Physical Disability Australia Ltd
P O Box 38
Willawarrin NSW 2440
Phone: 02 6567 1500
Fax: 02 6567 1500
Email: [email protected]
Submission from Physical Disability Australia to
Medical and Disability Aids and Equipment Pricing Investigation
30 September 2013
Overview
Physical Disability Australia (PDA) welcomes the investigation and report on the pricing of medical
and disability aids in Queensland compared to other states and countries. We would also welcome
further involvement in the commission’s investigation. This matter of investigation not only has
implication for our Queensland members with a physical disability, it has potential to impact all
persons who use aids and equipment freedom for participation in everyday life.
In 2009, PDA produced a policy paper for the Department of Families, and Community Services,
Housing and Indigenous Affairs (FAHCSIA) examining the various Aids and Equipment Schemes,
which supply and provide essential support items for people with disabilities, across Australia. The
nine key recommendations from this report are in the appendix a. However, to summaries, PDA
requested a national review regarding the disparity in subsidy, choice and supply regarding Aids
and equipment, and a streamlined and unified consumer-driven approach to the funding aids and
equipment across Australia. These recommendation have not change, they have only expanded to
include the need for independent agencies to investigate competition, choice and best interest
regarding aids and equipment in Australia.
Today, significant problems with the systems continues to disadvantage many individuals and
families. The disparity between subsidy and cost of equipment is one area that continues to
disadvantage many. This pertains to items, such as high-tech communication devices, mobility
devices (customised electric wheelchairs) and daily living equipment (specialise mattress, celling
hoist), all of which are fundamental in realising ones fundamental human rights; the right to
dignity, self-determinism and full participation in everyday life. Instead the disparity encountered
means that many people with a physical disability requiring these types of equipment, are left to
cover the cost, fundraise and/or seek assistance from charities and non-government organisation
for their mobility, independence and voice. In addition, the historical monopolizing by government
systems and supplier have made difficult consumer driven demand/supply and competition.
The responses provided here are not comprehensive, due to the time limitations, however, they
seek to illustrate the context of inequalities to essential aids and equipment many individuals with
a physical disability continue to encounter. The submission also seeks to raise further question to
be probed by the commission.
1
The submission begins with an outline of the essential role of aids and equipment. Followed by a
respond to each main question.
Equipment/Aids are Essentials
The Importance of equipment and aids cannot be underestimated. They provide people with a
physical disability the ability and freedom of self-determination, dignity and participation in
society. Equipment and aids (PDA, 2009, p.2-3)i:

Provides individuals with greater personal independence.

Improves quality of life.

Reduces the demand for costly personal assistance.

Assists people to remain at home thereby diverting from more costly disability or aged care
support options. Aids and equipment can reduce the need for out of home placements
through avoiding hospital admissions (for example because of pressure sores from poor
equipment).

Enhances the longer-term capacity of carers (for example the use of hoists).

Can aid potential to be employed.

Means the difference between being independent and reliant on others.

Assists in the social inclusion of people with disabilities throughout society.
Response to Question
Q 1: BACKGROUND AND SCOPE OF THE INVESTIGATION
1.1. Are the definitions of disability and disability aids and equipment appropriate for use in this
investigation?
The definition in the scoping document needs to be widen to reflect the more comprehensive list
see AIHWii (2003, p. 5). This is because summarising can be dangerous, as it can limit the perceived
diversity and vastness of what are aids and equipment.
Recommendation: use the list by AIHW, 2003 (p. 5).
1.2. What sources of data for expenditure on medical aids and equipment are available?
There is limited sources of data per se independent of governments own sources of expenditure
e.g. MASS. Estimates pooled by Summers (2001, p.32) however, suggests:
“One in ten Australians use aids and equipment (ABS 2004). Annual national expenditure is
estimated at $4.5 billion, split almost equally between public and private spending.
(compiled from multiple sources including AIHW 2008, ABS 2005, PriceWaterhouseCoopers
2009). About $3.1 billion of this spending was health-care related according to Australia’s
Health 2008 (AIHW 2008)”.iii
Recommendations:
2
As encouraged by advocates, reports and submission previously, there needs to be a collaborative
research project between DPO’s, economist, agencies like ACCC and academics to cost out this
information. Part of this needs to factor in the cost and ripple effect of those who are also affected
by disability through association, include families, carers, communities and schools. This has not
been measured but should be considered as they often deliver advice and assistance when
researching and using disability aids as well as fund or help to fund gaps in equipment provision.
The other requirement is a system that can provide ongoing monitoring of expenditure, needs and
demands to inform progress and decision-making publicly.
1.3 Are there specific examples of price disparities for medical aids and equipment?
Whilst specific examples of price disparities can be found over the internet, there is difficulty
tracking the span of how far these price disparities go. Price promotions have a large impact and
cannot be tracked continuously as this changes regularly, particularly within the online
environment. The other problem is access to cost of items by some providers are not readily
available, unless one makes an enquiry.
It is important to consider the type of product consumer require when considering price
disparities. Everyday medical aids, such as continence products would be readily available, in a
series of price brackets and consumers will be able to trail many different options until they find a
suitable choice. These can be considered low involvement products.
Medical aids that are designed to enable someone with a specific disability that severely impact on
everyday life, such as wheelchairs and hearing products can be considered high involvement
purchases. With high-involvement purchases, often consumers will undergo a rigorous research
process prior to purchase. This process may span a period of time exceeding a few days or weeks.
Much of the data available on disability and medical aids are found via catalogues and online
stores. There is no singular site that provides a comprehensive comparison of product variants on
a national or state basis. Table 1 provides a minor comparison between three organisations that
specialise in medical and disability aids from Australia, the United States (USA) and the United
Kingdom (UK).
Because of Standing Offer Arrangement SOA412 (SOas), for Medical Aids Subsidy Scheme (MASS)
it is difficult to say if there is disparity, as prices are not published.
TABLE 1: INTERNATIONAL COMPARISON
Incontinence pads
Shop
Company/Location
Size/Price
Euron Form all in
one wrap around Access Health, VIC
Continence Pads
Pk 14 - $18
Tena Pants Plus
Chemist Direct, AUS
Extra Large
Pk 12 - $37.50
Website
http://www.accesshealth.c
om.au/hospital-nursinghome/continencepads/3771/euron-form-allin-one-wrap-aroundcontinence-pads/
http://www.chemistdirect.
com.au/tena-pants-plusextra-large-x3
Premium
All-InDisability
One Incontinence
UK
Pads
12?utm_source=MyShoppi
ng&utm_medium=ppc&ut
m_term=313289
http://disabilitysupplies.co
m/acatalog/Premium-AllSupplies, Pk 15 - £10.12 (med)
In-One-Incontinence-Pads-- £12.49 (lge)
-Pack-of-15---Medium-L63599.html
Shower & Bathtub grab rails/bars
Shop
Location
Price
Website
Mobility Shop
Pennant Hills, NSW
$51.95 - $339.95
http://www.mobilityshop.c
om.au/grab-rails
Texas, USA
$66.00 – $150.97
http://www.adaptiveaccess
.com/grab_bars_shower_tu
b.php
Surry, UK
http://disabilitysupplies.co
£25.52 –£ 276.60
m/acatalog/Bath___Grab_
(EXC VAT/GST)
Rails.html
Adaptive Access
Disability Supplies
Scooter Ramps
Shop
Location
Price
Website
Rubber wedge ramps
Mobility
Shop
Adaptive
Access
$89.95
Pennant Hills,
Collapsible Silver Star ramps $274.95
NSW
Roll up ramp
$374.95
Texas, USA
Threshold ramps
41.60-120.00
Solid ramp
174.40-320.00
Folding ramp
102.40- 246.40
Modular ramps
2145.00
Disability
Supplies
Surry, UK
http://www.mobilityshop.c
om.au/scooter-accessoriesand-parts/scooter-ramps
http://adaptiveaccess.com/
alum_wheelchair_ramps.ph
p
429.00 –
Folding Ramp
£97.50 - £284.25
Doorframe ramp
£97.50 - £146.24
Fibreglass folding ramp
£468.75
http://www.disabilitysuppli
es.com/cgibin/ss000001.pl?page=sear
ch&SS=ramp&PR=-1&TB=O
Below are a further initial observations from this minor price comparison investigation:
4

There is minimal product variety available online within Australia. Online USA and UK
stores offer greater product variety and ability to personalise/customise items to specific
customer demand. In Australia personalised offerings and service in store versus
comprehensive online offerings. This is further supported by many Australian online
retailers offering catalogues for consumer’s convenience, but not allowing purchases to be
made directly online with a credit card or by other methods of online money transferal.

Ramps offered overseas appear to be functionally more diverse than those offered in
Australia. Ultimately they are also dearer than their Australian counterparts. This could be
because the state of housing in Australia is much more wheelchair accessible for disabled
persons because it is newer.

Similar to many other products, often consumers will need to ‘shop around’ to achieve the
best price suitable to their circumstances, budget and needs.

Certain product categories are difficult to purchase online, even more so to establish
pricing structures (items can be sold unbundled or bundled, depending on website, and will
affect the final price including cost of distribution). This is particularly evident for complex
products that require further advice and referrals from medical or disability professionals,
such as catheters. Rather, the system appears to devised in a such a way that consumers
must seek professional medical advice and referral prior to making purchases online, either
through and Australian or overseas website.
1.4 Are there any additional community concerns about pricing disparities for medical and
disability aids and equipment?
There have been a number of concerns voiced by the community in regards to the pricing
structures of Disability and Medical Aid equipment in Australia versus the products and prices
offered overseas. Price gouging occurs when the prices set by a seller are at a much higher level
than is considered reasonable or fair. In Australia, given the smaller population in comparison to
other Western counterparts, the cost of living and innovation has made access to necessary
medical equipment harshly expensive. Particularly for those living with disability, that are not in
the workforce and disconnected from the community, there are heightened barriers to access.
Below
are
some
links
to
news
articles
voicing
these
concerns:
“Parents angry over disability product price gouging” http://www.abc.net.au/news/2011-0716/companies-disabled-price-rises/2797208.
Areas of consumer concern when considering purchasing necessary disability equipment include:


Do they adhere to Australian Safety Standards?
Do they meet the guidelines expressed through the Australian Consumer Law (particularly
for products purchased from overseas suppliers)?
Whilst resources are made available, such as the ones below, it is still difficult to navigate this
information, plus accessing some information incurs a cost.
A series of reports into the requirements of products in Australia are available for purchase
via http://www.iso.org/iso/home/store/catalogue_ics.htm
5
A comprehensive website of information on consumer’s rights can be found via
http://www.accc.gov.au/consumers/consumer-rights-guarantees/consumerguarantees
The Queensland State government has created a webpage to assist those buying
high value items from overseas. Though designed for Queenslanders, the guide is a
simplified guide for consumers on how to approach purchasing high value items
and equipment online: http://www.qld.gov.au/disability/adults/getting-help/aidsequipment-technology/buying-aids-online.html
Another concern is the limited certainty when dealing with an overseas seller. Consumers can
experience difficultly contacting suppliers directly as such information is not often advertised
to consumers. Consumers must also face the burden of intercontinental barriers to consumer
advocacy, such as warranties.
2 – PROCUREMENT, DISTRIBUTION AND SALES OF MEDICAL AIDS AND EQUIPMENT
2.1 Is there scope to rationalise or consolidate government and/or non-government programs for
distributing medical and disability aids and equipment?
The Productivity Commission report recommended a market-based system for disability care and
support. The rationalising of government and non-government programs consolidated into an
individualised funding model lies at the heart of productivity commission recommendations. There
is considerable scope for state-based programs to be folded into one national program, which
enables consumers to make informed choices.
The current funding agreements, which distribute medical aid and equipment are summarised in
tables 2 and 3.
TABLE 2: NATIONAL LEVEL PROGRAMS
Plan
Continence
Payment
(CAPS)
Funding amount ($)
Website
Aids Payment for 2013-14 is up to $533.50 and is http://www.humanser
Scheme indexed annually.
vices.gov.au/customer/
services/medicare/con
tinence-aids-paymentscheme
DisabilityCare (NDIS)
Productivity Commission has suggested double http://www.disabilityc
the current rate of funding for the effective areaustralia.gov.au/
implementation of the program (upwards of $8
Productivity
billion).
Commission’s findings:
http://www.pc.gov.au/
projects/inquiry/disabil
ity-support/report
6
TABLE 3: STATE LEVEL PROGRAMS
QUEENSLAND
Plan
Funding Amount and Inclusions
Community Aids
Equipment
and
Assistive
Technologies
Initiatives (CAEATI)
Funding is capped at $10,000 per client for a period of 3 http://www.qld.g
years.
ov.au/disability/a
dults/caeatiPrescriber subscription (covers the cost of a registered access/
therapist to assist the client in completing the CAEATI
application process - maximum $500 per application up
to a maximum of $800 every 3 years).
Communication
support
(Speech
devices/PODD communication books).
Website
generating
Mobility/ Active participation (Power assist wheels,
recreational wheelchairs, sports wheelchairs).
Postural support (weight bearing devices, hi-lo seating).
Medical
Subsidy
(MASS)
Aids Includes communication aids, continence aids, daily http://www.heal
Scheme living aids, medical grade footwear, mobility aids, th.qld.gov.au/ma
orthoses, oxygen, spectacles through the Spectacle ss/
Supply Scheme, Cystic Fibrosis Program.
Also encompasses the Spectacle Supply Scheme (SSS).
NEW SOUTH WALES
Plan
Funding Amount and Inclusions
Website
EnableNSW
Mobility, self-care, communication, and respiratory http://www.enab
support.
le.health.nsw.gov
.au/
EnableNSW Income Bands for all assistive technology
Assistive
Technology
for devices (except for prosthetic limbs)
Communication,
Consumer co-payment
Mobility,
 Band 1 – Adults on full pension and children
Respiratory
under 16 years $100 each year accessing services
Function & Self
Band 2 – up to $42,000 (single) or $70,000
Care
(couple) + $2,100 per
dependent, $100 each
year accessing services
 Band 3 – above $42,000 (single) or $70,000
(couple) + $2,100 per dependent 20% of devices
costing $800 and above Consumers in Band 3 are
not eligible for devices under $800.
Includes wheelchairs, adjustable beds, hoists and shower http://www.enab
and toileting aids
le.health.nsw.gov
7
Specialized
Equipment
Essential
for
Discharge (SEED)
.au/home/service
s/sesup
VICTORIA
Plan
Funding Amount and Inclusions
The Victorian Aids All funding is decided on case by case basis.
and
Equipment Mobility Aids and Equipment $200-$6000
Program (A&EP).
Personal Aids and Equipment $1200+
Website
http://swep.bhs.org
.au/saeas
SOUTH AUSTRALIA
Plan
Funding Amount and Inclusions
Website
Individualised
Funding Agreement
People with a disability who are eligible to receive
an Individualized Funding Agreement can use a
budgeting system to purchase wheelchairs, scooters,
and other forms of aid.
http://www.sa.gov.
au/subject/Commu
nity+support/Disabil
ity/Disability++consumers/Individ
ualised+funding+for
+people+with+disab
ility/Information+pa
ck+on+individualise
d+funding
DCSI
Equipment DCSI’s state wide equipment program, manages the
Program
equipment and home modification needs of clients
of Disability Services, Domiciliary Care Services,
Novita Children’s Services and Minda Inc.
http://www.sa.gov.
au/subject/Seniors/
Corporate+and+busi
ness+information/D
omiciliary+care/Sup
port+and+services/E
quipment+Program
TASMANIA
Plan
Funding Amount and Inclusions
Website
Community
Equipment Scheme
A number of contracts with NGOs are negotiated to
allow those with a disability to purchase subsidized
aid from commercial suppliers. Eligible clients pay a
minimum $50 loan fee for equipment and
maintenance.
http://www.dhhs.ta
s.gov.au/service_inf
ormation/services_f
iles/RHH/treatment
s_and_services/com
munity_equipment_
scheme
8
WESTERN AUSTRALIA
Plan
Funding Amount and Inclusions
Website
WA
Community
Aids
and
Equipment
Program (CAEP)
Provides long-term loan to help with mobility in the
home; or funding home modifications such as installing
a ramp to assist mobility. Funding can be received for
as long as equipment is necessary.
http://www.conce
ssions.wa.gov.au/C
oncessions/Pages/
Community-Aidsand-EquipmentProgram-(CAEP)--funding.aspx
In Queensland there are also Non-Government Organisations (NGOs) which may provide assistance
for aids, equipment and assistive technologies).Examples can be found in Table 4.
TABLE 4: NON-GOVERNMENT FUNDING PROGRAMS
Plan
Funding and services available
Website
Spinal
Injuries An Equipment Hire service provides manual http://www.spinal.
Association
wheelchairs, pressure relieving cushions and com.au/services/e
mattresses, shower chairs, hoists and slings and quipment/
portable ramps and bed blocks. Rates start at minor
amounts such a $20 per day for simple products, such
as bed blocks and increase with the complexity of
device and length of use.
Muscular
Dystrophy
Queensland
Provides assistance with information and referral, http://mdqld.org.a
equipment loans, assistance with costs related to u/get-support
equipment, modifications, mobility and access, respite
and No Interest Loans (NILS). Funding amount not
specified.
Motor
Neurone Provide a listing of support and funding agencies for http://www.mnda
Disease
those living with Motor Neurone Disease to contact to q.asn.au/
Association
of seek further assistance.
Queensland
Variety
Queensland
Specifically handles the needs of disabled children by http://www.variet
providing a series of programs which enable physical, y.org.au/QLD/HO
emotional and financial support to families.
W-WE-HELP/
9
From a consumer perspective it is difficult to discover avenues of funding without guidance from a
third party (friends, family, and government or non-government employees in human services). A
one-stop-shop of information and links to national and state wide disability funding agreements
would be ideal as would increasing the rate of key-word searches to enable consumers faster selfservice.
According to a spokesperson of the Australian Federation of Disability Organisations (AFDO) (May
1, 2013 - http://www.afdo.org.au/node/429):
“One of the major problems with the system at the moment is that it’s a mix of government
funding, donations and self-funding by people with disability and their families so funding is
uncertain and there’s often a struggle to get what you need,” said Ms Hall. “Meeting the
basic rights of a person with disability like the ability to get out of bed, out of your house
and into a job should be done through stable funding.”
Concerns can be raised about the capacity for one body to manage all funding agreements and
distribution.
At the moment this appears to be resting with the rollout of the NDIS Launch Transition Agency
(known as DisabilityCare Australia). Structured to operate as an independent body under the
Federal Government, is in its early stages and their long term capacity to determine providers will
be heavily scrutinized by the community, including persons with and without a disability. Fear that
an independent body will potentially be threatened with severe cuts or rearrangement into a
Federal health and welfare portfolio, in the future, should be a factor to consider prior to the
consolidation of distributors and funding.
2.2 Will there be scope under Disability Care Australia to use government procurement to make
non-subsidised aids and equipment available to consumers in competition with retail outlets?
It would appear contrary to the recommendations of the ACCC report to manufacture competition
through an artificial market to exact some form of price control, or price limits for aids and
equipment. Under such a system, price setting will still be in the hands of individuals who are not
acting in alignment with their own particular self-interest. Such a system would quickly become
another form of rationing that would limit consumer choice that were deemed to be appropriately
priced.
The key point is choice and adequate funding whether the procurement process can ensure
consumer driven market. This point was further reinforced by: National Aids and Equipment
Reform Alliance’s (2010, p. 2)iv urging reviews to consider a: “threshold test for services to eligible
people based on reasonableness and relevance as is the case with the TAC, rather than one that
caps benefits and uses rigid lists to determine the specific items of equipment that can be funded
by the scheme”. Queensland currently reflect the later, which has meant many individuals and
families with a physical disability are subject to unmet needs.
10
2.3 Do stakeholders expect that retail options for medical and disability aids and devices will
expand
as
Disability
Care
Australia
is
implemented?
Retail options would be expected to expand under Disability Care Australia, if the purchasing
decision making power is (as recommended), placed with the individual and/or family. Retail
options may diminish if decision-making remains with a central equipment service provider.
2.4 What role do health care professionals have in determining the source and choice of aids and
equipment
and
in
ensuring
value
for
money
in
purchases?
Healthcare professionals will take a central role in the assessment of necessary equipment that
individuals will require under the Disability Care program. Under Disability Care, professionals will
be assessing and recommending the dollar value of support an individual requires and this extends
to the provision of resources for equipment. Also they provide the specialist knowledge to
recommend the purchase and development of types of equipment. The source of equipment
should however operate at the level of choice for the individual concerned.
According to multiple Disability Organisations, including AFDO, there has been a lack of political
activity by allied health clinicians. Reasons for this may vary, below are some possible
explanations:




Lack of general involvement on account of bureaucracy,
Ethical reasons held by physician or patient,
Lack of specific knowledge in an area of disability or specialised referral availabilities,
Fear of being accused of prescribing the ‘wrong advice’ and facing litigation.
This is also an issues that has been raised within the online and print medical community:
“NDIS fails to relieve litigation pressure”: www.australiandoctor.com.au/news/latestnews/ndis-fails-to-relieve-litigation-pressure
“NDIS may spark rise in medical lawsuits”: www.australiandoctor.com.au/news/latestnews/fears-ndis-may-cause-lawsuit-surge
3 – PRICE DISPARITIES
3.2 What additional non-price factors are important when purchasing medical and disability aids
and equipment?
It is important to consider that decision making around the procurement of medical and disability,
aids has historically not rested in the hands of the consumer or "user" of the equipment. Multiple
conflicts of interest within the supply chain has been the norm, and until recently with the Release
of the Productivity Commission report, has received little enquiry or investigation. To establish a
more genuine market-based system, that would operate according to consumer demand, which,
in turn, would significantly influence item price. The review needs to be mindful of this, particular
historical relationships that have developed and galvanised over many years.
It might also be important to realise the role that government has played in taking decisionmaking responsibility away from that of the individual (and their family) with the establishment of
11
centralised systems of equipment provision. The relationship between the representatives of the
funder (government), equipment supplier, equipment prescriber and the "client" has not been
fully appreciated in the pricing and provision of disability equipment and aids under such systems.
3.3 Is there evidence of excessive Australian prices as a result of exclusive supply arrangements?
The cost of maintaining complex equipment is inflated by resources devoted to centralised
systems that are maintained in each jurisdiction in Australia. Invariably, the necessary skills and
expertise to maintain and develop customised adaptions to complex equipment systems sits more
closely with the supplier. Many of the state-based organisations have very little value, but do incur
considerable costs to the overall equipment budget.
3.4 Is there evidence of 'geo-blocking' being applied to the global sourcing of medical and disability
aids
and
equipment?
Examples used in this discussion include Adaptive Access, a USA based company who offer
competitive prices and a large product range. However, as stated on the website, Adaptive Access
will only distribute through the USA.
This may not necessarily be an issue of geo-blocking as may simply be an issue of distribution.
Import duties and taxes are levied once the order reaches the destination and these may be
considered not-worthwhile from the seller, or consumer’s perspective.
3.5 Is there evidence of differential pricing where suppliers specify price on application and do not
publically disclose prices
There is a difficulty with equally comparing products online that are available within the Australian
markets. Consumer awareness about pricing and where to look may also vary depending on their
access to knowledge and other resources. A great deal of patience negotiating with bureaucracy,
investigating alternatives and waiting for referrals is also need in the purchasing process. Product
searches cannot always find exact matches on a state-by-state basis and often link with a physical
retailer, rendering the search quite limited and providing minimal scope for comparison.
Furthermore, product information and pricing is frequently only obtainable after making an
enquiry.
Comparison exercise. For example, a search for the Powered wheelchair, Merits Interceptor S 940
found the following results. No searches matching these criteria could be found from the other
State and Territories. Scooter-World, an Adelaide based company, operate a Bricks-and-Mortar
store and do not sell online. Therefore, they offer competitive pricing strategies as a means of
remaining competitive with online companies that distribute nationally.
Location
Price
Website
Adelaide, SA
$5990
http://scooter-world.com.au/our-products
Melbourne, VIC
$6490
http://www.mobilitycare.net.au/mobility_products/meritsinterceptor-940-4-wheel-scooter.html
Sydney, NSW
$5750
http://www.rolandpriestley.com.au/content_common/pr-four-wheel-scooters_interceptor-940.seo
12
Another problem is with the SOAs used by MASS. The price agreed upon as part of the SOA
supplier list is unknown to the consumer. This process, whilst controls pricing, negates information
and choice outside of these formal arrangements.
3.6 Should there be government programs to assist consumers in comparing prices of products?
Currently the disability sector appears to be favouring a seller’s market, in the sense that the
current procurement system favours certain suppliers determined on factors such as order volume
or type of equipment.
DisabilityCare will aim to provide Australians living with a disability and their families with the
resources, information and support so they have the same opportunities as everyone else. As
DisabilityCare is rolled out across states, the emphasis on contracted supply arrangements and
non-tendered purchasing may increase in order to manage funding and ensure the scheme
remains within the budget agreements. However, with the increase of people who may be
covered under DisabilityCare is predicted to increase by the Productivity Commission, the need for
individualised funding to allow for individualised choice is imperative
Under recommendation 7 of the Australian Human Rights Commission Submission to the
Productivity Commission Inquiry into Long Term Disability Care and Support (29 June, 2010)
advocates for institutional roles to be assigned, for achieving reasonable adjustments, in all of the
areas of life, including:
“Provision of access to practical information,”
By expanding Government resources to include a price comparison, most likely in the form of a
website, of available on the market consumers will be able to determine for themselves what
product is right for them depending on a range of criteria – price inclusive, rather than a
standardised ‘one-size-fits-all’ approach.
The communication technology now exists for consumers to readily compare prices and products
in an online environment. Government would go a long way to assist consumers by providing the
tools and resources that would enable consumers to speak with each other and request
information within a controlled online environment.
Comparative pricing arrangements are supported by governments in various jurisdictions
(including by the Commonwealth) to compare utility pricing plans and options. This does require a
sophisticated online portal.
However, issues regarding such practices include ensuring the website remains up-to-date and
considers fluctuating sale prices. Managing these changes can become a time consuming practice.
Currently, the Federal Government provides funding to 13 national disability organisations who
contribute to discussions concerning disability policy. Their role also encompasses conveying:
“Information between government, their membership and the broader community on social
policy issues and represent their constituencies’ views.”
If an agreement between the Government and the national disability organisations can be
reached, this would divide the responsibility of managing and reviewing pricing and product
options. This method would allow the input of each organisation to continue to provide specific
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information regarding their area of disability expertise (i.e. physical, hearing, children related and
so on).
Key recommendation: Commission to explore the role of independent bodies, such as Choice, to be
a central hub to provided analysis and consumer information to aid choice for like-products.
4 – SOURCES OF PRICE DISPARITIES
4.3 Do Australian standards for therapeutic goods raise the cost of aids and equipment?
The standards for therapeutic goods provided a comprehensive guide for the quality of products
released into the market. It is questionable whether the standards effect the price of aids
significantly in comparison to other developed countries. What can be agreed on is that there is no
singular factor that when in isolation raises the price of medical and disability aids in Australian.
Instead, there are a range of factors, all of which, contribute to the overall problem.
There are currently 100 listed retailers of disability aid equipment in Australia. Market power may
be significantly influenced by the procurement process at Federal and/or State levels. Government
policies that tender large contracts for funded schemes to a small proportion of medical aids
suppliers, thus reducing competition and increasing the market power of the few.
According to a report on “Doing Business in Australia” by PricewaterhouseCoopers, the cost of
inflation in Australia has remained steadily slow over the past decade and would be a valuable
selling point to foreign investment in any industry (2010, p10). However, the cost of labour in
Australian manufacturing is recognised as being higher than in other countries. Further, the cost of
innovation is too great in Australia that often technologies are developed overseas.
Consequentially, parts are manufactured overseas.
4.4 Do differentials in the cost of aids and equipment between countries reflect the exercise of
market power?
The Trade Practices Act is regulated by the Australian Competition and Consumer Commission
(ACCC), and prohibits anticompetitive behaviour in Australia as well as the misuse of market
power. Currently, no investigations have been undertaken, or reports presented, that outline any
issues in the market structure of the medical and disability aid suppliers or retailers.
Perhaps, one of the recommendation is for national review by ACCC into this area, particular
looking at the constraints to open market and consumer’s value of fairness and equity.
5 – ENHANCING EFFICIENCY AND COMPETITION IN MEDICAL AND DISABILITY AIDS AND
EQUIPMENT MARKETS
Queensland Standing Offer Arrangement SOA412, for Medical Aids Subsidy Scheme (MASS), such
as Continence Aids Supplier List, reduces shopping around and choice. According to Mass:
MASS has Standing Offer Arrangements (SOAs) for the supply of wheelchairs and wheeled
walking aids, oxygen, continence aids and spectacles. The SOAs are formal arrangements,
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following a prescribed competitive offer and evaluation process, with commercial suppliers
for the supply of these products at an agreed price for an agreed period.
SOAs are in place for the exclusive right to supply these products to MASS and must be
used by MASS, regardless of the expenditure value of individual purchases or the cost that
the product might be able to be obtained from alternative suppliers. Source:
http://www.health.qld.gov.au/mass/soa.asp
Whilst designed to aid MASS’s process, such preferred supplier lists can act as a control and
gatekeeper, making it impossible for people to choose outside of the list. Furthermore, product
information are not readily available to the consumer nor is the price know under the
arrangement.
Open markets offer healthy competition, which also helps to keep markets accountable.
Key Recommendation: PDA would like the commission to explore what role SOAs play in
constraining markets and choice. Open markets offer healthy competition and provide
Notes
i
PDA. (2009). Position Paper on Equipment and Aids required by people with physical disability.
2008 – 2009.
ii
Bricknell S 2003. Disability, the use of aids and the role of the environment. Disability Series. Cat. no. DIS 32.
Canberra: AIHW.
iii
Summers, Michael. Ripe for Reform: Aids and Equipment Policy [online]. Health Issues, No. 105, Summer 2011: 3234. Availability:
<http://search.informit.com.au.ezp01.library.qut.edu.au/documentSummary;dn=785492517509038;res=IELHEA>
ISSN: 0819-5781. [cited 30 Sep 13].
iv
National Aids and Equipment Reform Alliance. (2010). National Aids and Equipment Reform Alliance Submission to
the Productivity Commission Inquiry into a Long Term Disability Care and Support Scheme 10 September 2010.
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Appendix A
PDA. (2009). Position Paper on Equipment and Aids required by people with physical disability.
2008 – 2009.
Recommendations: (page 11-12)
Recommendation 1
PDA believes that equipment for people with disabilities should be under a national system of Aids
and Equipment and managed and/or allocated according to individual need.
Recommendation 2.
PDA believes that people with disabilities require appropriate and affordable equipment and aids
to enable full participation in Australian society, in accordance with self determination.
Recommendation 3
PDA believes for Equipment that more funds are needed for the purchase and supply of disability
equipment, that is up to date and the best item available for the individual according to need, not
cost.
Recommendation 4
PDA believes that more research on the latest equipment available is needed and these items
purchased where needed.
Recommendation 5
PDA believes that more development funds are needed for Australian companies to produce and
supply innovative equipment for people with disabilities.
Recommendation 6
PDA believes that there is a need for equity across the system nationally, in addition to more choice
rather than random distribution of disability equipment based on what is available or affordable.
Recommendation 7
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PDA believes that assessment centres for equipment be advertised and available to people with
disabilities, with particular emphasis and importance placed on rural and remote areas, who often
miss out.
Recommendation 8
PDA believes that if a national equipment scheme is not implemented, then the Commonwealth,
State and Territory governments should immediately implement a combined equipment strategy
as part of the National Disability Agreement.
This equipment scheme should be:

Consistent across all States and Territories;

Have consistent assessment processes and eligibility criteria;

Assessed against the person’s potential rather than their so called deficits;

Have consistent guidelines on co-payments and costs to the individual;

Available to all people with permanent disabilities, regardless of income;

Have the same information available in all states and territories, on websites, brochures
and other methods of information provision;

Able to be transportable across all states and territories;

Should enable individuals with disabilities to be included in Australian society in the most
appropriate way through supply of equipment regardless of situation.
Recommendation 9
Further, PDA believes that the issue of provision of equipment through different schemes is urgent
and needs immediate attention by the Commonwealth Government in order to support
government policies that assist people with disabilities into employment.
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