Provider Factsheet - Client Relocations
Hearing Service Program (program) clients have the right to choose where they receive their hearing services and can choose to relocate to a new service provider (provider) at any time.
Section 35 of the Hearing Services Program (Voucher) Instrument 2019 outlines the program requirements regarding clients relocating between providers.
The Service Provider Contract (contract) at clauses 11.1(h), 12.6c (ii), and 27.3(c) also includes provisions related to client relocations. Item C, Schedule A of the contract requires providers to have a policy in place for the management of client relocations.
A client must give their informed consent to relocate to a new provider before the new provider processes their relocation and commences delivering services. If the client has a Power of Attorney (POA) or other legal guardianship arrangement in effect, then the consent must come from the POA or guardian.
The client must also provide four points of identity (their eligibility number or voucher number; first name, surname and date of birth) with their consent to allow the new provider to access the client’s record in the Hearing Services Online Portal (the portal). Information held in the portal is sensitive information and is covered by the Privacy Act 1988.
Accessing someone’s health information without their consent is a serious breach of the Privacy Act 1988 and the contract. Breaches may need to be reported under the Notifiable Data Breaches scheme.
The new provider is expected to obtain written consent from the relocating client before processing the relocation. However, in some circumstances, verbal consent is acceptable for the convenience of clients (for example, for emergencies or to allow the client to make an appointment and the new provider to obtain the client record before the client visit).
The client’s signed and dated written consent to relocate must still be obtained at the first appointment and must be kept on the client record.
The department has released a Client Relocations template for use by providers. This template can be amended but the information contained on the template must be retained.
Processing a Relocation
Each client is linked to their chosen provider in the portal. The client’s information is safeguarded by limiting access in the portal to their chosen provider. When a new provider initiates a relocation through the portal a link is created between the client and the new provider. This link allows their provider to view and update the client information.
When processing relocation requests, providers must ensure they are logged into the portal under the site requesting the client’s record, as the record will be sent to the requesting site’s address.
The previous provider will receive an automated email relocation notice to their registered contact email address. A relocation notice is an email instruction from the program. It is automatically generated when a provider uses the portal to transfer a client from another provider. In accordance with Section 35 of the Instrument, the file must be transferred as directed by this notice.
The previous provider will no longer have access to the client’s information in the portal. Information on how to process a relocation in the portal is available in the Quick Reference Guide – Transfer, link and search for existing clients.
The relocation notice instructs the previous provider to send the client’s complete record, including copies of all claim forms, to the new provider within seven (7) business days. The previous provider should take this opportunity to check that the client record is complete, and submit any outstanding claims for payment. Please refer to the Provider Factsheets on Management of Client Records and FAQs.
New providers should check with the previous provider whether there are any outstanding claims to be submitted before delivering services to the client.
Providers must not ask clients to collect their file from a previous provider.
Contacting Relocated Clients
Clients can choose not to have further contact with their previous provider, Australian Privacy Principle (APP7) under the Privacy Act 1988, allows clients to withdraw their consent to receive direct marketing communications from their previous provider and request they no longer contact them.
If a client does not wish to be contacted by their previous provider, the client will need to contact their provider to withdraw consent for the use or disclosure of their information.
Clients must not be contacted and pressured into staying with their previous provider if they have chosen to relocate.
Relocated Maintenance Claims
All outstanding claims for payment must be submitted by the previous provider within 20 business days of the date of the relocation notice. If a client wishes to continue with maintenance arrangements, the new provider can submit a relocated maintenance claim for that client (items 711/ 722).
If the client is not on a maintenance agreement at the time of relocating but would like to start a maintenance agreement they can do through standard maintenance agreement processes.
All client records must be managed in accordance with the program’s Management of Client Records Provider Factsheet. The previous provider must keep original claim forms and copies of client receipts for seven (7) years after the date of service.
The new provider must retain the signed consent from the relocating client on the client record. If verbal consent was obtained initially, there must be documentation on the client record.
Please refer to the Private Services and Devices Factsheet for information about record keeping related to private services for relocating clients.
Program requirements are monitored in accordance with the Compliance Monitoring and Support Framework. The program monitors relocation patterns and claiming, and undertakes routine compliance checks in accordance with the Service Provider Contract, specifically clause 16.
Please note that if any invalid claims are identified, including if a service was claimed when the client had not given consent to relocate, providers must reimburse the Commonwealth and may be required to reimburse clients.
Links and Resources
Frequently Asked Questions
What do I do if we do not receive a client’s file within 10 days?
In the first instance providers should contact the previous provider to confirm they received the relocation notice.
If the previous provider has received the notice, the new provider should
- Ask if the file has been sent and obtain the tracking number.
- Ask what is causing the delay.
If the previous provider has not received the notice, the new provider should
- Confirm their email address.
- Allow an additional 7 business days to receive the file.
If the new provider still does not receive the client file within an appropriate timeframe, they should email the program, briefly outlining their efforts to resolve the issue including
- Names and voucher numbers of the relevant clients
- Date of follow up request for the file
- Any relevant file notes.
What do I do if the file sent is incomplete?
When a client relocates to another business, the previous provider will receive an email directing them to send the complete original file to the new provider. It is a contractual and legislative requirement that the complete file is sent within the timeframe specified in the email.
If the provider has not supplied the complete file, the new provider should contact the previous provider detailing the missing information and request it be sent through. If the information is still not provided after a follow up request you can then contact the program for further assistance.
Can a provider refuse to forward a client file?
No. Once a provider receives a relocation notice they must forward the file to the requesting provider. If a provider has concerns they should contact the requesting provider to confirm the relocation request. It is the responsibility of the requesting provider to document client consent.
Can a client who is eligible for or obtaining specialist hearing services relocate to my business?
Yes, however you are responsible for ensuring clients who are eligible for or receiving specialist hearing services are aware of the services available through Hearing Australia. You must explain that Hearing Australia is funded to provide a broader range of fully subsidised hearing devices, communication training, ongoing services and support.
Information on specialist hearing services is available on the program website.