Chapter 5 Additional Issues
The Personal Emergency Response Services Association (PERSA) and
Tunstall Healthcare raised a series of issues concerning the operation of
medical alarms for aged and at-risk persons under the NBN rollout—in
- support for medical
alarms by NBN retail service providers (RSPs) through the User Network
Interface Voice (UNI-V) port service
- battery back-up for
NBN customer equipment in terms of medical alarm functionality
By way of background, there are ‘approximately 250,000 existing medical
alarms protecting aged and at-risk persons’ in Australia, in both private homes
and residential aged-care facilities.
Tunstall Healthcare has some 72,000 monitored clients in Australia, and its
Brisbane emergency response centre takes over 2,000 emergency calls per
day, with an average of 500 to 600 of those calls per week requiring emergency
assistance. Tunstall Healthcare noted
that it currently had 136 clients living in the NBN footprint, and by June next
year it estimated that 2,000 of its clients would be on the NBN.
Retail Service Providers and Uni-V Port Service
Analogue medical alarms will be supported on the NBN via NBN Co’s User
Network Interface Voice (UNI-V) port, which is supported by the backup battery.
Internet Protocol (IP) based medical alarms will be supported by the NBN over
the User Network Interface Data (UNI-D) product. NBN Co is currently developing
battery backup functionality for the UNI-D and, once this is implemented,
IP-based medical alarms will also be fully supported on the NBN.
Connectivity over the UNI-V port requires a client’s RSP to support the
UNI-V port service and, as PERSA noted, ‘not all RSPs [are to]... support the
analogue (UNI-V) port service’.
Further clarifying this point, Tunstall Healthcare identified that ‘less than a
third’ of the ‘approximately 35 RSPs... who have been accepted and endorsed for
the NBN’ have the ability to facilitate voice calls over the UNI-V ports on the
As not all RSPs will be supporting medical alarms through the UNI-V port
service, consumers will therefore need to select an RSP providing this service.
This raised concerns for PERSA and Tunstall Healthcare about how people would
know which RSP to select to ensure their medical alarm continued to work under
the NBN rollout.
For example, PERSA noted that ‘typical users of medical alarms are not
aware of the technical requirements of their equipment’ and therefore may ‘run
the risk of being locked-in to a long term telecommunications contract with an
RSP which, for them, is unsuitable’. Similarly, Tunstall
Healthcare stated its concern that some clients ‘unknowingly or unwittingly may
sign up to an RSP who cannot support their medical alarm or deliver the service
PERSA proposed a range of initiatives to address these issues:
- ...Require RSPs to
properly inform potential client’s about the compatibility of their service
offering with [medical alarm] equipment...
- Require RSPs to
include information about service compatibility with medical alarms and other
telecommunications equipment in their product sales information.
- Place a list of RSP’s
who can support existing medical alarms through the UNI-V port in a prominent
position on the NBN Co Limited (NBN Co) website.
- In order to ensure
preservation of the correct Mode-3 wiring format for medical alarms, require
all RSPs that remove the copper service to only connect the analogue (UNI-V)
port to the clients incoming copper exchange line.
- In order to ensure
the continuing operation of any medical alarm equipment, require all RSPs to perform
a medical alarm test-call through to the emergency monitoring centre
immediately after service change-over. If the medical alarm fails the test the
RSP should immediately reconnect the copper service to the medical alarm in the
- Lengthen the
telecommunications service contract cooling-off period from 10 days to 30 days,
to allow for further identification of any non-compatible equipment.
- NBN Co. to educate
consumers and RSP’s about the requirements of medical alarms.
- Ensure the copper
service to a client is not disconnected or decommissioned before all medical
alarm connectivity issues are fully resolved.
Like PERSA, Tunstall Healthcare also proposed a range of initiatives to
address these broader issues, including:
- The provision of a
Free Call consumer hotline made available to assist with information and
guidance for consumers with medical alarms.
- NBN Co to provide and
maintain a publically available up to date list of Retail Service Providers who
offer UNI-V (Voice) port services (i.e. landline telephones over NBN) so
consumers can make an informed choice about which NBN RSP can meet their needs.
- As part of the
standards—copper wires and POTS services are not decommissioned for consumers
who have a medical alarm unless their RSP provides for Voice ports (UNI-V).
On the proposal for the establishment of a free-call number, Tunstall
Healthcare further explained:
...we believe it is important that every medical alarm
patient, client, and resident of Australia have an advocacy service in regard
to the benefits and what NBN is actually deploying, as opposed to being an
industry representation or an RSP provision service. That way, a client can
actually get true information in regard to what NBN is about, what the benefits
to them are, and what their requirements are.
In particular, Tunstall Healthcare emphasised the need for the establishment
of a code of conduct for RSPs:
We would like to see some safeguards in place to protect the
vulnerable customer and to ensure that the RSPs adhere to a duty of care for
the service they provide. We would also suggest that it be mandatory that the
RSP investigate the client’s requirements before signing them up to a contract.
Further to this, we would suggest that the code of conduct set some response of
the RSP in relation to the installation of the medical alarm.
PERSA and Tunstall Healthcare also raised a number of issues concerning
battery back-up for NBN customer equipment in terms of medical alarm
functionality—in particular, the short run-time of battery back-up during a
mains power failure in contrast to the requirements of Australian Standard
AS4607 for the provision of personal emergency alarm services.
By way of background, Tunstall Healthcare explained that the current
unit NBN Co are supplying ‘supports six to eight hours of battery supply to the
NTD during a mains fail’. However, as PERSA
pointed out, while it is proposed to provide ‘the standard 6-hour battery
backed-up power supply at no cost to the consumer at the time of NBN service
installation (optional by informed consent)’, this proposed battery run-time
for the NBN customer equipment ‘falls significantly short of the 36 hours
required for medical alarms under Australian Standard AS4607’.
Tunstall Healthcare similarly noted that many of their customers and
corporate client groups ‘expect that their alarm equipment will have a minimum
of 36-40 hours back up support in line with the requirements of the AS4607
standards for the provision of Personal Emergency Alarm Services’.
As Tunstall Healthcare further clarified:
The current AS4607 provides a requirement for 40 hours of
battery capacity or battery back-up to be provided to the medical alarm during
a mains failure or power failure. The standard at this stage highlights the
requirement for 40 hours and that is what the medical alarm actually delivers
to every medical alarm user in the country. It is our understanding that the
existing NBN NTD, or power supply unit, will supply approximately six to eight
hours of battery back-up in the event of a mains failure. That is significantly
less than the 40 hours that is currently provisioned. Obviously that is a
significant difference in regard to what can be provided to a client during a
power failure or an outage of power in Australia...
At the moment, under AS4607, our batteries inside our alarms
last for 40 hours. On the existing infrastructure in place now, prior to NBN,
during a mains fail we will get their alarm calls through for more than 40
hours—40 hours is our minimum. With the introduction of NBN, as soon as the
power supply unit—the NTD—loses power there will be no telephony in or out of
Tunstall Healthcare outlined the potential impact on their clients of
this shorter battery back-up time:
The problem is that if they lose power during the night, for
example, with a 40-hour battery we would get notified that they had lost power
but we would know that they would have power in the morning. We did not wake
them up to say, ‘Margaret, you’ve lost power’ at this stage. When they are
longer than the six hours, we can get through the night and work with the
client and we can work with family the next day to address those issues. The
problem with having a smaller window is that if a power failure happens at say
eight o’clock at night, potentially there is no power for the client to press
the medical alarm button at four o’clock in the morning with no notification.
Mr Geoff Feakes, Chief Information Officer from Tunstall Healthcare,
usefully summarised the issue, as follows:
As an industry we adhere to AS4607 as a standard. With the
provision of the battery backup inside the NTD or for NBN the battery life
standard has been reduced and our industry is concerned about that...
Australian standard AS4607 is in place to provision a service
for the medical alarm client and patient. What we are looking for is extending
the battery backup as currently provisioned by NBN to come back as close as we
can to AS4607, that way providing the best outcome for the patient and the
client so that we can get through a night or a period of time in the event of a
Given this reduced battery back-up time during a mains power failure,
there was interest in establishing the number of power outages generally
experienced each year in the community. Tunstall Healthcare responded that,
‘with our 72,000 clients and patients around the country in the last 12 months
we had some 22,000 power outages notified to our emergency response centre. If
you do the mathematics you would see that we had some 60 patients and clients
who were impacted by power outages every day in Australia’.
Further, given the reduction in battery back-up time from 40 hours to
six to eight hours, the committee was interested in the average length of these
power outages—specifically, in terms of how often power was lost for six or
eight hours. In response, Tunstall Healthcare analysed their national database
for the months of January 2012, May 2012 and August 2012 and provided the
following information about ‘mains failure notifications’
relating to their monitored clients:
- January 2012 = 5229
total mains failure notifications
- Of which 1023 were
greater than 8 hours within any 24 hour period.
- May 2012 = 5162 total
mains failure notifications
- Of which 1150 were
greater than 8 hours within any 24 hour period.
- August 2012 = 4914
total mains failure notifications
- Of which 1118 were
greater than 8 hours within any 24 hour period.
On the basis of these figures, Tunstall Healthcare concluded that a
‘monthly average of 1097 equates to approximately 13,164 instances per year of
mains failures greater than 8 hours’.
Options supported by PERSA to address these broader issues included
- NBN Co supply longer
run-time battery back-up options
- NBN Co allow
after-market suppliers to connect their own, longer run-time, battery backup
Similarly, Tunstall Healthcare made the following proposals to assist in
addressing these issues:
- Standards for installations
be established and published to protect consumers who need and have medical
alarms in their homes or places of residence.
- The existing AS4607
standards are taken into account in the development of NBN installation
standards for the protection of consumers with medical alarms...
- As part of the
standards—the installation of a power pack and back-up battery to the UNI-V
(Voice) ports are mandatory for all consumers identified as having a medical
It is important to highlight here that, at the time of the committee’s
inquiry, NBN Co had recently announced some changes to its process concerning
batteries. For example, Tunstall Healthcare pointed to ‘the recent decision to
power the data points of the network termination unit during a mains failure,
which we see as a positive, and also a modification for the auto-shutdown
functionality from 30 per cent to 50 per cent of remaining battery life during
a main failure’.
A further change involved ‘informed consent of the battery backup. It is
not an opt-in or an opt-out anymore; it is predominantly an informed consent’.
By way of background on this point, NBN Co explained that:
The Government consulted widely with key stakeholder groups
(including emergency service organisations, consumer groups and the medical and
security alarm industry) on the extent to which NBN Co should provide Battery
Backup to different types of end-users (e.g. phone only end-users and Priority
Assist end-users). The 2012-15 Corporate Plan incorporates the Government’s
policy approach that end-users will be able to nominate whether or not they
want NBN Co to provide Battery Backup. This is known as a ‘must-opt’ approach.
At the time of ordering a service from an RSP, an end-user will make an active
decision as to whether to take the battery back-up unit, or to not take the
unit. Priority Assistance households will be provided with a Battery Backup
Under the ‘Must Opt’ regime for battery back-up units, end users can therefore
‘nominate whether or not they want NBN Co to provide Battery Backup’, noting
that ‘Priority Assistance households will be provided with a Battery Backup’.
Under this regime, it is assumed that ‘50% of Fibre End-Users will elect not to
have Battery Backup’.
A key issue under the ‘must opt’ regime, as highlighted by PERSA,
is therefore not only that consumers are aware that battery back-up is optional
at the time of NBN service installation but that sufficient and clear
information is provided for consumers to make an informed choice on this
matter—reinforcing the importance of this being ‘optional by informed consent’.
Connecting Multi-Dwelling Units
The NBN Co updated the committee on how it is progressing on connecting multi-dwelling
units (MDUs) or apartment blocks to the NBN’s fibre network.
The NBN Co confirmed that ‘the installation process in apartment blocks
...take[s] longer than in a single dwelling unit (SDU) because multi-dwelling
units (MDUs) require multiple connections to multiple’ Premise Connection
The NBN Co, however, added that while MDUs are being connected to the
NBN, this process will evolve and become more efficient as the NBN rollout
progresses. The NBN Co stated:
We are working on this. There is no right answer to this.
Every MDU looks different. There is not one method of connecting MDUs, and
installation methodologies do evolve rapidly. Therefore, what we do today will
also change over time because there will be more efficient ways of doing this.
But we are connecting MDUs today.
The NBN Co commented that each MDU has differing numbers of units
ranging from the average of nine to 50, 100 or more, all with differing designs,
which determines connection methodology. The NBN Co explained:
We are using figures which we have experienced to date. There
will obviously be opportunities further in the future. But you also need to
bear in mind that the average number of premises per MDU in Australia is nine.
For instance, a block of town houses is often considered an MDU. If you have 10
town houses, these are basically 10 individual Single Dwelling Units (SDUs) but
are labelled an MDU, potentially. In small apartment blocks, where you have
four, five or six units in a block, it is labelled an MDU, but the installation
methodology would be very, very similar, if not the same, as for an SDU. And then, obviously, you have the very big blocks, where you
have 50, 100 or more units in it. Every MDU is an individual design, because
every premises will look different.
The NBN Co further stated that it:
...will need to have a higher degree of engagement with body
corporate entities and undertake site surveys ahead of time, incurring detailed
design and installation costs for the internal cabling of MDUs.
The NBN Co 2012-2015 Corporate Plan states the NBN Co is using a ‘build
drop’ method to connect MDUs. The ‘build drop’ method replaces the ‘demand
drop’ approach taken previously. The NBN Co explained the difference between
the two build methods and stated:
With a ‘Build Drop’ the connection from the street to the
premises is carried out when the distribution and local segments of the fibre
network are being built. ‘Demand Drop’ is
when the connection from the street to the premises is installed when an order
for a service is received from a retail service provider.
The NBN Co further stated that the ‘Build Drop’ approach will be more
cost effective than the previous ‘demand drop approach’ in the long run. The
NBN Co explained:
The ‘Build Drop’ strategy is expected to be more cost
effective in the long run than performing ‘Demand Drops’, particularly in the
context of the agreement with Telstra to disconnect its copper network. ‘Build
Drops’ from the street to the premises for single dwelling units and
multi-dwelling units arc the most effective way to minimise
mobilisation/dc-mobilisation costs and to realise productivity improvements. It
is more efficient to provide the drop that connects each premises from the
street to the Premises Connection Device...on the outside of the premises, while
the construction crews are in the area.
In regard to consultation on connection of the NBN to MDUs, the NBN Co
2012-2015 Corporate Plan states:
NBN Co will need to have a higher degree of engagement with
body corporate entities and undertake site surveys ahead of time, incurring
detailed design and installation costs for the internal cabling of MDUs.
The committee appreciates the concerns raised by PERSA and Tunstall
Healthcare about the operation of medical alarms for aged and at-risk persons
under the NBN rollout.
The committee was therefore pleased to note that the DBCDE and
NBN Co had held discussions with PERSA and Tunstall Healthcare on these
issues—particularly in light of PERSA’s statement that they were ‘extremely
concerned about a potential life threatening situation resulting from the
rollout of the... NBN in Australia’ in terms of the operation of medical alarms
for aged and at-risk persons. Further, regarding this
statement, the committee acknowledges significant relevant matters raised by
the DBCDE and NBN Co, as discussed below—in particular, paragraphs 5.36-5.43 refer
to medical alarm functionality and the copper network; initiatives undertaken
by the DBCDE and NBN Co; and a key point emphasised by NBN Co that, in the
effective operation of medical alarms over the existing copper network and the
NBN, ‘[a]ll participants have a role to play to ensure that end users are given
access to the services they need’.
In this regard, the committee also notes Tunstall Healthcare’s statement
that: ‘we have put procedures in place to support clients that have shorter
backup battery time, so that we can manage risks on their behalf... if they
were our client we would have an understanding of their situation and we would
manage that accordingly’. Tunstall Healthcare
emphasised that they had been ‘working closely with NBN Co’ to ‘ensure that the
safety of [their] clients is not compromised during the transition across to
the National Broadband Network’.
Accordingly, the committee is aware that the DBCDE and NBN Co have
discussed a range of initiatives with stakeholders to address these issues.
Tunstall Healthcare highlighted to the committee that it understood
NBN Co was seeking possible ‘legislative amendments’ to address some of
We have been working very closely with NBN, and NBN have
attended our industry representation meetings and are fully aware of our
concerns. I believe they are addressing those and seeking legislation to
address those concerns moving forward.
Tunstall Healthcare explained that these possible legislative amendments
included looking at ‘extending of the battery run time to be approximately 30
hours or greater’, considering ‘other
power sources’ in terms of the batteries and seeking ‘alternate
ways... [to] power the NTD’, including considering
‘some requirement for modification to the power supply unit that connects to
the NTD itself to have a more generic plug so that alternative power supplies
can also be sorted’. Tunstall Healthcare
further noted that ‘[c]urrently the battery is only provisioned on the UNI-V
port not the UNI-D port. That is one of the issues they are addressing, being
able to provide the battery backup to the UNI-D port as well’.
In response to this information, NBN Co clarified to the committee that
‘NBN Co is implementing a battery backup model in line with Government policy’
and that a ‘legislative amendment is not required to make changes to the
implementation of the battery backup deployment’.
NBN Co also explained in further detail the outcome of its discussions with PERSA
and Tunstall Healthcare:
During 2011 NBN Co held complex services workshops with
relevant industry stakeholders, including PERSA and Tunstall Healthcare, to
assist in the design and development of the User Network Interface Voice
(UNI-V) product so that it is fit for purpose to support a range of legacy
services, including medical alarms.
More recently, NBN Co met with PERSA in September 2012 to
discuss how medical alarms will be supported over the NBN. Analogue medical
alarms will be fully supported on the NBN via NBN Co’s UNI-V port, which is
supported by the backup battery.
Internet Protocol (IP) based medical alarms will also be
supported by the NBN over the User Network Interface Data (UNI-D) product. NBN
Co is currently developing battery backup functionality for the UNI-D. Once
this is implemented, IP-based medical alarms will also be fully supported on
NBN Co is also working to extend the run time of the battery
for both the UNI-V and the UNI-D ports. Both the UNI-V and UNI-D ports have
Traffic Class 1 functionality, meaning that the highest traffic priority over
the network is available for medical alarms.
NBN Co also highlighted that, outside of its activities, the
Communications Alliance is ‘developing a set of recommendations for how RSPs
inform end-users of their legacy service support at the time of sign up’, in
terms of what legacy service they ‘do and do not support’.
In addition, the recent Communications Alliance Telecommunications Consumer
Protection Code C628:2012 (TCP Code) has ‘increased protections for consumers
who have identified a particular need to their RSP’.
The Australian Communications and Media Authority (ACMA) has
the power to issue a specific direction requiring an RSP to comply with the TCP code. If an RSP has been directed to comply
with the TCP code and does not, the ACMA has powers to issue a formal warning,
or commence proceedings in the Federal Court to issue an injunction or seek
recovery of a pecuniary penalty from the RSP of up to $250,000 for each
contravention of the TCP code.
NBN Co noted that it was convening an industry workshop with RSPs and
PERSA members in November 2012 to ‘discuss medical alarm support and help RSPs
prepare’, and that it was also ‘keeping PERSA briefed on the implementation of
the “must opt” battery backup policy’.
The committee welcomes these initiatives. However, at the time of finalising
this report, the committee had not been made aware of any specific new
announcements in this area. Accordingly, the committee supports further
consideration of a number of the initiatives proposed by PERSA and Tunstall
Healthcare to address these concerns and suggests this be
progressed as a matter of priority. In doing so, the committee acknowledges a
key point emphasised by NBN Co—that is:
It is important to note that the effective operation of
medical alarms—over the existing copper network and the NBN—requires more than
technical functionality. All participants have a role to play to ensure that
end users are given access to the services they need. Customers need to advise
their... RSP of what services they require with their telecommunications
service. Equally, RSPs need to give customers clear and consistent information
about which services are supported so that end-users can choose the right
service to meet their needs...
In addition to the RSPs providing clear information about
what legacy services they do and do not support, there is also a role for the
alarm industry to educate and inform their end-users about the requirements of
their alarms so that their end-users are better able to choose the
telecommunications service to best meet their needs.
Connecting Multi-Dwelling Units
The committee notes the NBN Co’s comments regarding the complexities
involved in connecting MDUs and the implementation of the ‘build drop’ approach
which will provide cost efficiencies in the longer term.
The committee also notes the information regarding MDUs in the NBN Co
2012-2015 Corporate Plan, in particular the need for it to ‘have a higher
degree of engagement with body corporate entities and undertake site surveys
ahead of time.’
The committee believes that a higher degree of engagement with body
corporate entities is essential for the NBN rollout to be carried out to ensure
minimal disruption to households and their surrounding premises, especially in
consideration of smaller MDUs such as townhouse estates.
The committee recommends that the Department of Broadband,
Communications and the Digital Economy (DBCDE) and NBN Co continue to work
with the Personal Emergency Response Services Association, the Communications
Alliance and retail service providers to implement a range of initiatives to
address concerns with the operation of medical alarms for aged and at-risk
persons under the National Broadband Network rollout. This process should be
in consultation with the Australian Communications and Media Authority, with
the DBCDE to report back to the committee on specific progress in this area.