Workplace Safety and Insurance Board Noise … · Workplace Safety and Insurance Board Noise...

Workplace Safety and Insurance Board

Noise Induced Hearing Loss Program

Value for Money Audit Report

CONFIDENTIAL

October 24 , 2014

© 2014 KPMG LLP, a Canadian limited liability partnership and a member firm of the KPMG network of independent member firms affiliated with KPMG International

Cooperative (“KPMG International”), a Swiss entity. All rights reserved. KPMG CONFIDENTIAL. 2

Table of Contents

Section Page

1.0 Executive Summary 3

2.0 Scope 7

3.0 Approach 9

4.0 Value for Money Audit Opinion 11

5.0 Observations & Recommendations 13

5.1 Observations & Recommendations – Delivery of Hearing-Related Health Services 15

5.2 Observations & Recommendations – Service Delivery and Case Management 17

5.3 Observations & Recommendations – Strategic Procurement 19

5.4 Observations & Recommendations – Billing and Payment 21

5.5 Observations & Recommendations – Instruments of Prevention 22

6.0 Supplementary Observations – Prevention 25

7.0 Appendices 27

Appendix I The Noise Induced Hearing Loss Program Background 28

Appendix II Value for Money Methodology and Approach 32

Appendix III Data Analysis and Trends 36

Appendix IV Stakeholder Consultation 42

Appendix V Jurisdictional Review 48

1.0 EXECUTIVE

SUMMARY



1.1 Executive Summary

Purpose and Scope:

KPMG conducted a Value for Money Audit (VFMA) of the Noise Induced Hearing Loss (NIHL) Program (“the Program”), for the Workplace Safety and

Insurance Board (WSIB) under its legislative requirement. The primary purpose of the audit was to assess the Program's strategic alignment and delivery

of value for money in accordance with the WSIB’s mandate. The scope of the audit included:

Reviewing the Program in order to assess its cost, efficiency and effectiveness from 2009 to 2013. The areas for review included:

Delivery of Hearing-Related Health Services

Service Delivery and Case Management

Strategic Procurement

Billing and Payment

Policy Framework

Providing recommendations on opportunities for strengthened policies and programs and enhanced cost, efficiency and effectiveness in the above

areas. The recommendations should align to WSIB’s overall strategic goals.

The audit also included a review of NIHL Programs in other workers’ compensation jurisdictions.

Value for Money Audit Opinion:

The Value for Money Audit opinion takes into consideration the structure and function of the NIHL Program from 2009-2013. The Audit was conducted

from June to October 2014. Our observations and recommendations are based on Program information up to December 31st, 2013.

In our opinion, there is significant value in the WSIB delivering the NIHL Program in support of its legislative obligations to workers who experience

occupational NIHL in Ontario. During the period from 2009 to 2013, the Program did exhibit value and produced notable results in terms of meeting the

needs of workers who have experienced occupational noise induced hearing loss. The Program is administered in an efficient manner that meets the

needs of both workers and employers. Examples of notable continuous improvement initiatives are detailed in Appendix I.

Continuous improvement efforts, ongoing revisions to the procurement strategy, and favorable worker and employer experiences with service delivery

indicate that the WSIB is very consistent in the provision of high quality claims management and hearing-related health services for the NIHL Program.

The WSIB relies on the expertise of a range of hearing health practitioners across the province as part of its quality NIHL adjudication model. These

professionals provide the WSIB with a range of medical advice to support both NIHL claim adjudication and ongoing Program service delivery to eligible

workers. It is important, both from legislative and service delivery perspectives, that the WSIB continue to reinforce its commitment to high quality

medical services and Program service delivery. The focus should be on continuing to improve communication with workers and employers about the

adjudication process and criteria for occupational noise induced hearing loss claims.



1.1 Executive Summary (cont’d)

NIHL has a long latency period. The majority of workers who apply for NIHL benefits are older, with an average age of 65. As the general working

population continues to age, claims will continue to increase placing additional resource pressures on the WSIB. In order to address this demographic

risk, the WSIB should enhance its procurement strategy for hearing aid devices and services to take full advantage of the economies associated with

emerging technologies and innovative service delivery models that the market will offer.

However, the future economies associated with market developments for devices and services will not be enough to manage the costs and service

delivery challenges associated with higher claims volumes as a result of the aging workforce. An enhanced procurement strategy is necessary but will

not fully address the root causes of NIHL which can only be further addressed by greater adoption of hearing conservation leading practices within the

workplaces of Ontario. The WSIB should liaise with the Ministry of Labour and the Chief Prevention Officer to support the development and

implementation of strategies to reduce the incidence of occupational noise induced hearing loss in Ontario. A range of initiatives should be examined to

incent employers to proactively introduce hearing conservation strategies in the workplace thereby reducing their associated costs. A stronger focus on

prevention and having the necessary incentives in place will help ensure workers have the opportunity to avoid workplace-related NIHL.

Recommendations:

The following recommendations have been developed for the WSIB to enhance the NIHL Program:

1. Timely and quality health services: Ensuring the ongoing provision of timely and quality health services to workers with occupational noise induced

hearing loss is a priority of WSIB. Assessments and services are provided in workers’ communities by hearing health practitioners. The WSIB should

continue this approach to service delivery while taking into account the emergence of new technologies and service delivery models.

2. Communication excellence with workers and employers: The WSIB should continue to build on the quality service results in its adjudication

program. The focus should be on continuing to improve communication with workers and with employers about the adjudication process and criteria

for occupational noise induced hearing loss claims. It should continue to explore opportunities to extend its e-business model and adjudication

decision support for the NIHL Program.

3. Enhanced strategic procurement: The WSIB should refine its strategic procurement strategy for hearing aids and services to:

Ensure the availability of quality hearing aids to meet workers’ needs and secure the right products at a fair price, taking into account market impacts

of new technologies with increased functionality at lower cost.

Implement an approach to the procurement of hearing-related health services that reflects competitive market pricing and future economies

associated with advances in technology and innovative service delivery models. The approach should address diseconomies associated with the

current fee structure for hearing aid services.

Continue to build the WSIB’s capacity to proactively monitor emerging technologies and alternative service delivery models. In addition, the WSIB

should also conduct ongoing market analysis to ensure that procurement processes and the frequency of procurement cycles are reflective of

emerging competitive products and services as well as pricing trends.



1.1 Executive Summary (cont’d)

4. Strengthened NIHL prevention: The WSIB should liaise with the Ministry of Labour and the Chief Prevention Officer to support the development

and implementation of strategies to reduce the incidence of occupational noise induced hearing loss in Ontario. A range of initiatives should be

examined to incent employers to proactively introduce hearing conservation strategies in the workplace thereby reducing their associated costs.

5. Timely information for employers: The WSIB should also introduce a proactive reporting mechanism to provide employers with more timely access

to NIHL claim and related cost information. This will assist employers in determining the best approach for supporting hearing conservation in their

workplaces.

2.0 SCOPE



2.1 Scope

The scope of the VFMA was to:

Review the Program in order to assess its cost, efficiency and effectiveness from 2009 to 2013. The areas for review included:




Billing and Payment

Policy Framework

Provide recommendations on opportunities for strengthened policies and programs and enhanced cost, efficiency and effectiveness in the above

areas. The recommendations should align to WSIB’s overall strategic goals.

This audit also included a review of NIHL Programs in other workers’ compensation jurisdictions.

The scope of the audit included interviews with WSIB leaders/Program experts and external stakeholder groups. Please refer to Appendix IV for details on

the stakeholder consultation.

3.0 APPROACH



3.1 Approach – KPMG’s Value for Money Audit Approach

The following approach was taken to evaluate the current state of the Program and to develop recommendations on the future state of the Program for

the WSIB. All aspects of the project were guided by the Canadian Comprehensive Auditing Foundation’s (CCAF) Attributes of Effectiveness.

Project Management.

To support the VFM audit, KPMG developed a Project Management Plan and worked with the WSIB to confirm milestones and key dates. At this stage, a

Steering Committee, comprised of persons from the WSIB, was set in place to provide insight, oversight and foresight into the project. The VFM audit

was comprised of four phases:

1. Document Review KPMG reviewed documents pertinent to the Program at WSIB. This information was used to develop an understanding

of the environment in which the Program operates. This phase also included a review of WSIB policies, practices and

corporate documents such as the WSIB’s Strategic Plan, Business Plan and related policies (i.e., WSIB’s Operational

Policies on NIHL).

2. Stakeholder Consultation KPMG conducted interviews with internal stakeholders (management and staff from WSIB) and external stakeholders

(other agencies or groups) of the Program. In advance of the interviews, all interviewees were provided a preparation

guide to focus the discussion. Listings of the internal and external interviewees can be found in Appendix IV.

3. Jurisdictional Review KPMG compared and contrasted the Program performance against leading practices. Information gleaned from the

jurisdictional review was designed to highlight ‘lessons learned’ from like-minded or peer organizations which can be

applied to Program. These included similar, provincially-based organizations such as WorkSafe BC and similarly-focused

organizations.

4. Analysis and Reporting The culmination of the efforts of Phases 1-3 was the analysis, recommendations, and reporting in Phase 4. Results of

this work culminated in the value for money opinion.

Note: KPMG’s Value for Money Methodology & Approach can be found in Appendix II. The Stakeholder Consultation can be found in Appendix IV. The

Jurisdictional Review can be found in Appendix V.

4.0 VALUE FOR

MONEY AUDIT

OPINION



4.1 Value for Money Audit Opinion

The Value for Money Audit opinion takes into consideration the structure and function of the NIHL Program from 2009-2013. The Audit was conducted

from June to October 2014. Our observations and recommendations are based on Program information up to December 31st, 2013.

In our opinion, there is significant value in the WSIB delivering the NIHL Program in support of its legislative obligations to workers who experience

occupational NIHL in Ontario. During the period from 2009 to 2013, the Program did exhibit value and produced notable results in terms of meeting the

needs of workers who have experienced occupational noise induced hearing loss. The Program is administered in an efficient manner that meets the

needs of both workers and employers. Examples of notable continuous improvement initiatives are detailed in Appendix I.

Continuous improvement efforts, ongoing revisions to the procurement strategy, and favorable worker and employer experiences with service delivery

indicate that the WSIB is very consistent in the provision of high quality claims management and hearing-related health services for the NIHL Program.


professionals provide the WSIB with a range of medical advice to support both NIHL claim adjudication and ongoing Program service delivery to eligible

workers. It is important, both from legislative and service delivery perspectives, that the WSIB continue to reinforce its commitment to high quality

medical services and Program service delivery. The focus should be on continuing to improve communication with workers and employers about the

adjudication process and criteria for occupational noise induced hearing loss claims.

NIHL has a long latency period. The majority of workers who apply for NIHL benefits are older, with an average age of 65. As the general working

population continues to age, claims will continue to increase placing additional resource pressures on the WSIB. In order to address this demographic

risk, the WSIB should enhance its procurement strategy for hearing aid devices and services to take full advantage of the economies associated with

emerging technologies and innovative service delivery models that the market will offer.

However, the future economies associated with market developments for devices and services will not be enough to manage the costs and service

delivery challenges associated with higher claims volumes as a result of the aging workforce. An enhanced procurement strategy is necessary but will

not fully address the root causes of NIHL which can only be further addressed by greater adoption of hearing conservation leading practices within the

workplaces of Ontario. The WSIB should liaise with the Ministry of Labour and the Chief Prevention Officer to support the development and

implementation of strategies to reduce the incidence of occupational noise induced hearing loss in Ontario. A range of initiatives should be examined to

incent employers to proactively introduce hearing conservation strategies in the workplace thereby reducing their associated costs. A stronger focus on

prevention and having the necessary incentives in place will help ensure workers have the opportunity to avoid workplace-related NIHL.

5.0 Observations &

Recommendations



We have drafted a series of observations and recommendations to support the VFM audit of NIHL Program which are

focused on the following areas:




Billing and Payment

Prevention

In addition, we have drafted supplementary observations which are of importance to the effectiveness of ongoing efforts

to support hearing conservation and to effectively manage NIHL claims going forward.

Areas of Review



5.1 Observations & Recommendations- Delivery of Hearing-Related

Health Services

Background:

Noise induced hearing loss (NIHL) is recognized as a widespread health concern in Ontario and across the country.

The WSIB is committed to quality service and to cost effective Program outcomes. To deliver the NIHL Program, WSIB works with a range of service

providers including:

Audiologists and hearing health practitioners

Hearing aid clinics

Hearing aid manufacturers

The WSIB has a multi disciplinary team in place to adjudicate claims and to provide support to workers, employers and hearing health practitioners

through streamlined administration and billing and payment processes.

Observations:


professionals provide the WSIB with a range of medical reports and test results that adjudicators use as part of their information gathering to

determine entitlement to WSIB benefits for occupational noise induced hearing loss.

The emergence of online hearing aid business models could result in workers not receiving independent and quality advice from their hearing health

practitioners. Such a business model could detract from the WSIB’s quality adjudication process which places high reliance on professional diagnosis

and advice.

Recommendation:

1. Ensuring the ongoing provision of timely and quality health services to workers with occupational noise induced hearing loss is a priority of WSIB.

Assessments and services are provided in workers’ communities by hearing health practitioners. The WSIB should continue this approach to service

delivery while taking into account the emergence of new technologies and service delivery models.



5.1 Observations & Recommendations- Delivery of Hearing-Related

Health Services (cont’d)

Management Response:

The WSIB agrees with this recommendation.

The WSIB remains committed to ensuring that workers receive the quality health services and the right equipment to address and mitigate their

occupational noise induced hearing loss to improve their quality of life.

The WSIB values the care and services delivered to workers by hearing health practitioners in communities across Ontario, and will continue to work

with them to sustain and improve these services.

The WSIB will review and monitor ongoing opportunities to implement best practices and benefit from new and emerging technology to improve its

delivery of hearing related health services.



5.2 Observations & Recommendations- Service Delivery and Case

Management

Background:

In the context of the WSIB’s new service delivery model, a new approach to NIHL claims adjudication was implemented. This focused on the need for

early intervention and enhanced worker communication, resulting in more timely decision making:

As of the beginning of May 2007, 379 claims were awaiting a decision for longer than 168 days; in May 2013, there were only 2 claims awaiting a

decision.

The timeliness of benefit payments to workers was also improved, for example, a more consistent and efficient process for non-economic loss (NEL)

determination has improved the timeliness of decisions from 4-6 weeks in 2011 to 1.5 days in December 2013.

Overall, workers were very satisfied with the claims adjudication process and turnaround times that the WSIB is providing.

Observation:

Currently, the WSIB has established a policy framework for NIHL which supports the adjudication and case management decision making processes.

NIHL adjudicators are provided with comprehensive training, tools, and resources to assist in determining entitlement in claims from workers

attributing their hearing loss to workplace noise exposure. They receive information and training about how to identify and assess the level of noise in

a workplace. With assistance from WSIB experts, adjudicators ascertain whether the pattern of hearing loss is typical of noise exposure and not likely

to have been generated by other causes e.g., the effects of age and other medical causes of hearing loss. The adjudicators are also guided by policy

in their determinations, including establishing the entitlement amounts and replacement periods for hearing aids.

Employers and workers have access to the WSIB’s NIHL policies through the WSIB’s website.

Consultation with employers indicated that the WSIB could enhance its communication about the criteria and decision making process to adjudicate

hearing loss claims.

In addition, there may be an opportunity to provide support to adjudicators and workers through an electronic decision support tool to increase the

efficiency of the claims management process.



5.2 Observations & Recommendations- Service Delivery and Case

Management (cont’d)

Recommendation:

2. The WSIB should continue to build on the quality service results in its adjudication program. The focus should be on continuing to improve

communication with workers and with employers about the adjudication process and criteria for occupational noise induced hearing loss claims. It

should continue to explore opportunities to extend its e-business model and adjudication decision support for the NIHL Program.

WSIB Management Response:


Quality service is the hallmark of the WSIB’s Noise Induced Hearing Loss adjudication and case management approach. Significant improvements

have been implemented to improve the timeliness of decision-making, as well as communication with workers and employers.

To support continuous improvement in this area, a team is in place to focus on identifying further opportunities for providing clear and comprehensive

information about the NIHL Program.

Initiatives for 2015/2016 include the introduction of new technology to better support quality case management, staff training focused on effective

communication, and better access to NIHL claim information. Improvements to the WSIB’s website will include the addition of more easily

accessible information about noise hazards in the workplace, how to make a claim, and information about NIHL eligibility criteria and WSIB benefits.



5.3 Observations & Recommendations - Strategic Procurement

Background:

The WSIB’s strategic procurement focus for hearing devices is ensuring workers receive quality hearing aids with the functionality they require at the

best possible price.

The WSIB has, over the last several years, engaged in a range of procurement activities to achieve this. This included working with a group of hearing

aid manufacturers in 2005 to obtain quality hearing aids for Ontario workers with NIHL at a reduced price.

Noting advancements in hearing aid technology, the WSIB then began an assessment of hearing aid functionality and features, in relation to worker

needs. Market analysis confirmed that, as technology had developed, a wide range of high quality hearing aids with the functionality to meet worker

needs had become available at a better price.

In 2009, the WSIB launched its first competitive process to procure hearing aids from hearing aid manufacturers. The WSIB subsequently entered into

contracts with 10 hearing aid manufacturers. The WSIB was able to benefit from new hearing aid technologies that provide the required functionality at or

below $1,000 for each hearing aid, significantly controlling the upward trending of costs. In addition to ensure that all workers’ needs could be met, an

exception process was put in place for those who required hearing aids with special functionality above $1,000.

Observations:

The strategic procurement and policy measures initiated by the WSIB in 2009 have shown positive results. It is estimated that hearing aid costs of

approximately $52 million have been avoided between 2009 and July 2014 while continuing to address worker needs.

The cost of hearing related health services is increasing in part due to increasing claim volumes. Despite increasing claim volumes, overall costs are

still lower than they were in 2009.

A review of WSIB procurement data indicated that 6 month clinic visits may be driving up hardware repair, cleaning and tune-up costs. There may be

opportunities to reduce the services costs since digital hearing aid technology has become the norm. It is unknown whether the 6 month clinic visits

add much in the way of effective hearing loss health related outcomes.

Emerging technology and the availability of hearing aids from online vendors is changing the hearing aid industry. As online service delivery options

become more available, consideration should be given to how these changes might impact the WSIB’s current model for delivering hearing related

health services. Of note is the need to address services for older workers who may not have access to newer technology.

The concentrated nature of the hearing aid market suggests there are opportunities to continue to drive down the cost of devices by exercising the

WSIB’s leverage in the market place.



5.3 Observations & Recommendations - Strategic Procurement

(cont’d)

Recommendation:

3. The WSIB should refine its strategic procurement strategy for hearing aids and services to:

Ensure the availability of quality hearing aids to meet workers’ needs and secure the right products at a fair price, taking into account market impacts

of new technologies with increased functionality at lower cost.

Implement an approach to the procurement of hearing-related health services that reflects competitive market pricing and future economies

associated with advances in technology and innovative service delivery models. The approach should address diseconomies associated with the

current fee structure for hearing aid services.

Continue to build the WSIB’s capacity to proactively monitor emerging technologies and alternative service delivery models. In addition, the WSIB

should also conduct ongoing market analysis to ensure that procurement processes and the frequency of procurement cycles are reflective of

emerging competitive products and services as well as pricing trends.

WSIB Management Response:


The WSIB will implement a proactive and effective procurement strategy and plan that will support its commitment to providing quality hearing loss

equipment and services.

The WSIB has been making major enhancements to its approach to strategic procurement, including procurement of hearing aids with the right

functionality to meet worker needs. Beginning in 2015 the WSIB will build key enhancements into the upcoming procurement cycle for hearing aids

and related devices reflecting the findings of this audit. This will include review and analysis of cost and pricing options to ensure the delivery of

timely and cost effective hearing related health services to workers.

The WSIB will also strengthen its capacity to proactively monitor market changes and stay abreast of Program improvement opportunities

associated with emerging technologies.



5.4 Observations & Recommendations - Billing and Payment

Background:

Through its ongoing improvement work, the WSIB has streamlined and expedited its billing and payment processes. The WSIB works in partnership with

hearing aid clinics across the province. To support the clinics in providing more timely service to workers, the WSIB has reduced “red tape” in hearing aid

approvals and has accelerated payment.

Improvements in technology have enabled the WSIB to extend the replacement period for hearing aids. This has reduced the frequency of billing by

clinics, improved efficiency within the WSIB and contributed to ongoing quality services.

Observations:

To expedite payment for hearing aids, hearing health providers bill the WSIB directly through the WSIB billing portal. Controls have been established in

the system for cost amounts and service time frames. Almost all bills are now processed electronically.

Overall, the billing and payment process is efficient and well controlled.

Recommendations:

Please see recommendation number 3 in the “Strategic Procurement” Section.



5.5 Observations & Recommendations – Instruments of Prevention

Background:

A major focus of the Ontario Ministry of Labour's occupational health and safety mandate is the coordination and implementation of strategies to prevent

workplace injuries and illnesses, and setting standards for health and safety training.

The Chief Prevention Officer in partnership with the Ontario Prevention Council provides leadership for this work.

The mandate for the prevention of workplace injuries and illness in Ontario was previously held by WSIB. In 2012, this mandate moved from the WSIB to

the Ontario Ministry of Labour. The WSIB, through its legislative obligations, continues to provide funding to the Ontario Prevention System, and remains

committed to promoting health and safety in Ontario workplaces. In 2013, the WSIB contributed approximately $250M to the Ontario Ministry of Labour

to prevent workplace injuries and illnesses, which includes, among other initiatives, the operation of the Ministry’s Prevention office and the Health and

Safety Associations.

Observations:

Jurisdictional research from the UK has indicated that most of the workers expected to use hearing protection either get no protection whatsoever or

the performance of their Personal Protective Equipment (PPE) is inadequate. A singularly focused strategy on PPE is simply not enough to mitigate the

risk associated with noise in the workplace. Peer group pressure and group behavior plus reluctance of supervisors to enforce wearing protection are

cultural factors that inhibit the effectiveness of a PPE strategy. Research has shown that hearing protection was most effective in companies where it

was implemented as part of a comprehensive noise control program. This is largely due to the cultural and management attitudes towards preventing

NIHL.

The research indicates that an effective hearing conservation strategy should include the following:

Baseline audiogram testing for workers performing functions which have a high NIHL risk

Adequate orientation awareness and training programs

Engineered solutions to reduce workplace noise

Continuous auditing of the effectiveness of hearing conservation initiatives in the workplace

Efforts should be focused on higher risk areas and activities. Command and control edicts making whole sites or departments mandatory

hearing protection zones when a significant proportion of the workforce is not at risk can be counter productive




(cont’d)

As observed on the MOL website, “the preferred and most effective way to control noise exposure is through engineering controls at the source or

along the path of transmission. In keeping with good health and safety practice, hearing protection devices (HPDs) should always be considered as a

last resort. Engineering and administrative controls are preferable to HPDs because these devices are often less protective than their ratings, due to

such factors as improper selection, poor fit, deterioration, user discomfort, and lack of user motivation.” Source: Ministry of Labour; Amendments to Noise

Requirements in the Regulation for Industrial Establishments & Oil and Gas-Offshore

Currently, approaches to encourage hearing conservation efforts are not explicitly defined in Ontario’s Integrated Health and Safety Strategy. This

should become a priority. Previous reports on health and safety prevention have recommended moving towards a system of health and safety

accreditation in the Province. Implementing a leading practice hearing conservation program in the workplace should be reflected in the evaluation

criteria, in the event that the Ministry of Labour moves towards health and safety accreditation.

As part of Ontario's health and safety system, the Health and Safety Associations are recognized by the Ministry of Labour, and the Workplace Safety

and Insurance Board as designated trainers and consultants for employers and workers on Occupational Health & Safety.

The health and safety associations (HSA) provide occupational hearing loss information, including educating key employer and employee

representatives groups about the unique characteristics of hearing loss which clearly distinguishes work related, age, lifestyle and

epidemiological causes. They also provide training, sector-specific services, and best practices for workers and employers in Ontario

The collective awareness and education strategy should support efforts to identify emerging demographics as well as leading practices for hearing

conservation programs in the workplace.

While strategic procurement efforts are important to controlling overall Program costs, the significant opportunity rests with further incentives and

investment by employers to implement hearing conservation initiatives to prevent NIHL.

High risk sector employers can be incented to adopt or further invest in hearing conservation through a range of options, including experience

rating and targeted sector incentives.

Employers indicated that it would be beneficial to have more timely access to NIHL claim and related cost information. This cost information will

provide employers with better understanding of the impact of NIHL claims on their organization and further support continued investments in hearing

conservation initiatives.

http://www.labour.gov.on.ca/english/hs/pubs/noise/gl_noise_3.php




(cont’d)

Recommendation:

4. The WSIB should liaise with the Ministry of Labour and the Chief Prevention Officer to support the development and implementation of strategies to

reduce the incidence of occupational noise induced hearing loss in Ontario. A range of initiatives should be examined to incent employers to

proactively introduce hearing conservation strategies in the workplace thereby reducing their associated costs.



The WSIB recognizes that, for many workers, enhanced hearing conservation programs could prevent the development of occupational noise induced

hearing loss. The WSIB will liaise with the Ministry of Labour and the Chief Prevention Officer to examine and implement possible strategies and

initiatives to incent employers to proactively reduce occupational noise induced hearing loss in the workplace.

Recommendation:

5. The WSIB should also introduce a proactive reporting mechanism to provide employers with more timely access to NIHL claim and related cost

information. This will assist employers in determining the best approach for supporting hearing conservation in their workplaces.



The WSIB is committed to ensuring that employers are provided with meaningful information to make sound decisions to prevent illness and injury in

their workplaces. The WSIB will make improvements to its website to improve access to NIHL information.

6.0 Supplementary

Observations -

Prevention



Supplementary Observations – Prevention

Through our research and stakeholder consultations we developed a series of observations that can enhance hearing conservation efforts within the

Province of Ontario. It is our view that these observations will provide valuable input into ongoing efforts to continuously improve hearing loss

compensation and prevention strategies. The observations reflect the following themes: 1) Long Term Impacts of NIHL; and 2) Engineered Noise

Solutions Standards.

Long Term Impacts of NIHL

1. In order to fully understand the impact of both work related and lifestyle causations of hearing loss for younger workers, the compensation insurance

scheme and hearing loss prevention efforts of the province would be well served by a longitudinal study across a variety of high risk sectors such as

Manufacturing, Construction and Schedule 2 employers. Such a study could include the development of a hearing loss statistical and trends

database. Such a database could provide: 1) early warning in trends analysis to employers allowing for early intervention for high risk workers; 2)

valuable sectorial information; and 3) support for both the WSIB’s actuarial and rate analysis and the Ministry of Labour’s NIHL prevention strategy

refinement. The database could support efforts to further align NIHL incentives, prevention and potential health and safety accreditation initiatives

within the province.

Engineered Noise Solutions Standards

2. Research indicates that the most effective prevention mechanisms to reduce NIHL are engineered solutions to reduce noise in the workplace. The

current Canadian standard CSA Z1007 – Management of Occupational Hearing Conservation Programs provides guidance on establishing hearing loss

prevention programs. There may be an opportunity to increase standards on engineered solutions which address the root cause of hearing loss risk.

Efforts should be undertaken with the Canadian Standards Association (CSA) to explore the feasibility of establishing a technical committee to

introduce/modify equipment and engineered solutions noise level standards in Canada. Such a standard, for noise reduction performance will further

incent employers to invest in leading practice conservation programs with a strong focus on engineered solutions.

7.0 APPENDICES

Appendix I

The Noise

Induced Hearing

Loss Program

Background



Appendix I – The Noise Induced Hearing Loss Program Background

About Occupational Noise Induced Hearing Loss:

Occupational Noise-induced hearing loss (NIHL) is a permanent loss of hearing in both ears resulting from sensorineural (inner ear) damage due to

prolonged, continuous, hazardous noise exposure.

This type of hearing loss is a cumulative process that develops over many years.

WSIB’s NIHL Program:

The WSIB’s NIHL Program is dedicated to ensuring workers with occupational NIHL across Ontario receive the services and equipment they require to

address their hearing loss and improve their quality of life.

The NIHL Program has a number of components. These include:

Strategic procurement

Policy services

Delivery of hearing-related health services

Adjudication and case management

Billing and payment

The Program operates within the framework of the Workplace Safety and Insurance Act (WSIA)

Operational policies to support NIHL Program include:

Policy 16-01-03, Occupational Noise Induced Hearing Loss

Policy 16-01-04, Noise Induced Hearing Loss On/After January 2, 1990

Policy 16-01-04, Tinnitus, Pre-January 2, 1990

Policy 16-01-08, Tinnitus, Post-January 2, 1990

Policy 17-07-04, Hearing Devices




(cont’d)

The WSIB focuses on delivering timely, quality support and benefits to workers.

Continuous Program Improvements:

The WSIB has implemented a number of continuous improvement initiatives that have enhanced services for workers and employers. These

initiatives were supported through key revisions to the NIHL policy framework.

Service Delivery and Case Management:

In the context of the WSIB’s service delivery model, a new approach to NIHL claims adjudication was implemented. This focused on the need for

early intervention and enhanced worker communication, resulting in more timely decision making.

Significant improvements in the timeliness of decision-making were achieved

The timeliness of benefit payments to workers was also improved, for example, a more consistent and efficient process for non-economic loss

(NEL) determination has improved the timeliness of decisions from 4-6 weeks in 2011 to 1.5 days in December 2013

Overall, workers have been satisfied with the claims adjudication process and turnaround times that the WSIB is providing.

Delivery of Hearing-Related Health Services:

To deliver the NIHL Program, the WSIB is working with a range of service providers to ensure worker needs are met. The WSIB values the care

and services delivered to workers by hearing health practitioners in communities across Ontario.

Strategic Procurement:

The WSIB has, over the last several years, engaged in a range of procurement activities to ensure that workers can receive hearing aids with the

functionality they require.

Noting advancements in hearing aid technology, the WSIB undertook an assessment of hearing aid functionality and features, in relation to worker

needs. Market analysis confirmed that, as technology had developed, a wide range of high quality hearing aids with the functionality to meet

worker needs had become available at a better price.

In 2009, the WSIB launched its first competitive process to procure hearing aids from hearing aid manufacturers. The WSIB subsequently entered

into contracts with 10 hearing aid manufacturers. The WSIB was able to benefit from new hearing aid technologies that provide the required

functionality at the best possible price.

These initiatives have shown positive results, including significant outcomes in Program service and cost effectiveness.




(cont’d)

Billing and Payment:

The WSIB works in partnership with hearing aid clinics across the province. The WSIB has streamlined and expedited its billing and payment processes.

This has enabled the clinics to provide more timely service and support to workers.

Prevention:

A major focus of the Ontario Ministry of Labour's occupational health and safety mandate is the coordination and implementation of strategies to prevent

workplace injuries and illnesses, and setting standards for health and safety training.

The mandate for the prevention of workplace injuries and illness in Ontario was previously held by WSIB. In 2012, this mandate moved from the WSIB to

the Ontario Ministry of Labour.

The WSIB, through its legislative obligations, continues to support the Ontario Prevention System, and remains committed to promoting health and safety

in Ontario workplaces.

Appendix II

Value for Money

Methodology and

Approach



Appendix II – Value for Money Methodology and Approach

KPMG’s value for money methodology is grounded in the Canadian Comprehensive Auditing Foundation’s Attributes of Effectiveness.

KPMG’s approach involves the independent assessment of whether a program function or activity achieves their stated objectives, is well-managed

and delivers services economically, efficiently and effectively.

Emphasis is placed on strategic alignment, achievement of intended results assessing performance management, including the measures chosen to

assess performance and the relationship between benchmarks and outcomes. Finally, our approach seeks to identify the risks to the achievement of

economy, efficiency and effectiveness of a particular function or activity.

Three principles underlie KPMG’s value‐for‐money audit approach:

Economy: This principle relates to minimizing the cost of resources used to drive the processes and activities. This assessment takes into

account the quality of the goods or services delivered. This principle also focuses on the soundness of the administration and management of

resources and the extent to which such administration and management is consistent with relevant corporate policies and procedures and legal

and/or regulatory requirements and constraints;

Efficient: This principle relates to the relationship between the goods and services produced/delivered by WSIB and the resources used to

produce them. Efficient organizations produce maximum outputs from any given set of inputs, without sacrificing the quality of outputs; and

Effective: This principle relates to the extent to which WSIB achieves its pre‐determined objectives and compares the actual versus intended

outcomes across a variety of areas.



Appendix II – Value for Money Methodology and Approach (cont’d)

The Canadian Comprehensive Auditing Foundation (CCAF) attributes of effectiveness include:

Clarity of Roles and Responsibilities: Does everyone understand what they are meant to be doing?

Strategic Focus: Do activities (priorities) continue to make sense in terms of the conditions, needs or problems to which they are intended to

respond?

Appropriateness of Investment: Are levels of effort and selected methods of pursuing objectives sensible and sufficient?

Environmental Scanning: How well are we anticipating and responding to the needs of our environment?

Values and Ethics: Are our organization’s management and operations guided by a clear set of appropriate values and ethics?

Management of Results: Achievement of Intended Results: How challenging are our established goals, and have they been accomplished?

Financial Results: How well do financial statements appropriately match, account for and value revenues, costs, assets and obligations?

Stakeholder Engagement: Are clients and other key stakeholders satisfied with the organization and its products or services?

Capacity & Economy of Time and Resource: Can we ensure our ongoing capacity to maintain and improve performance?

Risk Management: Have we identified and dealt appropriately with the key risks associated with our policies and goals?

Strategic Partnerships: Do we know whether strategic partners can adequately fulfill our business objectives?

Secondary Impacts: What are the unintended effects of our activities, both positive and negative?

Protection of Assets: How well do we protect against surprise events or losses of key personnel, critical competencies, client information, facilities,

equipment, inventories, processes or agreements?

Costs and Productivity: Are the relationships between costs, inputs and outputs favorable? Can we demonstrate impact for our investments?

Monitoring and Management of Results: Do we keep track of our results?



Appendix II – Value for Money Audit Methodology and Approach

(cont’d)

The following table provides an overview of the approach taken to conduct the value for money audit of the Program:

Phase Stage Steps & Activities Deliverables & Due Date

Stakeholder

Interviews

I: Kick Off Confirm project scope, timelines and

deliverables with WSIB Project Sponsors

Develop map of key stakeholders (internal

and external)

Project timelines and due dates

Completed June, 2014

II: Internal Stakeholder

Engagement

Develop interview guide

Conduct interviews of internal stakeholders

Analysis of interview results; identification of

key themes and areas of opportunity

Review internal documents

Approved stakeholder map

Approved interview guide and introduction

letter

Completed internal interviews

Document review

Presentation of interim results & key findings at

Steering Committee

Completed July, 2014

III: External Stakeholder

Engagement

Develop interview guide

Conduct interviews of external stakeholders

Analysis of interview results and leading

practice review

Approved interview guide

Completed external interviews

Leading practice review

Develop report with key findings

Completed September, 2014

Document Review,

Analysis, & Final

Report

I: Program Review Review internal documents Document review



II: Evaluation of WSIB’s NIHL

Program

Evaluate Research Governance Framework

using the CCAF Attributes of Effectiveness



III: Jurisdictional & Leading

Practice Review

Conduct leading practice review Develop report with key findings

Completed October, 2014

IV: Value for Money Audit

Opinion

Develop final report Completed October, 2014

Appendix III

Data Analysis and

Trends



Workers come from

various sectors across the

province

As illustrated in the chart,

the top 5 sectors for

allowed claims over the

last 10 years are:

Manufacturing

Construction

Schedule 2

Services

Transportation

Appendix III – Data Analysis – Sector Analysis

MANUFACTURING25.8%

CONSTRUCTION15.2%

SCHEDULE 212.7%

SERVICES7.3%

TRANSPORTATION6.0%

AUTOMOTIVE5.9%

PRIMARY METAL4.8%

MINING4.5%

CHEMICAL/PROCESS3.9%

FOOD3.7%

PULP & PAPER2.5%

FORESTRY2.5%

ELECTRICAL1.6%

MUNICIPAL1.6%

EDUCATION0.8%

AGRICULTURE0.6%

HEALTH CARE0.6%

Percentage of claims by sector



-

200

400

600

800

1,000

1,200

2004 2005 2006 2007 2008 2009 2010 2011 2012

Cla

ims

2004-2012 Allowed Claim Volume

AUTOMOTIVE CONSTRUCTIONMANUFACTURING SCHEDULE 2SERVICES TRANSPORTATIONOTHER

Observations:

The top sector, with the highest volume of claims is Manufacturing:

In the last 9 years, it has increased by 55% (on average, by 4% each year)

Another key sector is Construction:

In the last 9 years, it has increased by 31% (on average, by 2% each year)

Other areas of continuing interest and large growth include Services and Transportation:

In the last 9 years, Services has increased on average, by 7% each year and Transportation on average, by 7%

each year

The category “Other sectors”

includes: Agriculture,

Chemical/Process, Education,

Electrical, Food, Forestry,

Health Care, Mining,

Municipal, Primary Metal and

Pulp and Paper

Due to the maturity of the

data, sector analysis includes

data up to 2012

Appendix III – Data Analysis – Sector Analysis

4%

2%

5%

7%7%

-2%

4%

-3%

-2%

-1%

0%

1%

2%

3%

4%

5%

6%

7%

8%

% Y

oY

Change

2004-2012 Year over Year Average Change in Volume of Allowed Claims

Registration Year



Noise induced hearing loss (NIHL) is recognized as a wide-spread health concern in Ontario and across the country. The

WSIB is currently experiencing increasing volumes of NIHL claims. The Program operates within the framework of the

Workplace Safety and Insurance Act (WSIA) and a number of WSIB policies.

The demand for services continues to grow:

The volume of newly registered claims has significantly increased, with the largest increase of 27% from 2007-

2009. These volumes remain high with almost 5800 newly registered claims received in 2013 (2.5% of total WSIB

claims registered)

The cohort of workers in the NIHL Program is predominantly male (95%), older and generally retired, with an average

age of 65 years

0

200

400

600

800

1,000

1,200

1,400

1,600

0 - 20 21 - 30 31 - 40 41 - 50 51 - 60 61 - 70 71 - 80 81 - 90 over 90

Age for Allowed Claims

2009 2010 2011 2012 2013Registration Year

Appendix III – Claims Profile

Age

Allo

wed C

laim

s



Appendix III – Data Analysis – Cost Overview

The NIHL Program costs include: hearing aids; hearing aid services; Program of Care; batteries, assistive devices and

related components; hearing tests; and other worker benefits, including loss of earning and non-economic loss.

$-

$10,000,000

$20,000,000

$30,000,000

$40,000,000

$50,000,000

$60,000,000

$70,000,000

2009 2010 2011 2012 2013

Cost

Payment Year

NIHL Program Costs 2009-2013



Appendix III – Data Analysis and Trends – Population and Pricing

Ontario Population Trends:

“The number of seniors aged 65 and over is projected to more than double from about 2.0 million, or 14.6 per cent of

population, in 2012 to almost 4.2 million, or 24.0 per cent, by 2036. The growth in the share and number of seniors will

accelerate over the 2012–2031 period as baby boomers turn age 65. After 2031, the growth in the number of seniors

will slow significantly.”

Source: http://www.fin.gov.on.ca/en/economy/demographics/projections/

Technology Pricing Trends:

According to the chart above; consumer electronics products have reduced in price on average by more than half. The

combination of market competition and low cost manufacturing has streamlined production processes and lowered

prices. The exceptions are MP3 players and hearing aids. MP3s experienced a price jump because its capabilities have

advanced exponentially over the past decade going from storing 128MB of data (roughly 12 songs) in 2000 to storing

160G of data (roughly 40,000 songs) or more today. Hearing aids prices have risen partly because they’re covered by

insurance and partly because of demand. It’s an industry well positioned for a radical overhaul.

Source: http://www.futuristspeaker.com/2013/04/how-google-glass-will-disrupt-the-hearing-aid-industry/

-60%-50% -50% -50% -50% -50%

-48%

67% 67%

-80%

-60%

-40%

-20%

0%

20%

40%

60%

80%

10 Year Price Evolution: Hearing Aids vs. Other Electronic Products

http://www.fin.gov.on.ca/en/economy/demographics/projections/

http://www.futuristspeaker.com/2013/04/how-google-glass-will-disrupt-the-hearing-aid-industry/

Appendix IV

Stakeholder

Consultation



Appendix IV – Stakeholder Consultation

KPMG developed an approach to stakeholder consultation with both key internal and external subject matter experts to gain a broad based

multidisciplinary perspective on the strengths and challenges facing the Program. Participants were asked for their perspectives on key strengths and

weaknesses of the existing Program and key opportunities to improve the Program.

Internal Stakeholder Interview Guide

1. Can you describe your current role at the Board? What is the nature of your interaction with the NIHL Program?

2. When you think about the NIHL Program what comes to mind in terms of:

a. Strengths?

b. Weaknesses?

c. Opportunities?

3. The delivery of the NIHL Program requires coordinated efforts from across many areas of the Board – strategic procurement, adjudication, billing and

payments. Operating both efficiently and effectively requires coordinated efforts from a number of different areas at the WSIB. From your

perspective, are these component parts working as effectively as they could? If so, what is working well? Where are there opportunities to improve

performance?

4. Over the past several years, the Board has set in place Program Interventions to improve all aspects of the program. These include: facilitating

approvals, accelerating payment and introducing new exceptions process and extending the hearing aid replacement period. When you think about

continuous improvement for the NIHL Program:

a. What, from your perspective is working well?

b. What is working not as well?

c. Where are opportunities to continue to improve performance?

5. When you think the Board’s mandate, how well do you think the NIHL’s mandate aligns with that of the WSIB overall? What, if any, are the areas for

improvement?

6. Is there anything else you feel would be important for us to know?



Appendix IV – Stakeholder Consultation (cont’d)

External Stakeholder Interview Guide

1. Can you describe your current role and the nature of your engagement with the WSIB? How familiar are you with the NIHL Program?

2. When you think about the challenge of Noise Induced Hearing Loss across Ontario, what comes to mind? In other words, from your perspective,

what are the trends and opportunities?

3. When you think about Programs, such as the WSIB’s, set in place to address Noise Induced Hearing Loss, what comes to mind in terms of:

a. Strengths?

b. Weaknesses?

c. Opportunities?

4. From your perspective, at a system level, how well coordinated are efforts to address, support and mitigate Noise Induced Hearing Loss? Are

component parts working as effectively as they could? If so, what is working well? If not, where are there opportunities to improve performance?

5. When you think of the overall mandate of the WSIB – how well do you think the NIHL’s mandate aligns with the WSIB overall?

6. Is there anything else you feel would be important for us to know?




Internal Stakeholder Engagement Participants

Internal WSIB stakeholders interviewed for this audit include the Chief Operating Officer and Acting Chief Corporate Services Officer, as well as senior

executives and subject matter experts from the following WSIB business areas:

Operations Finance

Health Services

Occupational Disease and Specialized Services

Channel Solutions

Policy and Consultation Services

Funding Modernization Office

Internal Audit

Actuarial Services

The Office of the President & CEO

External Stakeholder Engagement Participants

External stakeholders interviewed for this audit include:

Workers who receive noise induced hearing loss services through the WSIB

Employers in a range of sectors, including the utilities and manufacturing sectors

Chief Prevention Officer of Ontario, Ontario Ministry of Labour

Ontario’s Health and Safety Associations

Workplace Safety and Prevention Services

Workplace Safety North

Infrastructure Health & Safety Association

Office of the Employer Adviser




Internal Stakeholder Observations:

The interviews revealed that the WSIB, over the last several years had undertaken significant Program improvements. These included:

A range of strategic procurement activities to ensure workers received hearing aids with the right functionality at the best price

A new approach to NIHL claims adjudication with a focus on early intervention and enhanced worker communication

Streamlined and expedited billing and payment processes

A continued partnership with hearing health practitioners across the province

This was enabled through key policy changes resulting in timely and quality service to workers and employers.

The interviews with internal stakeholders indicated that the WSIB is committed to meeting worker needs and ensuring ongoing program quality.

The WSIB recognizes that an aging workforce will have an impact on the volume of future NIHL claims.

Internal stakeholders were very cognizant of the importance of expanding awareness and prevention efforts for NIHL, in order to encourage

workplaces to establish or mature hearing conservation programs. Prevention is critical to strategically managing the trend claim volumes




External Stakeholder Observations:

Throughout the interviews employers have emphasized the importance of prevention and hearing conservation.

Progressive employers indicated that the WSIB should further examine financial incentive options to encourage broader adoption of hearing

conservation strategies.

It was also noted that the WSIB should liaise with the Ministry of Labour and its Health and Safety partners to develop strategies to reduce the

incidence of occupational noise induced hearing loss in Ontario.

Employers identified a need for the WSIB to enhance its communication about the criteria and decision making process to adjudicate hearing loss

claims. Also, employers indicated that it would be beneficial to have more timely access to NIHL claim and related cost information to provide them

with a better understanding of the impact of NIHL claims on their organization. This would help them gain support for continued investments in

hearing conservation initiatives.

Overall, workers were highly satisfied with the claims adjudication process and turnaround times that the WSIB is providing. Access to hearing-

related health services and quality of care were consistently well regarded.

There was strong recognition of the importance of an expanded role for research in further refining the NIHL Program and associated prevention

strategies.

Appendix V

Jurisdictional

Review



Appendix V – Jurisdictional Review

As part of the Value for Money Audit, KPMG conducted a jurisdictional review of Noise Induced Hearing Loss programs from workers’ compensation

boards in Alberta, British Columbia, and Saskatchewan.

It should be noted that due to varying policies regarding entitlement and benefits across the provinces, direct comparisons between provincial benefits

cannot be made.

1. Alberta:

The Workers’ Compensation Board of Alberta administers an occupational noise induced hearing loss program. The program operates under the

Province’s Workers’ Compensation Act, RSA 2000. The policy that governs hearing loss is Policy 03-01 Part II –Application #5.

Entitlement to benefits for NIHL is based on a pattern of hearing loss on an audiogram consistent with occupational noise induced hearing loss and a

clear history of prolonged occupational noise exposure.

Alberta saw a significant increase in NIHL claim volume between 2002 and 2011. During this period, the most affected sector was construction with

25% of the claims.

Alberta covers hearing aids up to a maximum amount. In addition, further costs will be covered for ear molds and appropriate service charges.

2. British Columbia:

WorkSafe BC administers an occupational noise induced hearing loss program. The program operates under BC’s Workers’ Compensation Act RSBC

1996 (s)7 and Schedule D. The policy that governs hearing loss is policy part #31.00 - Hearing Loss.

Workers in BC may be eligible for benefits for NIHL where, as a minimum, evidence is provided of continuous prolonged work exposure for eight

hours per day at 85 dBA or more, and when other evidence does not disclose any cause of hearing loss not related to work.

WorkSafe BC covers the cost of hearing aids up to a maximum amount. The worker can enter a cost-share agreement with WorkSafe BC and the

service provider for a hearing aid exceeding this amount, and in exceptional circumstances, WorkSafe BC may cover the full cost of a hearing aid

above the maximum amount.

Employer audiogram data has been collected since the 1970s. This provides WorkSafe BC with a substantial longitudinal database to study NIHL

trends.



Appendix V – Jurisdictional Review (cont’d)

WorkSafe BC is responsible for prevention. Prevention resources are available on the WorkSafe BC website, where employers can have access to

regulations and guidelines, resources (i.e., noise exposure levels by sectors) along with other reports and statistics (i.e., Hearing Loss Prevention

Annual Statistics).

3. Saskatchewan:

Saskatchewan’s Workers’ Compensation Board administers an occupational noise induced hearing loss program. The program operates under The

Workers’ Compensation Act, 2013. The policy that governs hearing loss is policy 3.1.2 Injuries – Hearing Loss.

Noise induced hearing loss is gradual and due to prolonged occupational exposure of excessive noise levels over a period of years (causing

sensorineural impairment). To be eligible for a claim, there must be evidence of continuous occupational noise exposure for two or more years at the

decibel levels and durations (85dBA for 8hours), and the occupational noise exposure must be the predominant cause. In accordance with the

Canadian Center for Occupational Health and Safety equivalent noise exposure standards, for every increase in noise of three decibels

(Saskatchewan three decibel exchange rate) above 85 decibels, the required daily exposure time (over two or more years) required to result in lasting

impairment will be reduced by half.

Saskatchewan’s WCB pays for the cost of entry level hearing aids and appropriate service charges.

Workplace Safety and Insurance Board Noise … · Workplace Safety and Insurance Board Noise...

Documents

Transcript of Workplace Safety and Insurance Board Noise … · Workplace Safety and Insurance Board Noise...