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

Disclosure

Clients of the Australian Government Hearing Services Program (the program) have the right to as much information as possible about the hearing services they receive in order to make informed choices. This includes transparency around any preferred provider arrangement(s) a service provider may have in place with a device supplier which may, or which could be perceived to be, influencing the recommendation they may make regarding the supply of a device under the program.

The program’s Service Provider Contract 2018-2019 has a new obligation for service providers to disclose any preferred provider relationships

30 Disclosure of Preferred Provider Relationships

30.1 The Service Provider must disclose, in a manner to be determined by the Service Provider, any preferred provider relationship with an Approved Supplier or manufacturer, to a Client.

30.2 A ‘preferred provider relationship’ is one where the Service Provider receives a benefit (pecuniary or non pecuniary) that is related to the Service Provider’s purchase of a Device from an Approved Supplier or manufacturer.

The new disclosure clause sets the requirement for service providers to disclose to program clients that such arrangement/s exist, rather than the full commercial detail.

Disclosure also helps to support service providers in the event of a client complaint about any services received under the program, in particular relating to the provision of partially subsidised devices.

This information sheet provides examples for service providers when considering what processes and procedures they might put in place in order to meet their obligations in this regard.

Possible examples

Examples might include, but are not exclusive of

  • Where the service provider is fully or partly owned by a supplier, or a manufacturer which is approved to supply devices to the program.
    • It might be perceived that this contracted service provider will only supply that brand of devices, rather than consider the entire schedule of approved devices as required under the service provider contract.
    • It might be perceived that this service provider, as a result of their association with a manufacturer, will request used devices ‘damaged beyond repair’ in order to increase sales of new devices from that supplier or manufacturer.
  • Where a device manufacturer has provided significant financial support to an independent service provider, to begin or promote their business.
    • It might be perceived that because the device manufacturer is sponsoring the advertising for that clinic, or loaning the equipment to that clinic, or providing financial support for any other thing, that the service provider or staff employed by that provider will in return recommend only that brand of device to program clients.
  • Where a service provider has a preferred supply arrangement with a device manufacturer and receives significant reductions in price commensurate with the number of sales of that brand.  Or other incentives such as a number of free tickets to an upcoming conference or to a private event held by that device manufacturer, which is tied to the number of device sales achieved per month.
    • It might be perceived that the service provider may be promoting sales of those particular devices in order to reach or maintain sales targets, without due regard for the individual circumstances or best interests of the client.
    • It might be perceived that the service provider may be fitting a particular device when a different device on the schedule of approved devices may be more appropriate to help the client manage their hearing loss.

Systems and procedures

Each service provider must demonstrate it has systems and procedures in place to ensure all program obligations are met, including for the new Disclosure clause, and that those systems are successful.  The service provider is responsible for ensuring its employees are aware of and follow these procedures in this regard.

It is up to each service provider to decide how disclosure to program clients occurs about their preferred provider relationships arrangements, if any.  An information flyer for individual program clients or a poster which may be displayed in a prominent place are examples.

As stated above, disclosure is about transparency regarding the existence of an arrangement and does not require disclosure of the commercial or other detail of that arrangement. As such, disclosure procedures will differ between service providers.

Compliance

Compliance with the Disclosure and other contract clauses will be confirmed through audit.

 

Disclosure (PDF 125 KB)

Service Provider Contract 2018-2019

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