Australian Government - Department of Health and Aged Care - Office of Hearing Services
Hearing Services Program

Compliance Update February 2023

The Hearing Services Program strives to work proactively with contracted service providers to support their compliance with program requirements through a range of supports including education and awareness raising. The program monitors provider compliance in accordance with the Compliance Monitoring and Support Framework (the framework). This Compliance Update includes information on the support available, priorities for compliance monitoring in 2023 and lessons from compliance activities in 2022. You are encouraged to review the Schedule of Service Items and Fees published each year and update your processes to align with any changes to ensure you remain compliant with the program requirements.

Provider Compliance Support

The program offers a range of support to assist providers and their staff with compliance. These include:

The program welcomes suggestions on how we can support providers to improve their compliance. Providers can also request support with compliance training and reviews of their processes and templates.

2023 Compliance Monitoring Program

The program has a robust risk-based compliance monitoring component. In addition to routine audits and claim monitoring activities, in 2023 compliance monitoring will focus on the following areas:

  • Revalidated Services
  • Practitioner Qualification Checks
  • Replacements
  • Maintenance Agreements and Claiming
  • Refittings Under Five Years

The 2023 Self Assessment Tool (SAT) will be held in Q4 2023 and will focus on all aspects of the program.

2022 Compliance Issues

Common issues identified during 2022 compliance monitoring were:

Incorrect practitioner details listed in the portal

The program commenced a review of practitioner information held in the portal in 2022. It has discovered many inconsistencies regarding names, QP numbers and provider/practitioner linkages. This is despite providers certifying in their SAT that their QP portal information is correct and up-to-date. Providers are being contacted regarding these issues. Providers are reminded to:

  • annually confirm the PPB membership and competencies of their practitioners
  • ensure QP details listed in the portal are correct
  • end date practitioners that leave their employment or are no longer delivering services to program clients, and cease using their QP numbers for record keeping and claiming.

No Self Assessment Tool (SAT) submission

Twenty providers did not submit their SAT by the closure date. These providers will be audited by the program and will be required to provide evidence to demonstrate compliance. Providers are reminded that the SAT is an important tool to support compliance with program requirements.  Completion of the annual SAT is a requirement of the Service Provider Contract (clause 16.8).

Poor record keeping

Audits and claim reviews continue to identify poor record keeping and lack of evidence of service as major issues. Client files must contain evidence of claimed services. This includes:

  • identification of the practitioner who completed the service
  • legible, dated and detailed file notes regarding activities completed
  • document requirements outlined in the Schedule of Service Items and Fees (client signed and dated WANT, evidence of ECR, correctly completed Statutory Declarations, etc)
  • data logging information where available, not self-reported use which is unreliable as evidence
  • device discussion notes, including reasons for choice of device
  • detailed quotes and client receipts
  • supplier invoices for remote controls.

Tick boxes alone do not provide adequate evidence of service provision or support continuity of care.

Unnecessary Revalidations requests

Unnecessary requests for revalidated services continue to be received, for example when the client has an available assessment or fitting service on their voucher. Providers should check the portal for the services available to the client before requesting additional services. A Client Review service may provide the information a revalidated Assessment service would disclose. Revalidated fitting requests must be supported by sufficient evidence and justification. Revalidated requests must be approved by the program before the service is provided to the client.

Devices not on approved schedule

Devices that have been removed from the Device Schedules are being provided to clients. Providers must ensure that devices supplied to clients are listed on an approved schedule of devices at the date of fitting, unless otherwise approved by the program. Email the program for approval to supply devices if they were ordered specifically for the client on or before the withdrawal date from an approved device schedule and can be fitted within 14 days of the date of withdrawal.

Invalid Client Reviews

Client records reveal that many client review services lack evidence of sufficient activities. All client reviews require the practitioner to review the client’s clinical and audiological history and their hearing goals. Merely recording ‘no change’ is not evidence that history or goals were discussed. Where a client is aided, their former goals should be assessed, and new ones established if necessary. Tick boxes do not provide sufficient evidence that any activity was completed. File notes should accompany tick boxes to detail the actions taken to ensure continuity of care and that client outcomes can be monitored.  

Teleaudiology service documentation

Many client files do not identify whether the service was provided face-to-face or by teleaudiology. The Schedule of Service Items and Fees, under General Program Requirements, states that telehealth services must be documented on the client record and the client informed of the service they are receiving.

Portal issues

Providers must ensure that the claims they submit to the program meet program requirements.

Invalid payments claimed by providers must be recovered by the Commonwealth.

Cost to Client Documentation

There are a range of issues being identified with the accuracy of cost to client information provided with claims when comparing to client records. Please ensure the actual cost to client for devices, maintenance and replacements are accurately captured and are substantiated by records held on the client file.

We will continue to work with providers to support compliance. Please do not hesitate to contact us if you have any questions about the program or suggestions on ways to help improve the support available.

Compliance Update February 2023

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