FAQs – Draft Service Provider Contract

FAQs – Draft Service Provider Contract
1. What are the key changes proposed in the new service provider contract?
The key changes in the draft new contract are:
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updated references to relevant legislation,
removal of complexity and prescription in some areas,
a new clause setting out disclosure obligations,
a requirement to participate in the annual self-assessment audit process, and
a revised Hearing Rehabilitation Outcomes document attached as a Schedule to the
draft new contract.
2. What are the key changes in the proposed new Hearing Rehabilitation Outcomes
(HROs)?
Much of the prescriptive detail has been removed from the Hearing Rehabilitation
Outcomes (HROs) document as it is considered unnecessary. Hearing services
practitioners use their professional clinical judgment when delivering program services to
clients and their responsibility in regard to the HROs is to document those decisions for
audit purposes.
3. How will the new clauses about conflict of interest and disclosure work?
This is about fairness and ensuring that the choices a client makes in relation to any fitting
of a hearing device are fully informed. The Hearing Services Rules of Conduct 2012 states
that contracted services providers must provide clients with a choice from a range of types
and styles of approved hearing devices. There continues to be a wide range of hearing
devices available to Program clients on the approved device schedules, noting it is common
business practice to enter preferred supplier arrangements. If there is a preferred supplier
arrangement, this should be made clear to the client at the time.
4. The proposed contract looks very similar to the current contract. Is this the case?
The service provider contract is one document in a suite that governs the administration
and delivery of the Hearing Services Program, and any changes made can have a direct
impact on another. Other Program documents, such as the Hearing Services Rules of
Conduct 2012 for example, are not included in this exercise as they will necessarily form
part of a broader Program reform plan dependant on the outcomes of several Government
activities currently underway. The proposed service provider contract contains a clause
enabling variations to be made during the life of the contract, so that changes can be made
further down the track if necessary.
5. Does the Office have plans to consolidate all of the Program’s governing
documents into a simplified set of rules for clients and providers?
We have aimed to reduce the amount of complexity and prescriptive content as much as
the level of reasonable risk allows, while listening to feedback from service providers to
produce an agreement where, as much as possible, their obligations under the Program are
contained in as few documents as possible. However, at this time, program legislation and
other documents, such as the Hearing Services Rules of Conduct 2012, are not in scope for
Office of Hearing Services
www.hearingservices.gov.au
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[email protected]
this exercise as they must necessarily form part of a broader Program review. Reform of
the regulatory framework may be shaped to a large extent, for example, by the progressive
rollout of the National Disability Insurance Scheme and other deregulation activities. We
anticipate further clarity on these matters over the next 18 months.
6. How has preliminary feedback on the proposed contract renewal been considered
by the Office?
Thank you to those who submitted ideas in response to ‘CSPN 2014/21: Review of the
service provider contract’ late last year. Comments received were about:
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consolidating all Program governing documents into one or two
reduce complexity
review fees
permit electronic signatures
give responsibility to providers for decisions about storage of client records
tighten rules about client relocations
Whilst it may not appear that these comments have been taken on in the proposed service
provider contract, all of these ideas are being considered by the Office across a number of
current projects being undertaken. For example, the Office is developing a policy on
electronic signatures, and is discussing with the National Archives the feasibility of
transferring ownership of client records.
7. What happens if there are changes to the Hearing Services Program during the
term of the proposed new service provider contract?
The proposed service provider contract contains a clause enabling variations to be made
during the life of the contract, so that changes can be incorporated along the way if
necessary.
8. Are there any plans to review the Schedule of Service Items and Fees?
The Schedule of Service Items and Schedule of Fees are not in scope for this exercise as
they may form part of a broader program review in the future. The issues are complex and
require significant liaison with the Department of Human Services, who operate the claiming
system
9. Are there any plans to review client record storage and destruction?
We are currently in discussion with the National Archives regarding this issue. While it will
not be resolved before the commencement date of the new service provider contract, we
will provide updates to contracted service providers should the status of client records
change from the Commonwealth to private ownership.
10. Is the option to provide verbal feedback available?
No. All submissions must be made in writing and submitted via email to
[email protected] by 24 April 2015. Please put ‘Contract renewal’ in the subject line.
11. Can you let me know what other service providers have thought about the
proposed new service provider contract?
Once all feedback has been considered, we will de-identify the information and publish all
comments on the website with a summary of action taken against each.
Office of Hearing Services
www.hearingservices.gov.au
1800 500 726
[email protected]
12. How do I let the Office know if I don’t agree with the proposed service provider
contract?
All submissions must be made in writing and submitted via email to
[email protected] by 24 April 2015. Please put ‘Contract renewal’ in the subject
line.
13. When will the new contract be offered to contracted service providers?
During May 2015 or early June 2015.
14. How long will providers have to sign and return the new contracts?
Contracted service providers will have a reasonable time period to read and consider
the offer, and then sign and return the contract. A due date will be specified when the
offers go out.
15. When does the consultation period close?
At close of business on 24 April 2015.
16. Are extensions available to provide comments after the consultation period
has closed?
In order to have the service provider contract ready to commence on 1 July 2015 it is not
possible to provide any extensions to the consultation period.
(Date of issue: April 2015)
Office of Hearing Services
www.hearingservices.gov.au
1800 500 726
[email protected]