Report on the regulatory framework for hearing services

Option D - Mainstreaming Hearing Services into the Medicare Benefits schedule

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

Context

Currently the Medicare Benefits Schedule (MBS) includes a number of items relating to audiology. For example:
  • items 11309 to 113210 – audiograms
  • item 10952 – provision of an audiology health service for chronic disease management
  • item 81310 – provision of an audiology health service to a person who is of Aboriginal and Torres Strait Islander descent
  • item 82030 – provision of an audiology service for certain children under 13 (as part of the provision of services relating to autism, pervasive development disorder and disability)
  • item 82035 - provision of an audiology service for certain children under 15 for treatment of a pervasive developmental disorder or eligible disability.

Based on 2012-13 budget fact sheets it is also understood that from 1 November 2012 new diagnostic audiology items will be introduced where an audiologist provides a service directly to a patient who has been referred to them by a specialist. These new items mirror the existing items for diagnostic audiology services being delivered by, or on behalf of, medical practitioners and specialists.

Description of the option

This option would involve ‘mainstreaming’ hearing services into the MBS such that all hearing service items would be listed on the MBS rather than in a separate OHS-specific Schedule.

This would also remove the need for separate legislation and contracts specifically for hearing services providers. Top of Page

The advantages and disadvantages of the option

Significant further work would need to be undertaken before the viability of this option could be determined.

Based on a preliminary consideration of the issues the main advantages of this option are:
  • practitioners would not need to be familiar with parallel systems. The one schedule would describe all service items relating to audiology and audiometry
  • there would be no need for a separate system of service provider accreditation and contracting. The requirements relating to service items could be built into the MBS claiming criteria. If the government had additional requirements of providers this could be achieved through delegated legislation (under the Health Insurance Act 1973) or through entering into an undertaking with practitioners.

There is some precedent for this approach in relation to optometrists. For example, Medicare pays benefits for services provided by optometrists who have signed an agreement with the Commonwealth. This agreement is known as the Common Form of Undertaking – Participating Optometrists. The Undertaking sets out the obligations to be met under the Medicare arrangements with the Commonwealth. For further detail regarding this approach, please refer to the Australian Government Department of Health and Ageing Medicare Benefits Schedule Book - Optometrical Services Schedule – Operating from 1 July 2012. This document includes a copy of the Undertaking.
  • compliance with the requirements of the MBS (claiming criteria) could potentially be overseen by the Professional Service Review (PSR). The PSR is a scheme for reviewing and investigating the provision of services by a health practitioner to determine whether the practitioner has engaged in inappropriate practice in the rendering or initiating of Medicare services or in prescribing under the Pharmaceutical Benefits Scheme. The PSR does not currently have jurisdiction over audiologists and audiometrists (as they are not prescribed practitioners under the Health Insurance Act 1973) but this could potentially be addressed through amendments to that legislation
  • many of the general requirements that apply to Medicare service items could equally apply to hearing services. For example, in relation to record keeping, the standards which determine if a record is adequate and contemporaneous for the purposes of the MBS are already prescribed in the Health Insurance (Professional Services Review) Regulations 1999. Even if this option (i.e. mainstreaming into the MBS) is not preferred it would still be useful to draw on these standards for the reform of the hearing services record keeping requirements.

Rather than identifying disadvantages of this approach it may be more useful to identify potential barriers to the adoption of this approach. Further consideration would need to be given to:
  • whether it is possible to embed client eligibility criteria in the MBS. For example, is it possible to restrict access of the hearing services Medicare service items only to those people who are currently eligible under the hearing services scheme? If this is not possible, this would eliminate this option. In order to confirm whether this was possible, discussions would need to be held with relevant areas of the Department and with legal advisors
  • while the MBS already enables payments to allied health professionals (such as mental health nurses, podiatrists, occupational therapists and social workers) consideration would need to be given to how audiometrists might be recognised under the MBS
  • how this approach would operate with respect to Australian Hearing (a government provider). For example, it may be possible to legislate to enable MBS equivalent amounts to be paid to Australian Hearing providers.

If this approach were viable, considerable negotiation would also be needed with both hearing services practitioners and also MBS advisory bodies.

If hearing services items were to be included on MBS, it is assumed that they would also need to be assessed for inclusion on the MBS by the Medical Services Advisory Committee (MSAC).

The extent of legislative drafting required

If broad policy agreement to this approach were obtained, it is likely that this option would involve:
  • repeal of existing hearing services legislation
  • amendments to the Health Insurance Act 1973 and delegated legislation.

Implementation timeframes

Implementation of this option is likely to take at least 2 years.

Cost implications

There would be significant initial implementation costs associated with:
  • consultation, negotiation and amendments to legislation and agreements
  • changes to the operation of the OHS
  • changes to IT systems and processes (to integrate with MBS)
  • client and industry education
While these up-front costs are likely to be higher than for other options, there is potential for long-term savings. Further consideration would need to be given to the extent of overall cost savings and also the extent to which OHS administrative costs would simply be shifted to Medicare and the PSR.

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