Hearing Aid Bill Written Testimony for the Joint Committee on Financial Services June 28th, 2011
My name is Peter Lee. I am the President of the Massachusetts Hearing Society. We support the hearing aid bill #H325 and oppose hearing aid bill #S429. The following testimonies will detail our position and the reasons for our position.
I am a Board Certified Hearing Instrument Specialist. I am licensed by the Commonwealth of Massachusetts to test and access human hearing and hearing loss, and to restore and rehabilitate hearing by dispensing and fitting personal amplification devices better known as hearing aids. Our products and service fees are reimbursable by the State under the Massachusetts Mass Health Medicaid Program. We are also certified to provide products and services for the Mass Rehabilitation Commission. We have own Federal Standard Occupational Code, which defines our roles, and differentiates us from Audiologists, and Speech Language Pathologists. Collectively, we are known as the communicative disorders professionals. I bring this up because we are an often misunderstood profession and industry, because we are neither doctors, like an Ear Nose and Throat Specialists, nor audiologists, who have more clinical training. In fact up until the early to mid 80's audiologists were not allowed to dispense hearing aids due to the self referral nature of this business, and it was generally considered unethical for an audiologist to dispense hearing aids. It is sort of like the Doctor selling or profiting from the medicines or drugs he/she prescribes to their patients. Hearing Aid Specialists used to be known as dealers, because we handled the "hardware" portion of the business. I submit into testimony the Federal Standard Occupational Code, which further documents and delineates the differences in the three allied healthcare professions. (Appendix A) attached
The Massachusetts Hearing Society is an organization dedicated to advocating for the rights of the hearing impaired. We do this by coming to these forums and speaking out in favor of legislation providing insurance benefits to the hearing impaired. We were here in November 2009 testifying on behalf of the hearing impaired and hard of hearing Massachusetts residents. Our members include: Audiologists, Hearing Instrument Specialists, Students and other hearing healthcare industry professionals who help the hearing impaired. Speaking on behalf of all members of the Massachusetts Hearing Society I want to address some of the keys issues facing the current hearing aid legislation. There are currently eleven (11) hearing aid bills or hearing aids related bills filed for this session, I will limit my comments to broad policy measures, and simplify them into three principles which any final bill must adhere to:
First, the bill must be inclusive, inclusive for all residents of Massachusetts whether they are children, adult or senior citizen. We ask that any bill must be inclusive for any level of hearing disability. A hearing loss is a hearing loss, and a hearing impaired individual needs help regardless of the degree, severity or configuration of their hearing loss. There are some bills which highlight and favor one group over another. We believe inclusion is the only way to go, cover all residents, young and old, and all residents with varying degrees of hearing loss, whether they are mild, moderate, severe or profoundly hard of hearing.
Secondly, we feel the bill should be inclusive for all providers, and not discriminate against any one class of providers, and especially the Hearing Instrument Specialist category of provider. For this reason we oppose Senator Brian Joyce's bill S429, for the simple fact that it excludes participation of hearing instrument specialists as a provider class. The policy is wrong; it is misguided, and inappropriate. We ask the committee ensure that this must not happen. We want to maintain a level playing field, and provide citizens of Massachusetts with competitive products and services, at the most competitive pricing. The only way to achieve this objective is to expand the provider base, and not limit or contract it. Inclusion of all providers is the only way to go; any other approach would achieve less optimal results.
Finally, the bill should provide hearing aid benefits to the residents regardless of whether the provider is a member of the insurance provider network or not. In other words, insurance companies should not be allowed to exclude providers because they are not members of a specific insurance company's network. There is a concerted effort by insurance companies to discriminate against the hearing Instrument specialist and excluded them from their networks. This practice must not be allowed to continue. I want to enter into the testimony a document produced by the International Hearing Society entitled "Statement on Network Provider Inclusion". This document addresses in more detail the need for making provider networks more inclusionary and not exclusionary. (Appendix B) attached
We support Representative Scibak's bill for hearing aids coverage #H325, which we worked closely with Rep Scibak to draft. The whole idea behind the bill #H325, was to mimic the current state health insurance plan, also known as the GIC plan, as closely as possible. This is because the GIC plan, although not perfect, has served the State and the State employees well, for the last 20 plus years.
Let me give you an example why the GIC framework has worked well for the last 20 plus years, and any bill must be continued in this manner. If you are a state employee, and your child has a hearing loss, your child is covered. If your spouse in later years develops a hearing loss, your spouse is covered. If, after you retire, you develop a hearing loss, you are covered. The current state program covers children, adults and seniors alike. No one is left out, and so this plan meets our first criteria for inclusion of all residents.
The GIC plan is portable, which means if you are a state employee, you will receive your hearing aid benefits, regardless of which insurance company you choose to work with. If you are enrolled as a Tufts member, or a Harvard member, or a Fallon member, or a Blue Cross member, or any other insurance company member, you are covered. In other words, the plan stays with you, and goes with you, regardless of the company you choose. Choice of plan also encourages competition and by using a market mechanism will keep costs lower for the consumers.
Finally, the plan allows you to visit any licensed provider in the state. It does not limit, nor does it direct you to go one type of provider or another. Both hearing aid specialists and audiologists are welcomed participating providers. The state employee makes the best decision for himself/herself, because the GIC system allows the consumer to choose. And so as consumers are given a choice, these choices will result in more competition and in the long run help will keep the prices down, which is an added benefit in this time of financial difficulty.
As a licensed hearing aid provider, you don't have to belong to the insurance companies' networks, in order to participate. Your insurance company must reimburse the provider regardless of whether the provider is in-network or out-of-network. Network participation does not matter. This leaves the decision in the hands of the state employee and not some insurance company bureaucrat.
The last and most important part of this plan is that the state has the financial information at their fingertips, to forecast the annual costs of this plan because that financial data is readily available. The GIC plan has been running for the last 20 plus years. It has proven its worth, and has stood the test of time. We ask that you allow the GIC plan to be your guide. Let's not re-invent the wheel, just use the wheel that has worked for years, by adhering as closely to the GIC plan as possible and you would have an excellent piece of legislation and a good benefit for the hearing impaired in our state.
To summarize, we support house bill H325, and oppose senate bill S429. Thank you for your time.
Respectfully Submitted,
Peter Lee, BC-HIS
Mass Licensed #40
President
Massachusetts Hearing Society