forum: Will the presence of NAL in the Consortium have any impact on
the research undertaken by the Consortium partners?
Consortium: In the same way that industry now intersects with NAL, we would see
members of the Consortium doing likewise. We are already heavily engaged with each
other through the auspices of the Hearing Cooperative Research Centre.
VOUCHER CONTRACT
Deafness Forum: Will Australian Hearings existing Voucher contract (and their
clients) transfer directly to the Consortium?
Consortium: Under the Consortium approach, we anticipate that service provision would
continue uninterrupted to any voucher clients who currently source their service from
Australian Hearing. Of course, the option to choose an alternative provider would also exist,
as is currently the case for these clients.
CSO CONTRACT
Deafness Forum: If the transfer of ownership occurs prior to the introduction of
contestability under the NDIS, will the CSO contract be transferred to the
Consortium? Will there be any changes to that contract particularly in relation to

the client groups and services that are included, or the terms covering access
and quality and other performance indicators?
Consortium: We are not clear of Government approach to the transition of CSO under an
NDIS landscape and whether there would be a preferred contract arrangement or
otherwise.
Deafness Forum: How will the approval of cochlear implant upgrades be
managed given the potential conflict of interest?
Consortium: Key to this process would be transparency and a focus on ensuring separation
between the manufacturer and any policy on the upgrade of cochlear implant processors.
How will CSO service delivery auditing be done in the short and longer term?
Consortium: To be determined. We will seek to make this clear through the due diligence
process.
Deafness Forum: Australian Hearing has a program of continuous improvement
to ensure its clinical protocols and procedures are in line with current
international best practice standards. How will the Consortium ensure that
internal standards and protocols continue to be developed and reviewed so they
are consistent with recommended practice standards?
Consortium: We would agree that such processes should continue and we have a clear
view to see that continuation through Consortium ownership, should Government decide
not to retain Australian Hearing.
OTHER CONTRACTS
Deafness Forum: Will Australian Hearings existing supplier contracts transfer to
Consortium particularly the supply contracts for devices?
Consortium: We would expect so, however, this is yet to be determined by Government.
Deafness Forum: What process will the Consortium use to source devices once
the current major device contract expires?
Consortium: We would expect this would be managed along the lines of current practice,
through a transparent contract negotiation process.
SERVICE LOCATIONS
Deafness Forum: Are there likely to be changes to the location of Australian
Hearing centres particularly those that are in the same location as RIDBC and
SCIC offices, or those in rural and remote areas?
Consortium: We anticipate that our due diligence process would uncover any synergies or
opportunities to provide high quality services from a range of locations, including those in
rural and remote areas.

TECHNICAL SUPPORT
Deafness Forum: Will device repairs including loan devices continue to be
available?
Consortium: Yes.
STAFFING AND MANAGEMENT STRUCTURE
Deafness Forum: How will the transfer of staff be managed? Is there likely to be
a change to the management structure within Australian Hearing? Given there
will be overlap of administrative support services between Australian Hearing
and the Consortium partners, is there potential for efficiencies by combining
these activities?
Consortium: We expect that the due diligence process will allow the Consortium the
opportunity to fully understand the staffing profile and other factors of Australian Hearings
operations in order to develop well considered arrangements for workforce and
organisational transition.
In a competitive NDIS environment, services will need to be provided by highly skilled and
competent staff with expertise across the age spectrum, types of hearing loss and ranging
complexities of clients. These factors will be critical in determining staffing and service
locations.
Deafness Forum: What KPIs will be in place to ensure that administration costs
are kept to a minimum?
Consortium: This is yet to be determined, but we would expect administration costs would
be kept to a minimum and would be subject to performance indicators to be included in the
operating terms of reference.
CLIENT INFORMATION
Deafness Forum: How will client information be managed between Australian
Hearing and the Consortium partners?
Consortium: Any access to, or transfer of, client information will be subject to Australias
privacy legislation and will be managed appropriately in accordance with a transparent due
diligence process.
RIDBC currently has processes in place that promote and facilitate cooperation with a range
of individuals and organisations in the research sector, which could be applied to Australian
Hearing to ensure continuation of world class research.
NEW AREAS OF WORK
Deafness Forum: Will private clients be able to access services from Australian
Hearing as soon as ownership transfers to the Consortium?
Consortium: This is a question for Government.

Deafness Forum: Will Australian Hearing be able to provide services to any child
requiring a hearing assessment? Is there likely to be a charge for this service?
Will families be able to claim this service on Medicare if they have a doctors
referral?
Consortium: This is a question for Government.
Deafness Forum: Will people with a cochlear implant be able to access services
at Australian Hearing? If so, would that be at any location?
Consortium: Yes, it is expected but it will be cochlear implant service dependant.
Deafness Forum: Are there other areas of work that are being considered that
could become part of Australian Hearings service offer?
Consortium: This is captured in other responses above.

Read a brochure published by the consortium


http://www.deafnessforum.org.au/images/pdf/The%20Future%20of%20Hearing%20Services%20for%20all
%20Australians.pdf

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