Australian Government - Department of Health - Office of Hearing Services
Hearing Services Program

Evidence Guide for Compliance Monitoring

To ensure compliance with program requirements, risk based audits and claims reviews are routinely performed. This guide provides an overview of the evidence reviewed during these compliance monitoring activities, and supports the principles of openness, transparency and consistency.

Record Keeping
Sites and Equipment
Service Management Systems
Service Provision
Evidence Reviewed on Clients files for Compliance Monitoring
Common Mistakes and Issues


The Hearing Services Program (the program) is governed by a range of legislative instruments, contractual arrangements and program standards, listed below. Collectively, these are the program requirements.

  • Hearing Services Administration Act 1997
  • Hearing Services Rules of Conduct 2012 (the Rules)
  • Hearing Services (Participants in the Voucher System) Determination 1997
  • Hearing Services Voucher Rules 1997
  • Hearing Services (Eligible Persons) Determination 1997
  • Hearing Services Providers Accreditation Scheme 1997
  • Australian Hearing Services Act 1991
  • Declared Hearing Services Determination 1997
  • Hearing Services Program Service Provider Contract 2018-2019 (the Contract)
  • Schedule of Services Items and Schedule of Fees
  • Hearing Rehabilitation Outcomes (HRO)
  • Minimum Hearing Loss Threshold (MHLT)
  • Eligibility Criteria for Refitting (ECR)

The program approach to compliance monitoring and support is outlined in the Compliance  Monitoring and Support Framework. To ensure compliance with program requirements, risk based audits and claims reviews are routinely performed. This guide provides an overview of the evidence reviewed during these compliance monitoring activities, and supports the principles of openness, transparency and consistency. Providers should register for the RSS Feed to ensure they are kept up to date with program changes and news.

The guide is divided into five core areas

  1. Record Keeping outlines the requirements for ensuring records are compliant with program requirements. Record keeping is a key component for all areas of compliance monitoring.
  2. Sites and Equipment outlines the evidence reviewed to ensure sites and equipment are compliant with program requirements, including ambient noise level certification, equipment calibration certification, insurances and provider information held on the portal.
  3. Service Management Systems outlines the evidence reviewed to ensure that service management systems are compliant with program requirements, including requirements for policies, procedures and disclosures.
  4. Service Provision outlines the evidence reviewed to ensure that services are provided in compliance with program requirements, particularly the Schedule of Service Items.
  5. Claiming outlines the evidence reviewed to ensure claims are compliant with program requirements, including client records, claim forms and online portal information.

Please note this is a guide only. Other information may be requested to assess program compliance. A review of previous Self Assessment Tool (SAT) responses is also undertaken to confirm SAT responses align with audit findings.

Specific evidence reviewed for the program requirements are outlined in Attachment A.  Common mistakes and issues identified during compliance monitoring are outlined in Attachment B. 

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Record Keeping

The Contract (Clause 1.1) states that records include any information about clients which the provider creates or maintains for the purposes of the program (and includes data or documents including paper, hard drives, USB flash drives, discs, tape or other articles/materials).

Program Requirements

  • All records and record copies belong to the Commonwealth (Contract Clause 4.1 (g), Archives Act 1983 (Cth) Section 3)
  • Records must be kept for at least seven years from creation or from any amendment to the record (client file). (Contract Clause 4.2, Rules of Conduct 7(2b))
  • Providers have responsibility for the protection of client’s personal information and must not disclose records without the prior written approval of the Commonwealth. (Contract Clauses 19 & 20)
  • All information provided to the Commonwealth must be correct, complete and not misleading in any respect.  (Contract Clause 7.2(a))
  • Providers must make and maintain a comprehensive, accurate, current, easily identifiable and accessible record for each program client. (Rules of Conduct 7)
  • Providers must allow access to program client records to ensure compliance with the Contract. (Rules of Conduct 7(3))
  • Providers must forward relocating client records (complete original file and copies of the original claim forms) to the new provider when they receive a written file transfer request. The old provider must keep the original claim forms for at least 7 years after transfer. (Rules of Conduct 12)
  • Providers using Cloud storage must ensure they are using an Australian Signals Directorate (ASD) certified Cloud service, or must have their Cloud service assessed by an independent Information Security Registered Assessors Program (IRAP) assessor. Refer ASD website. All records must be hosted on an Australian server.

Evidence Reviewed

  • Partially-subsidised device quotations
  • Medical referrals and reports
  • Claim forms
  • Other relevant client information
  • Statutory Declarations and manufacturer’s letters for lost/damaged devices Appointment records
  • WANT forms for clients with 3FAHLs ≤23dB
  • Audiograms, SPIN tests, REM, etc.
  • Client files and case notes
  • NOAH data (where available)

Common Record Keeping-Non-Compliance Issues

  • Incomplete or illegible file notes
  • Insufficient detail to clearly demonstrate that all the requirements of a service were met
  • Incomplete forms (e.g. Unsigned and undated documentation)
  • Out-dated forms being used (e.g. superseded ECR being used)
  • Statutory declarations on the wrong form or not correctly completed
  • Conflicting information (e.g. Inconsistent dates on claim forms, appointment books, file notes and NOAH data.

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Sites and Equipment

Program Requirements


  • Sites must provide an appropriate and safe environment for providing services. (Contract 7.1(c) & 10.3)
  • Sites must have appropriate equipment and facilities for providing services, including audiometric testing equipment for assessment, fitting and rehabilitation. (Contract 10.5)
  • The Hearing Services Rights and Responsibilities information must be displayed at each site. (Contract 10.6)
  • Providers must open and close sites through the online portal, and indicate whether the site is permanent, remote or visiting. (Contract 10.1)
  • Providers must update site details on the portal if there are changes. (Contract 10.2)


The provider must maintain

  • public liability insurance for no less than $10 million per claim
  • professional indemnity insurance for no less than $1 million per claim covering all practitioners
  • workers' compensation insurance as required by law for the Contract period (and  for  professional indemnity insurance, for at least seven (7) years after the expiry or termination of the Contract. (Contract 23.1)

Evidence Reviewed

  • Ambient noise level certification
  • Equipment calibration certification
  • Provider details on the Hearing Services Portal
  • Insurance certificates of currency
  • Previous SAT responses on sites and equipment, for example that certification was up to date and that the client rights and responsibilities poster is on display

Common 'Sites and Equipment' Non-Compliance Issues

  • Missing or incomplete documentation
  • Incorrect or out-dated Standards used for certification of ambient noise levels or equipment calibration
  • Certification that does not meet the requirements of the Standard
  • Hearing Services Portal not updated with current provider and/or site information.
  • Providers not removing old employees as users of the portal

Evidence found in compliance monitoring doesn’t match the responses to the provider’s Self-assessment

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Service Management Systems

Providers are required to have specific policies and procedures to support program compliance.

Program Requirements

  • Clinical personnel hold appropriate professional qualifications & Practitioner Professional Body (PPB) membership. (Rules of Conduct Part 4, Contract Clause 5.1(c))
  • Services are provided to a high standard in accordance with professional standards of conduct for hearing service delivery published by the relevant Practitioner Professional Bodies. (Contract  Clause 5.1(e))
  • Services are provided in a safe and appropriate manner and environment. (Contract  Clause  5.1(f))
  • Any preferred supplier relationships are disclosed to clients. (Contract Clause 30)

Hearing Rehabilitation Outcomes (HRO)

  • Clients are referred to a medical practitioner where clinically appropriate. (HRO 2)
  • Audiometrists must liaise with an audiologist about the management of non-routine clients (refer HRO Glossary) or refer such clients to a medical practitioner for assessment. (HRO 2)
  • Internal policies and procedures are established to support service delivery and compliance with program obligations. (HRO 7)
  • Service delivery is continuously monitored and improved. (HRO 7)
  • Staff are aware of, and have access to, current versions of policies, procedures, instructions, documents or forms relevant to the requirements of the program. (HRO 7)
  • A policy for dealing with complaints/disputes is maintained and available to all clients. (HRO 7)
  • Reasonable steps are taken to try to resolve any client complaint. (Rules of Conduct Rule 9)
  • Compliance with the HROs is periodically reviewed and non-compliance is remedied. (HRO 7)

Evidence Reviewed

  • Practitioner Professional Body membership certificates
  • Policy and Supervision of Non-Qualified Practitioners
  • Preferred Provider Relationship Disclosure
  • Certificates of Competency for all practitioners
  • Policy for referral of clients for further advice (Medical/Audiological Referral
  • Complaints Policy

Common 'Service Management Systems' Non-Compliance Issues

  • PPB certificates not available for all staff providing services during the audit period.
  • No policy for the supervision of non-qualified practitioners.
  • Evidence that non-qualified practitioners are delivering services without the supervision of a qualified practitioner.
  • No complaints policy in place and/or not made available to clients.
  • No disclosure of preferred supplier relationships to clients.
  • No clear process for the referral of clients for further medical/audiological advice.
  • Clients not being referred as required by the referral policy, for example non-routine clients.

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Service Provision

Providers must comply with

  • the Hearing Rehabilitation Outcomes (HRO), which describe the outcomes to be achieved when delivering services to eligible clients.
  • the Eligibility Criteria for Refitting (ECR), which outline the six circumstances where it is acceptable to refit a client under the program.
  • the Minimum Hearing Loss Threshold (MHLT), where clients whose 3 Frequency Average Hearing Loss (3FAHL) is less than or equal to 23 dB in the ear being fitted, cannot proceed to fitting or receive an Alternate Listening Device unless the client meets the two MHLT exemption criteria. One of the criteria is the Wishes & Needs Tool (WANT). The other criterion lists four conditions, one of which must be met. (Hearing Services (Participants in the Voucher System) Determination 1997). 
  • the Schedule of Service Items, which outline the conditions which must be met in order to claim the service/s.

Program Requirements

  • A valid voucher must be held before services are provided under the program.
  • Services must be provided in accordance with the Act, the Rules of Conduct, the Contract and  the Standards. (Contract Clause 5.1)
  • Services must meet their purpose, be complete and be performed in compliance with program requirements. (Contract 7)
  • A relocation request must be received from a client before requesting transfer of their records. (Rules of Conduct 12). Where this request is verbal, it must be documented on the client file.
  • Complex Clients must be notified via the portal and the client given information on services available from Australian Hearing Services (AH). (Rules of Conduct 14)
  • Clients requiring devices must be offered a range of types and styles of fully-subsidised (free-to-client) devices suitable to their needs, prior to fitting. (Rules of Conduct 16)
  • Clients considering partially-subsidised devices must be given a detailed, partially-subsidised (top-up) device quote. (Rules of Conduct 17(2))

Evidence Reviewed

  • Client records
  • Evidence of ECR being met
  • Partially-subsidised device quotes
  • Portal claims records
  • NOAH data
  • Evidence of MHLT exemptions
  • WANT forms
  • Medical certification

Common 'Service Provision' Non-Compliance Issues

  • Insufficient evidence on client files to substantiate program service requirements.
  • Clients fitted with devices when they do not meet the MHLT exemption criteria.
  • Clients refit with new devices when they do not meet the Eligibility Criteria for Refitting.
  • Missing or incomplete partially-subsidised (top-up) device quotes.
  • Clients not notified as specialist (complex) through the hearing service portal.
  • Clients provided with ‘private services’ when they are eligible for services through the program.

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The Schedule of Service Items outlines the conditions required for service delivery and claiming.

The Schedule of Fees outlines the fees paid for services delivery in line with the conditions for claiming documented in the Schedule of Service Items.

Program Requirements

  • Each client must have a valid voucher. (Contract Clause 11.9)
  • Claims for payment must comply with the Contract and Schedule of Service Items (Contract  Clause 11.1)
  • Client records must support and justify all claims for payment. (Contract Clause 11.4)
  • Providers must check that any services required by the client have not already been provided under the Voucher. (Contract Clause 11.9)
  • All claiming information provided to the Commonwealth must be correct, complete and not misleading. (Contract Clause 7.2(a))
  • Claim forms must be signed by either the client or their representative (relationship must be specified on the claim form and in the client’s file). (Contract Clause 11.6)
  • Claim forms must show the QP number of the practitioner who completed or supervised the services. (Contract Clause 11.8(b))
  • E-claims for relocated clients must be submitted within 28 days of receiving a transfer request. (Contract Clause 11.3)
  • Clients cannot be charged for services other than partially-subsidised devices, replacement fees or annual maintenance. (Rules of Conduct 28)
  • All original claim forms must be kept for seven years. (Contract Clause 11.12)
  • Payments received for services not provided in accordance with program requirements must be reimbursed to the Commonwealth. (Contract Clause 12)

Evidence Reviewed

  • Client Records
  • Claim Forms
  • Appointment records
  • NOAH data
  • Audiograms and other assessment records

Common 'Claiming' Non-Compliance Issues

  • Vouchers not valid at the date of service.
  • Incomplete or missing medical certification for the issuing of a voucher.
  • Binaural services being claimed when the client is monaurally fitted.
  • Claim forms missing or not signed.
  • Incorrect dates, devices, services, practitioner number, client costs and/or 3FAHL results recorded on claim forms or in the Hearing Services Portal.
  • Hearing Services Portal showing different information than the claim form, for different 3FAHLs, dates of service etc.
  • Claims for services already provided on the client’s voucher.
  • Duplicate claims being submitted, for example via e-claims and the Hearing Services Portal.

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Evidence Reviewed on Client’s files for Compliance Monitoring

Client Records
Assessment (600) / Reassessment (800)
Audiological Case Management (610/810)
Fitting and Follow-up Services
Client Reviews (930/940)
Refitting Services
Spare Aids
Remote Controls (Item 4)

Evidence Reviewed – Client Records

Client records

Client records should include

The Rules of Conduct (7) state that client records must be comprehensive, accurate, current, easily identifiable and accessible, and kept for at least 7 years.

File notes must be legible (readable and accessible).

Any Cloud storage system must be Australian Signals Directorate (ASD) certified and records must be hosted on an Australian server (Refer ASD website).

  • Client details name, voucher number (check the portal for client’s eligibility)
  • Relocation form / file request signed by client (if relocating client)
  • Fully completed medical certification with contraindications to fitting noted (Y/N)
  • Detailed and dated case notes for all appointments, visits, phone calls etc. including the clinician's name
  • Audiograms, test results (REIG, REM, SPIN etc.)
  • Record of client’s clinical / audiometric history
  • Record of client’s needs and goals (COSI etc.)
  • Record of client’s attitude and motivation regarding a fitting
  • Wishes & Needs Tool (WANT) for clients under MHLT (3FAHL ≤ 23dB)
  • Statutory declaration for lost device/s stating when and where device/s lost
  • Manufacturer’s letter for devices damaged beyond repair (DBR)
  • Medical referrals and responses
  • Partially-subsidised device quotations
  • Claim forms signed and dated by client and provider
  • Copy of receipts for client payments e.g. maintenance, partially-subsidised device payments
  • Other relevant client information

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Evidence Reviewed – Claiming


Evidence to support program claims includes

Clause 7.2 (a) of the Contract requires providers to warrant that all information that has been, or will be, provided to the Commonwealth, is or will be, correct, complete and not misleading in any respect.

Clause 11.1 of the Contract requires that the provider must not make claims for payment of Scheduled Fees unless the provider complies with the Contract (including the Schedule of Service Items).

Clause 11.4 of the Contract states that providers must at all times, maintain records that support and justify all claims for payment.

  • Evidence of appointment (diary entry/appointment dates of client’s visit)
  • Detailed and dated client case notes documenting services provided
  • Copies of test results (audiograms, NOAH data, REMs, WANTs, etc.)
  • Correctly completed claim form, signed and dated by client, including client’s name & voucher number, claim details (item numbers &  costs), date of service, 3FAHL results, site identification, QP number, etc.
  • If claim form is signed by client’s representative, the relationship to the client must be specified on the claim form and noted on the client file.
  • Alterations to claim forms must be initialled by client where relevant.
  • Statutory Declarations must be completed in the name of the person signing the declaration. (I declare, NAME – signature SAME NAME)

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Evidence Reviewed – Assessments


Case Notes

Assessment(Item #600)

Reassessment(Item #800)


  • an accurate and complete assessment by a qualified practitioner or a provisional practitioner under supervision.
  • clients to be supported in making decisions including receiving advice about communication strategies, rehab programs, and technological and device options.

Refer to the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 1 Assessment
  • HRO 2 Referrals
HRO 3 Hearing Rehabilitation
Rules of Conduct

Rule 16 - Choice of hearing device - requires the client to be offered a choice of free of charge devices, and that written evidence of the client’s choice must be kept on file.

Rule 17(1) Top-up devices - states that a provider must not encourage a voucher-holder to select a top-up device when a free of charge device would reasonably meet the client’s hearing rehabilitation needs.

Rule 17(2) Top-up devices - states that the provider must not supply a partially-subsidised device to a client unless a written quote which includes the full price, model, style, and maintenance and repair costs information is provided and signed by the client.  A copy of the quote must be kept on file.

Rule 17(4) Top-up devices - states that if a provider fails to abide by Rule 17 and a voucher holder buys a top-up device as a consequence, the provider may be required to refund all charges to the client.

Evidence in client’s case notes to support an assessment/reassessment claim should include
  • Practitioner (& supervisor’s) name & date of service
  • Reason for hearing test (hearing issues at home, with telephone etc.)
  • Family/Occupational history (exposure to noise etc.)
  • Previous audiological history (tinnitus, vertigo, wax problems, etc.).
  • Hearing device history (previous aids)
  • Medical conditions/disabilities (ear infections, dexterity issues etc.)
Attitude, goals and expectations
  • Attitude to their hearing loss (client’s own attitude, family’s attitude)
  • Attitude to hearing aids
  • Hearing goals and expectations (e.g. COSI)
  • Visual otoscopy – (canals, blockages, wax build-up, etc)
  • Audiogram (copy on client file showing date, 3FAHLS results etc.)
  • Speech testing
  • Wishes & Needs Tool (WANT) and evidence supporting Minimum Hearing Loss Threshold (MHLT) criteria if 3FAHL results ≤ 23dB
  • other tests as appropriate.
  • Referral to medical practitioner where clinically appropriate
  • Non-routine clients assessed by an audiologist, or referred to an audiologist or medical practitioner
  • If complex, client advised about Australian Hearing’s services & notified via portal. File note recording client’s chosen provider.
  • Discussion on communication strategies and rehabilitation programs
  • Discussion details on suitable device options ( type, style, telecoil, etc).
  • Details of fully-subsidised device/s recommended
  • Written quotation if partially-subsidised devices (Top-Ups) are to be fitted (even if no cost to client), signed & dated by client prior to fitting, including
    • make and model of device(s)
    • full price of device(s), identifying government subsidy and cost to client annual batteries and maintenance and repair costs

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Evidence Reviewed – Audiological Case Assessment

Audiological Case Management (referral)

Evidence in client’s case notes

Audiological Case Management (referral)

with first assessment (Item #610)

with reassessment - on Return voucher (Item #810)


  • clients to be referred for medical evaluation where appropriate
  • audiometrists to liaise with an audiologist about the management of non-routine clients
  • audiologists to complete extra tests before referring their own client to a medical practitioner

Refer the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 2 Referrals
  • HRO Glossary
Evidence in client’s case notes for an Audiological Case Management claim should include
  • Documented assessment of client’s condition, justifying why referral is required
  • Review of client’s historic clinical records (if relocated client)


  • Referral or letter from an audiometrist to an audiologist seeking advice on further treatment or management of a non-routine client
  • Response advice from audiologist to audiometrist and evidence advice followed


  • Evidence and file notes of further testing by an audiologist, and a referral of their client to a medical practitioner
  • Response advice from the medical practitioner
  • Evidence that advice received from the medical practitioner was followed

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Evidence Reviewed – Fitting and Follow up Services

Fitting and Follow up

Evidence in client’s case notes


Device must be listed on Schedule of Approved Devices.

Devices fitted to clients must be

  • appropriately programmed, with the device(s) response verified against a prescriptive target
  • optimised according to the client’s needs and preference
  • checked for comfort

Clients and carers must be assisted to manage the device(s).

Maintenance options must be discussed.

If partially-subsidised (top-up) device claim form must indicate the equivalent free device category (C1, C2, C3).

Refer to the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 4 Fitting of Hearing Devices
Evidence in client’s case notes for fitting services should include
  • History of the client’s previous device use
  • Otoscopy at time of fitting
  • Device details: serial numbers, features (eg telecoil), extras (eg remote) 
  • Programs in use (print out of settings or NOAH data)
  • REM / Insertion Gain
  • Occlusion checks
  • Feedback checks
  • Maximum Power Output (MPO) checks – (clapping, paper rustling etc)
  • Details of any modification/s made
  • Client’s reactions to device settings
  • Aided speech test
  • Comfort check
Client case notes on training/device management after fitting should include
  • Aid insertion
  • Battery instruction / maintenance  
  • Device care: cleaning, wax management                                              
  • Program switching, phone use, audio input
  • Practitioner (& supervisor’s) name & date of service


Fitting follow-up appointment
  • Requires a face-to-face follow-up appointment with clients one week or more after fitting.
  • Must re-evaluate the hearing goals and expectations recorded during their assessment, and address any of their issues or concerns.

Refer to the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 5 Follow-up
Evidence in client’s case notes for fitting follow-up service should include
  • Practitioner (& supervisor’s) name and date
  • Device modifications if required
  • Changes to device settings (printout or NOAH data)
  • Device management (volume control, programs, care, remote, telecoil etc.)
  • Review of device usage (data logs)
  • Review of MPO, Occlusion, Feedback
  • Client comfort
  • Client and family’s satisfaction (opinion of aided hearing)
  • Communication tactics review (different situations etc.)
  • Further training needs (Rehab Plus)

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Evidence Reviewed – Client Review (Item #930 monaural, # binaural)

Client Review

Evidence in client’s case notes

Client Review (Item #930 monaural, #940 binaural)

Aims to help extend the life of the current fitting.

Reviews a client’s needs where the client was fitted over 12 months ago.

Requires the client to receive ongoing hearing support, including reviews of communication and hearing goals, and referral where necessary.

If Client Review is claimed on same date as Reassessment, activities preformed must be different to those performed for the reassessment and services must be documented separately.

Refer to the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 6 Aftercare


Evidence in client’s case notes for Client Review services must include
  • Review of audiometric history
  • Review of communication and hearing goals
  • Check for device malfunction, blockage etc.


at least 3 of the following activities
  • Hearing screening including middle ear status (audiogram, tympanometry)
  • Real Ear Insertion Gain (REIG), Aided Threshold Measurement (ATM), Live Speech Mapping (LSM)
  • Resetting/reprogramming device parameters due to changes in hearing
  • Checking REIG/ATM with new device settings
  • Fitting new moulds, modifying current moulds/shell, retubing, replacing earhook etc
  • Assessing Loudness Discomfort Levels re MPO settings
  • Review of goals/expectations & communication strategy/tactics
  • Review & reinstruction of client aid management

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Evidence Reviewed – Refitting

Refer to the Eligibility Criteria for Refitting (ECR)

Refit criterion

Evidence in client’s case notes for refitting must include

  1. Current hearing aid(s) can no longer be optimised by adjustments or other modifications to meet current gain requirements.
  • Evidence that current device(s) are in optimal working order (NOAH, manufacturer service/repair, mould/shell modification/replacement), and
  • Evidence Real Ear Measurements show a poor match to targets after adjustment/modification to current device(s) to accommodate changes in thresholds.


  • Device specifications show that the client’s current Hearing Threshold Level (HTL) is outside the range of the current hearing aid(s) and they were previously optimally fitted.
2. Client can no longer use their aid(s) due to a significant deterioration in health, dexterity or cognitive ability since last fitting.
  • Description of deterioration and effect on client’s ability to manage their device(s) or a letter from the client’s doctor, carer, etc. giving details of how the condition affects current device usage.
  • Evidence of attempts to adjust current device(s) and/or details why they cannot be modified.
  • Details how the proposed new device(s) will address the issues with the current device(s).
3. Client requires a different style of hearing device due to a change in the physical condition or health of the ear the since last fitting.
  • Description of the change in physical condition of the ear or ear health.
  • Evidence of attempts of adjust current device(s) and/or details why they cannot be modified.
  • Details how the proposed new device(s) will address the issues with the current device(s).

4. Client requires a telecoil and the current hearing aid(s) do not have a telecoil and cannot be retrofitted.

Please Note This situation does NOT allow for refitting with an FM system, streamer or equivalent.

  • Detail specific goal which can only be met with the inclusion of a telecoil.
  • Description of change in client needs relating to telecoil since the last fitting.
  • A statement from the manufacturer that a telecoil cannot be retrofitted without re-shelling and/or faceplate modification.
  • Please Note client must opt-out of having a telecoil.
5. Client currently fitted with an Alternative Listening Device (ALD) and now requires hearing aid(s).
  • Evidence of change in client circumstances that indicates hearing aid(s) required.
6. Client's previous initial fit or refit occurred more than five (5) years ago.
  • Evidence that no fittings have been claimed for the proposed ear(s) within the last 5 years.

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Evidence Reviewed – Replacements


Evidence in client’s case notes

Replacement of lost or damaged beyond repair aid (Item #840 monaural, #850 binaural item)

Replacement should be same device if it is still on the Device Schedule, otherwise a similar device.


If client’s circumstances have changed and they meet Eligibility Criteria for Refitting (ECR), refit instead of replace.


Rules of Conduct (28(5) – Fees and charges) states that a provider may not charge a program client fitted with a fully-subsidised device more than $30 for a replacement device.

The client fee may be waived and

  1. an Item #888 claimed where
  • client holds a DVA Gold Card
  • client holds a DVA White Card which includes hearing loss.
  1. an Item #555 claimed where device(s) has been lost or damaged
  • in nursing home by staff ( must be certified by the staff member)
  • in hospital
  • in the post
  • client has dementia
Evidence in client’s case notes for replacement device must include

The declaration should state when and where the loss occurred. 

  • Damaged beyond repair device letter from manufacturer stating device(s) damaged beyond repair
  • Device details – replacement should be same device(s) unless no longer on Device Schedule or client meets refitting criteria (ECRs)
  • Evidence device(s) set to client’s preferred settings (NOAH etc)
  • Receipt of replacement payment ($30) if not waived
  • Evidence to support Item #555 if claimed (nursing home letter etc.)
  • Device quote if replacement is partially-subsidised device


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Evidence Reviewed – Spare Aids

Spare Aid

Evidence in client’s case notes

Spare Aid (Item #960)

Only one spare aid per client per lifetime

Only available to clients with one aidable ear and

  • no second aid that can be adapted as spare
  • no previous spare aid supplied

If spare aid lost/damaged beyond repair or no longer clinically appropriate, submit Replacement claim (Item  #840)

Evidence in client’s case notes for spare aid must include
  • History of monaural fitting or fitted with BICROS system 
  • High dependence on device
  • Future maintenance must be monaural unless client is fitted with CROS/BICROS

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Evidence Reviewed – Maintenance

Client must be offered a maintenance agreement with initial fitting. Agreements last 12 months only.  Maintenance includes adjustments, repairs, ear mould replacement and batteries.  
Hearing Rehabilitation Outcomes - HRO 4 Follow-up

Maintenance Services

Evidence in client’s case notes

Maintenance service & battery supply (Item  #700 monaural, #710binaural)
  • Claimed ≥ 12months after previous maintenance claim or ≥ 12 months after initial fitting date, whichever is most recent.
Evidence in client’s case notes for a maintenance claim should include
  • Signed claim form dated ≤ 45 days before maintenance services commenced.
Relocated maintenance & battery supply (Item #711 monaural, binaural #722)
  • Claimable where client has paid the annual maintenance contribution (unless exempt) to the previous provider (check portal).
  • Cannot be claimed if client relocates away and then returns within 12 months of an existing maintenance agreement with provider.
  • Covers full maintenance/batteries for 12 months
Evidence in client’s case notes for a relocated maintenance claim should include
  • Relocation authorisation signed by client
  • Signed claim form
Maintenance & Battery supply – aids fitted outside the program (Item #790 monaural,  #791 binaural)

Claimable where suitable device(s) have been fitted outside the program and are in good condition. Enables clients to bring devices into the program.

Client must have accepted & paid maintenance agreement (unless exempt).

  • Once only claim
  • Claimed on or after first assessment
  • Client cannot be refit on the same voucher without approval.
Evidence in client’s case notes for maintenance for devices fitted outside the program must include
  • Documentation of initial Assessment (Item #600)
  • Device details including condition/working order
  • Signed claim form


Maintenance – DVA (Item #777)

Payment of client maintenance contribution for DVA clients (where client has not paid contribution to provider)

  • DVA Gold Card or White Card which includes hearing services
  • Claimed with fitting items that include maintenance (Items 630,635,640,790,791) or maintenance and battery claims (Items 700,710)
  • Claimed once every 12 months
Evidence in client’s case notes for a DVA maintenance claim should include
  • Signed claim form dated ≤ 45 days before maintenance services commenced, with $0 cost to client.
Minor Repair (Item #900 monaural, #910 binaural)

Minor maintenance for clients who have lost program eligibility.

Available for up to 5 years from the date eligibility was lost.

  • Claimed on/after anniversary of first fitting or subsequent Maintenance claim.
  • Only once every 12 months
  • Annual Maintenance charge not payable by client


  • Device cleaning
  • Replacement tubing & wax guards
  • Replacement cords (CROS, body aids)
  • Replacement earphone/microphone tubing
  • Earmould renewal/repair/cleaning.
Evidence in client’s case notes for  minor repairs claim must include
  • Evidence of client’s previous participation in the program
  • Evidence repairs are needed
  • Signed claim form, with $0 cost to client. 


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Evidence Reviewed – Remote Controls (Item 4)

Remote Control

Evidence in client’s case notes

Remote control (Item #4)

A remote control can be provided if a client cannot manage their device(s) without a remote control. 


Evidence in client’s case notes for provision of a remote control must include
  • Justification of client’s need for a remote control
  • Manufacturer’s invoice (amount claimed must equal invoice amount excluding postage and handling and less than $200)
  • Signed claim form, with $0 cost to client.

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Evidence Reviewed – Rehabilitation


Evidence in client’s case notes

Rehabilitation (Item #670)

For clients who are not to be fitted (cannot claim if previously fitted).

Rehabilitation services help clients acquire and apply skills to maximise their communication abilities and better manage their hearing loss.

Claimed after assessment/reassessment & client never fitted.

Refer to the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 3 Hearing Rehabilitation
Evidence in client’s case notes for a Rehabilitation claim must include
  • Assessment and/or reassessment case notes
  • 2 Rehabilitation appointments 1st = consultation, 2nd = follow up.
  • Discussion of client’s attitude & motivation towards rehab
  • Discussion of client’s communication and hearing goals
  • Advice and support provided to client on communication strategies
  • Signed claim form
Rehabilitation Plus (Rehab Plus)

Only available for new or return clients being fitted with fully-subsidised (free-to-client) devices or ALD for first time.

Item #680 - Session requirements

  1. Group Sessions 2 sessions, 1 hour per session, partners and others can attend. Sessions are managed by Qualified Practitioner(s).
  2. Individual Sessions 2 sessions, 30 minutes per session, conducted by Qualified Practitioner.
  3. Mixed Sessions minimum of one of each of the above.
  4. Can only be claimed once per client.

Item #681 – Session requirement

  1. Group Session 1 session, 1 hour duration, partners and others can attend. Sessions are managed by Qualified Practitioner(s).
  2. Individual Session 1 session, 30 minutes duration, conducted by Qualified Practitioner.
  3. Can only be claimed twice per client.

Refer to the following Hearing Rehabilitation Outcomes (HRO)

  • HRO 3 Hearing Rehabilitation
Evidence in client’s case notes for a Rehabilitation Plus claim must include
  • Evidence of fully-subsidised device fitting or ALD
  • Evidence of discussion or training on communication strategies and tactics
  • Signed claim form

#680 = Rehabilitation Plus (2 appointments).

  • Appointments must be ≥ 2 weeks & ≤ 12 months after Follow-up.
  • Claim form shows QP no. & site ID of session

#681 = Rehabilitation Plus (2 appointments).

  • Appointment must be ≥ 2 weeks & ≤ 12 months after Follow-up.
  • Claim form shows QP no. & site ID of session

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Common Mistakes and Issues

The most common issues found during compliance monitoring are

  • Vouchers not valid at the date of service please ensure you check your clients’ voucher status prior to delivering services. Pre-voucher services are invalid. It is recommended to complete eligibility checks and/or voucher applications for clients prior to the day of their first appointment. This allows for unexpected issues (e.g. mismatching client details) to be resolved in advance of the appointment.
  • Incomplete or missing medical certifications please ensure you check the medical practitioner certification regarding contraindications before issuing a voucher for a client.  
  • Lack of evidence in file notes to substantiate claims  please ensure client files include detailed evidence of service provision, including correctly dated records, detailed client histories, notes on goals and needs, notes on the discussion of device options, quotes for partially-subsidised devices, test results, evidence of verification of fitting, signed claim forms, etc.
  • Binaural maintenance being claimed for monaural clients please ensure maintenance claims match fittings. When a client changes from binaural to monaural, remember to update your e-claim systems.
  • Lack of clarity over reassessment and client review services please ensure client file notes contain adequate detail to differentiate between reassessment services and client review services. Refer to the Schedule of Service Items for the conditions of claiming.
  • Missing authorisations from clients showing that they agreed to transfer to a new provider please keep a signed transfer request on the client’s file.
  • Clients being provided services privately when they were eligible for services under the program please ensure clients are offered the services available to them under the program and ensure client decisions are fully documented on the client file.
  • Using old forms or criteria please check our website to ensure you are using the correct forms and guidance, particularly the Eligibility Criteria for Refitting (ECR).
  • Refitting please check that the client’s voucher has no previous fitting claimed and that the client meets the ECRs before refitting. Only one fitting item can be claimed per voucher.
  • Returned devices please email when a client returns or exchanges their device/s. This allows us to correct the client’s device history on the portal.
  • E-Claim rejections if you are trying to re-submit rejected e-Claims, please delete the rejected claim from your system first. Failure to do so may result in further rejections of the same e-Claim.
  • Replacement of lost devices please obtain a correctly completed Statutory declaration stating when and where the device/s were lost, and ensure it is signed by the client or their representative and an ‘authorised witness’.
  • Clients with mild hearing loss being fitted without meeting the Minimum Hearing Loss Threshold exemption criteria please ensure that clients whose 3FAHL is less than or equal to 23dB in the ear being fitted meet both the Wishes & Needs Tool criteria and one of the four exemption conditions.
  • Recording 3FAHL results please ensure 3FAHL results are accurately recorded on the claim form and in the portal.
  • Relocated maintenance claimed when provider still has a current maintenance agreement with client if a client transfers from you to another provider and then returns to you, you cannot claim relocated maintenance if the client’s previous maintenance agreement with you is still active/current.

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Evidence Guide for Compliance Monitoring (DOC 566 KB)

Evidence Guide for Compliance Monitoring

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Evidence Guide to Compliance Monitoring

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