National Relay Service
The National Relay Service (NRS) is a crucial communication bridge enabling deaf, hard of hearing, deafblind and speech impaired people to make ‘telephone’ contact with others.
A coalition of national bodies representing NRS users is deeply concerned that the NRS will have the funding and monitoring mechanisms to continue to provide its crucial services. Read the NRS coalition's views and recommendations to the Government in this consultation paper.
FUTURE OF HEARING SERVICES IN AUSTRALIA
Hearing health and wellbeing a National Health Priority
Hearing health does not 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 1 in every 4 Australians by 2050.
Hearing loss ranks as a major cause of years of healthy life lost due to disability. A 1999 Australian Institute of Health and Welfare study of the burden of disease 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%) is due to excessive noise exposure due to inappropriate listening behaviours. Educational expenditure on prevention of hearing loss could be effective in reducing the projected increase in prevalence.
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.
Importantly, given that a significant component of hearing loss is in fact preventable, there is a clear argument for identification of hearing loss as a National Health Priority; and for a cross-jurisdictional approach to awareness, prevention, and remediation of 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 has nine National Health Priorities Areas such as obesity and asthma - hearing should become a Priority too
- this will raise public profile, education, prevention, supports, and research to direct smart, integrated government policy
Read our submission to the Government on why hearing heath and wellbeing must become a national priority. Download it here
Hearing services in the National Disability Insurance Scheme
The Australian parliament is examining hearing services under the National Disability Insurance Scheme (NDIS).
Current issues of concern are explored in two submissions that Deafness Forum had prepared:
- submission to a parliamentary inquiry into hearing services within the NDIS. Download it here
- submisison to the Productivity Commission regarding costs of hearing services in the NDIS. Download it here
The issue of eligibility
Reports from consumers indicate there has not been a consistent approach to providing access to the NDIS for people with hearing disability across Australia, so clear guidelines are needed for those who do the assessments for eligibility.
Some consumers and clinicians have been advised that eligibility for the NDIS is dependent on the person’s average hearing threshold level. Eligibility for the NDIS should not be based on hearing threshold levels alone. This measure does not provide any information on the impact of the hearing loss on a person’s ability to undertake activities, or participate in employment or socially. An average hearing threshold level can be misleading if viewed in isolation, especially if the person has other disability. Deafness Forum of Australia supports the holistic approach taken by the NDIS to determine eligibility for the Scheme which is based on the WHO International Classification of Functioning, Disability and Health, and would be concerned if this was replaced by an average hearing threshold level for people with hearing loss.
Concern has been expressed about the ongoing provision of services to people who are not eligible for the NDIS.It is not 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 e.g., children who require hearing assessment services.
There will still be people who will miss out on government funded hearing services. People whose hearing loss is not 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 e.g., unemployed people, people in part time employment or those with low paying positions will still have to fund their own hearing services. They generally cannot 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 do not qualify for any funded supports.
Issues relating to 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 will not 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
Deafness Forum of Australia notes 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 followup 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 do not 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, Deafness Forum believes that audiologists would prefer to be rewarded for their expertise and the results they achieve for their clients.
Deafness Forum supports 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 10 older Australians have hearing loss, but the staff of age care service providers and in hospitals are seldom adequately trained to assist.
It is 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.
Instructional video (link is external) on Youtube (also available on Vimeo (link is external))
Good Practice Guide
These resources may also be useful for carers and volunteers who assist hearing impaired people in the community.
Follow this link
Medical Benefits Scheme
Medicare benefits are payable for professional health services. A professional service is a clinically relevant service which is listed on the MBS. A medical service is clinically relevant if it is generally accepted in the medical profession as necessary for the appropriate treatment of the patient.
The audiology items require a review by the Government to bring them into line with current clinical practice. This includes the need for a review of the rules that apply to existing items and the inclusion of additional items to cover new diagnostic procedures.
Some of the rules governing the Medical Benefits Scheme in relation to referrals to and from audiologists require review in order to make the system more efficient. This change if implemented would result in it being more patient focussed.
It would be reassuring for consumers to know that the Medical Benefits Scheme items were based on evidence based practice guidelines and were regularly updated to reflect current practice recommendations. This would eliminate the risk of their practitioner providing an MBS approved service that had been superceded due to new evidence or an updated procedure.
Poor quality automated online captions
Deafness Forum is part of a group of not for profit organisations representing people who rely on captions for information, which draws attention to the growing issue of inaccessibility of online audio/visual content.
We are concerned that while there is an increasing amount of web video content being auto-captioned, the vast majority of these captioned videos are not being reviewed for accuracy, readability or comprehensibility.
In the same way that any text document published online is reviewed and edited for accuracy, captioned content needs to be reviewed and edited for accuracy, readability and comprehensibility before being published on the web.
A survey of Australian Government-associated websites found that a wide range of problems exists, ranging from video with no captions, video captions with minor misspellings and videos with completely incomprehensible captions. Access to government information and services, political party policies and parliamentary member’s communications is an integral aspect of our democratic society. When inaccurate captions bar access to this information people who rely on captions are at risk of being excluded from full economic, social and political participation.
Life threatening danger to children posed by button batteries
Severe health complications can develop within two hours if a young child was to swallow a coin lithium battery, such as those used in hearing aids and a range of other products.
If it is not removed promptly, death could result within 24 hours.
Most instances occurred where children removed the battery from a device or the battery was left unsecured.
Nearly 10 percent of injuries to children under the age of four involved batteries associated with hearing aids.
Deafness Forum of Australia calls on its members, other advocates, and professional and industry associations in the hearing health sector to champion the message to the community.
Willing to Work: National Inquiry into Employment Discrimination Against Older Australians and Australians with Disability
The 'Willing to Work' inquiry, conducted by the Age and Disability Discrimination Commission exaimned obstacles faced by, and discrimination against, older persons and persons with disabilities in actively participating in the workforce
Deafness Forum of Australia highlighted that taking into account Australia’s looming workforce challenges, it was critical that all people with disability and businesses be placed at the centre of a new employment framework to ensure that people with disability were not left behind.
Deafness Forum made the point that the Australian Public Service is not the leader and exemplar it could and should be.
We explained that people who want to participate in the labour force and have hearing loss or are Deaf face challenges that are unfamiliar to most of their hearing peers: for some, the barriers become evident, start at or before the process of searching for work and, for many, they become more acute during the selection process or at work. A loss of hearing can also lead people to exit the labour force sooner than they would like to, and before their intended age of retirement. As a result, there is a hidden loss to national productivity. The problem may be worse than currently perceived. There is, we believe a significant under-reporting of disability amongst people who are hearing impaired or have a chronic disorder of the ear.
The Government's Employment Assistance Fund (EAF) was established to "...help people with disability and mental health conditions by providing financial assistance to purchase a range of work related modifications and services for people who are about to start a job or who are currently working, as well as those who require assistance to find and prepare for work." It is an excellent program of government. It can continue to optimise the return on tax-payer investment by keeping in step with evolving workplace realities. In this respect, here are our recommendations.
A generic EAF assessment to people with a disability before they commence or seek employment. Their 'passport' would provide access to the EAF and any workplace-specific modifications could then be more readily accessed as add-ons or via a short form application process. For example, in the case of a person who is hearing impaired or Deaf, the generic EAF assessment could cover standard communication related modifications and so on, with any specific requirements for a workplace to be accessed separately as and when required.
The EAF needs to be more flexible and able to meet other work-related requirements of recipients. For example, more emphasis needs to be placed on supporting the needs of employees at informal and social functions within their workplace as these are often crucial to forming productive networks with colleagues and enabling access to future career progression opportunities.
The EAF needs to be expanded to become accessible to people who are hearing impaired or Deaf who wish to undertake volunteer or community work as a way of enhancing their skills and experience and making them more employable in the future.
Tailored to suit the need
Provision of increased EAF support funding for applicants who are promoted to management positions to ensure that there are no artificial caps that restrict the career advancement opportunities.
More sensory disability awareness training provided to EAF consultants, so they fully understand and appreciate the barriers faced by people who are hearing impaired or Deaf.
A national, ongoing strategy to engender greater awareness by employers of the entitlements of individual employees under the EAF program.
An up-to-date knowledge bank of the main examples of EAF workplace modifications.
An up-to-date survey undertaken of employers and employees that will lead to published data on the level of public awareness of the EAF and its functions.
Tax advantages for employers who supplement an EAF entitlement from company funds to ensure individuals do not miss out on meetings, training and other opportunities that hearing colleagues are afforded.
National Practice Standards for Audiology
The Office of Hearing Services (part of the federal Health Department) is developing national practice standards in Audiology.
The process is supported by an Audiology Expert Reference Group. Deafness Forum of Australia is a member of the Expert Reference Group.
The objective is for the voluntary standards to reflect nationally agreed practice expectations of those working in the hearing services sector. The standards will:
- Be applicable to all professions involved in hearing services in Australia
- Encompass all client populations and practitioner types
- Be up to date, evidence based and relevant to the needs of all key stakeholders in the hearing services sector including clients, practitioners, families, carers and funders
- Be endorsed and owned by the hearing sector
- Be measurable by third parties if required
On-demand, real time captions and interpreters in Government shopfronts
Deafness Forum has advocated since early 2012 the need for on-demand captions and Auslan interpreting services to improve customers’ interactions at Australian Government service shopfronts, such as Centrelink, Medicare and NDIS offices, etc.
The current communication arrangements in most government shopfronts are inconsistent, time-consuming for all involved, and the source of tension and misunderstandings for both customers and staff. People with hearing devices rely on hearing loops, but these are not always present, may not function properly or are not switched on. People whose preferred communication is Australian Sign Language require access to interpreters via video links.
Our objective is that all Government shopfronts should provide designated facilities that provide equitable communication access.
Inclusion in education
All children in Australia have the right to an inclusive education. However, there are many barriers to the realisation of this right in the lived experience of children and families. Teaching and acquiring literacy is vital for children with reduced hearing acuity and those whose native language is Australian Sign Language.
Literacy is the ability to read, write and to apply critical thinking skills to the written word. It is recognised that some students with disability have positive education experiences with good academic and social outcomes, but this is by far the exception.
The breadth of disadvantage that students with disability must contend with in the current education system is profound. A typical school experience for students with disability involves discrimination, limited or no funding for support and resources, inadequately trained staff, a systemic culture of low expectations, exclusion and bullying
Despite the high value and strong evidence base linking educational attainment and improved life outcomes, students with hearing disability are frequently denied educational opportunities.
Unwelcome change to Veterans’ hearing health entitlements
Australians who live with a hearing loss as a result of their military service have lost their right in civilian life to receive a proper level of hearing services.
As a result of a review of military compensation arrangements, Veterans with long term hearing needs have been switched to a Repatriation Health Card.
The White Specific Treatment card, as it is known, was intended to streamline services and payments, however it also introduced changes to the level of hearing aid technology that a Veteran could receive without payment.
Until recently, eligible Veterans could receive aids to suit their individual hearing needs.
Now that these Veterans have been issued with a White Specific Treatment Card they receive their hearing services under the Australian Government Hearing Services Program. Under this Program, Veterans receive only a base-level hearing aid at no cost. To access the correct level of technology to suit their individual hearing needs they must now make a personal payment to bridge the gap.
Veterans have told Deafness Forum of Australia they were not consulted or informed of the changes in the level of hearing devices they would receive when they were issued with the White Specific Treatment Card.
While Veterans who volunteered to defend their country have lost their entitlement, government employees and contractors will continue to receive fully funded top up hearing aids under Comcare arrangements.
Deafness Forum of Australia believes it is an administrative oversight: at odds with the Government's regard for defence personnel and a matter that can be readily rectified.
An issue of interest is the captioning quota in place for Subscription Television, which is based on platform (Foxtel, Fetch, etc), not individual channels. These channels do not have a specific common quota.
Our view, and that of Deaf Australia and other advocacy organisations are as follows:
- Free to Air channels must be 100% captioned 24 hours a day (currently 0600 to 2400).
- Multi-channel platforms (ABC2, 7Mate, etc.) must caption their programs to the same standard as Free to Air channels. Many programs bought from overseas for the purpose of multi-channel screenings arrive already captioned but these captions are not displayed in Australia.
- Subscription Television - each channel must have a common, minimum captioning quota.
- Captioning quality standards - the current “readability, comprehensibility and accuracy, so that they are meaningful to viewers” standard is subjective. Captioning quality standards should be metric based.
Hearing care for hospital patients
Enrolled Nurses are employed in a wide range of nursing fields and can be influential in recognising the needs of people in their care who are Deaf or live with a hearing difficulty.
Enrolled Nurses are trained to take part in hospital admission and discharge procedures and, with a knowledge of communication access assistance, would be well placed to contribute to reducing stress on vulnerable patients.
Deafness Forum made key recommendations to a review of the curriculum for the Diploma in Nursing for Enrolled Nurses.
Communication access needs to be adequately identified in appropriate parts of the curriculum.
Communication access needs to be presented as an integral part of nursing care, particularly for our increasing elderly community.
There is a crucial need for Enrolled Nurses to be equipped to support and oversee implementation and maintenance of communication access in residential and in-home care as well as in hospital settings.
Enrolled Nurses would be well placed to ensure that patients' hearing aids or alternative listening devices are used and cared for while in hospital.
A proposed change to the Australian Building Codes with the aim of reducing false alarms resulting in unnecessary Fire Brigade attendances was opposed by Deafness Forum of Australia.
The change would have meant that some buildings, such as hotels would no longer require installation of monitored smoke detectors.
While the aim is worthwhile, the solution was ill-informed. An unforseen effect would be a significant increase in the risk of a sleeping occupant being unaware of the presence of a smouldering fire. A Deaf or hearing impaired person could be overcome by smoke and fumes before the heat detector or the sprinkler system were activated.
Deafness Forum of Australia, AFAC representing the various Fire Brigades, the Australian Protection Association of Australia and Standards Australia advised that the benefit would be outweighed by dangers to personal safety.
As a result, the proposal to change the Building Code of Australia to install smoke alarms in place of smoke detectors was withdrawn. The current requirements will remain in force.
Safe and accessible accommodation
Hotels, motels, and serviced apartments should provide communication access facilities that:
- Ensure appropriate rules are in place to ensure that all guests and staff will be alerted to any danger, and to any drill or system test
- Have guest registration cards that include a section “If you are likely to have any difficulty hearing alarms, or evacuating the building in the event of an alarm, please tick this box”
- Provide a telephone with built in or clip on amplifier, telecoil coupler and flashing light alert
- Provide a television capable of accessing captioning
- Provide a portable non-audible door alarm
- Provide a vibrating alarm clock
- Provide meeting rooms with functioning assistive listening systems
Replacement speech processors for pensioners aged over 26 years
Age and Disability Pensioners who have cochlear implants and are eligible for the Australian Government's Hearing Services Program are denied the appropriate, reliable technology through the Government which they depend on for social inclusion, productivity, independence and quality of life.
These ”Eligible Persons” under the Hearing Services Administration Act 1997, are not provided with replacement cochlear speech processors. However, people who use hearing aids as their means of amplification are (quite correctly) provided with replacements and upgrades to their hearing aids as required.
This inconsistency impacts the most significantly impaired and financially vulnerable cochlear implant recipient group. It can be readily addressed at little cost to Government.
The Government does provide replacement and upgraded cochlear speech processors for people under the age of 26
Our understanding is the planned transfer of parts of the Australian Government's Hearing Services Program to the National Disability Insurance Scheme will resolve the matter for people who are eligible to enter the Scheme. This may take several years to be put in place.
Deaf culture is rich in language, the arts and community
We must take action to improve access to Auslan for Deaf children in infancy, support hearing families in their efforts to learn it, expect educational institutions to embrace Auslan as a first language for Deaf children, and promote it as a valuable second language for teaching in schools to hearing children. Literacy is not just the ability to read and write, but to apply critical thinking to the written word. Teaching and acquiring literacy to prepare for a competitive employment market is vital. Quality education in the early years is key to optimising an individual's inherent, unique potential.
The Government can implement:
- Provision of information to new parents (and ongoing support) about the benefits of introducing Deaf children to Auslan
- Elective study of Auslan in school curricula
- Government and business shopfronts, health and welfare services to provide real-time Auslan interpreting and captioning services for customers, which would have flow-on effect to corporate Australia
- Inclusion of Auslan and captions in electronic government communications, which would set the standard for commercial businesses
A viable, accredited Auslan interpreting and captioning service sector is crucial. There are established Australian companies that can provide these services, both on-site and remotely via the internet. However, there is a shortage of qualified interpreters. Captioning, a growing service industry, would benefit from professional development programs and standards.
Fair and equitable access to justice
Equality and justice will not be served until all participants in a court’s proceedings know every word that is spoken by every other participant.
Our members believe that federal, state and territory Attorneys-General should put in place programs that will ensure full and equitable communication access to all courts in Australia for people who have a hearing impairment or are Deaf, using their preferred methods of communication.
All courtrooms should have consistently functioning hearing loops and be responsive to needs to provide appropriately qualified and certified Australian Sign Language interpreters.