THE STANDING COMMITTEE ON HEALTH, AGEING AND SOCIAL SERVICES

INQUIRY INTO THE IMPLEMENTATION, PERFORMANCE AND GOVERNANCE OF THE NATIONAL DISABILITY INSURANCE SCHEME IN THE ACT

COMMUNITY SERVICES DIRECTORATE

MARCH 2018

CONTENT

• INTRODUCTION
• NDIS/ACT GOVERNANCE
• WORKFORCE
• PSYCHOSOCIAL DISABILITY
• EARLY CHILDHOOD INTERVENTION
• HEALTH MAINSTREAM INTERFACE
• INFORMATION LINKAGES AND CAPACITY BUILDING
• LOCAL AREA COORDINATION
• MARKET READINESS
• EMERGING GAPS
• HUMAN SERVICES REGISTRAR
• CONCLUSION
• APPENDIX A
• APPENDIX B
• APPENDIX C

INTRODUCTION

The most significant policy development for people with disability, their families and carers in recent years is the implementation of the National Disability Insurance Scheme (NDIS). The NDIS is a new way of funding individualised support for people with disability (including psychosocial disability) that involves more choice and control and a lifetime approach to a person’s support needs. The ACT was the first jurisdiction in Australia to transition all eligible residents into the Scheme by July 2016.

The move to individual choice and control and a market-based model of support under an NDIS is a significant change for the ACT. While the National Disability Insurance Agency (NDIA) is responsible for administering the Scheme in the ACT, the ACT NDIS Taskforce had responsibility during trial for the strategic policy and planning of the design and implementation of the NDIS in the ACT.

Implementation was overseen by a Project Board of Directors-General from ACT Health, Education Directorate, Community Services (Chair), the Head of Service and the NDIA, reporting to the Minister for Disability. Additionally, the ACT NDIS Expert Panel provided strategic advice on issues affecting people with disabilities, their families, carers and the Canberra community.

The Australian Government committed $122.6 million over four years to prepare the Australian disability sector for the NDIS; $0.5 million was assigned to the ACT for specific readiness activities in 2012–13 and a further $12 million for sector development preparation from 2013–14. Detail on the projects undertaken with this funding is at Appendix A.

The Office for Disability

The Office for Disability (OfD) was established in October 2016 as an ACT Labor election commitment through the 2017-18 Budget. $2.2 million over four years funding was provided to support ongoing policy and oversight responsibilities related to the implementation of the NDIS and the ACT commitment to the National Disability Strategy 2010 - 2020 (NDS). The broad remit of the OfD is to provide strategic advice and practical implementation to progress outcomes to include people with disability as valued members of the ACT community.

Election commitments overseen by the OfD include Disability Inclusion Grants, with funding of $200,000 over four years to enable increased opportunities for people with disability to participate in

the community. Other significant responsibilities of the OfD include the development of a Disability Justice Strategy.

NDIS/ACT GOVERNANCE

The ACT is still in the transition stage to full implementation of the NDIS. All eligible people who were previously receiving support from the ACT Government are in the Scheme. The ACT Government continues to work closely with the ACT NDIA and with the NDIA at a national level.

The OfD and the NDIA have jointly developed a Program of Work. The NDIA, ACT Government and the Commonwealth Government Department of Social Services (DSS) will continue to work together through the Program of Work to support the final phase to full establishment of the NDIS in the ACT.

A governance structure has been established to oversee this work and to address any other ACT implementation issues. An organisational chart is at Appendix B.

Council of Australian Governments Disability Reform Council

The Council of Australian Governments (COAG) Disability Reform Council (DRC) provides a forum for member Governments to discuss matters of mutual interest and progress key national reform in disability policy including the NDIS.

The DRC oversees the trial and implementation of the NDIS and makes recommendations to COAG on the transition to NDIS full scheme. The DRC also ensures that a broad range of reforms are implemented through the National Disability Agreement and the NDS to support people with disability, their families and carers.

The DRC is chaired by the Commonwealth Minister responsible for disability and consists of Commonwealth, State and Territory Ministers within disability and treasury portfolios.

The DRC’s work covers the following themes:

• Ensure a broad range of reforms are implemented through the NDS to establish inclusive and accessible mainstream services and systems for people with disability, their families and carers;
• Provide strategic oversight of the transition to full scheme of the NDIS, including oversight of costs and financial sustainability and implementation risks; and

• Make recommendations to COAG on the policy framework for the arrangements for full scheme NDIS.

The DRC has responsibilities under the National Disability Insurance Scheme Act 2013 (NDIS Act) to:

• Consider policy matters that relate to the NDIS or arise under the NDIS Act, including:
  • Views on amendments to the NDIS Act; and
  • Agreement of jurisdictions on NDIS rules.

The DRC meet twice a year and provides an opportunity for all disability Ministers to share their jurisdictions’ experiences and concerns directly with one another, the Commonwealth Minister and the Chair and Chief Executive Officer of the NDIA. The ACT has been active in raising concerns within the forum about a number of issues, including planning processes, support for participants with high and complex needs, and the implementation of supported independent living costs and payment arrangements.

Senior Officials Working Group

The Senior Officials’ Working Group (SOWG) reports to the DRC on key policy areas. This group includes senior officials from all jurisdictions. The group has a program of work including the reinvigoration of the NDS.

Two of the key policy areas that the DRC and the SOWG are working through include: Personal Care in School (PCIS); and Specialised School Transport. There are still issues to be resolved at a national level in relation to the scope of the NDIS funding responsibility for PCIS and Specialised School Transport and how these responsibilities will be operationalised in terms of assessment, funding and service delivery arrangements.

The Principles to determine the responsibilities of the NDIS and other service systems (Applied Principles which are explained in more detail on p.28) specify the NDIS is responsible for funding PCIS ‘additional to reasonable adjustment’ obligations under the Disability Discrimination Act 1992.

A key challenge arises in determining NDIS responsibility to fund PCIS supports in the school system where all personal care supports have traditionally been deemed as ‘reasonable adjustments’. The meaning of ‘reasonable adjustment’ and its application to personal care in the context of the NDIS has not been definitively clarified in case law.

The Applied Principles note that further work must be undertaken on how a student’s personal care needs will be assessed, calculation of the level of funded supports for personal care, and how these funds will be managed/administered. Key issues for consideration include:

• how to measure and cost the provision of PCIS;
• whether it is viable for PCIS to be delivered through individualised NDIS funding packages; and
• how might NDIS funding of PCIS impact on school operations – will there be an expectation for families to exercise choice and control over who provides PCIS for their child? Will this mean external providers delivering PCIS? How does this affect a school’s legal responsibility of duty of care for students?

The Specialised School Transport Program currently provides transport assistance to and from ACT public schools for 352 students with disabilities. The Specialised School Transport Program is currently being funded and delivered by Transport Canberra and City Services as an in-kind service under the NDIS. Although Specialised School Transport has been identified as a funding responsibility of the NDIS, this responsibility is yet to transition from states and territories to the NDIS. This is due to a number of challenges that have been identified in achieving this transition and the need for a nationally consistent approach to the delivery of transport to and from school for students with disability under the NDIS.

During transition to the NDIS, states and territories are continuing to either deliver services directly or pay providers to deliver school transport to students with disability as ‘in-kind’ supports. At this stage there is considerable uncertainty regarding the future of Specialised School Transport eligibility under the NDIS.

The DRC has considered comparative work presented by the NDIA detailing the range of complexities in transitioning Specialised School Transport to the NDIS. This includes:

• questions of how to transition from current block funding and subsidised arrangements to individual funding through participant plans while achieving economies of scale and sustainability for providers;
• how the different arrangements in states and territories will transition into a national scheme; and
• safeguards considerations.

A draft model that hopes to address these issues will be discussed at NDIS public consultation sessions held nationally throughout April 2018.

Trilateral Meeting

The ACT Trilateral meeting provides the strategic oversight for the NDIS implementation. Membership includes senior officials from the ACT Government including Chief Minister, Treasury and Economic Development Directorate and the OfD. This meeting also includes senior officials from the NDIA and DSS. This has recently been superseded by regular bilateral meetings with NDIA senior officials and the OfD.

Bilateral Meetings

The ACT Government also has bilateral meetings with the Commonwealth Government to agree and work through high level intergovernmental agreements such as costs and participant numbers.

On 28 November 2017, the ACT Government signed a bilateral agreement with the Commonwealth for the transition period of the NDIS in the ACT. Core elements of the bilateral agreement include monthly in advance payment by the ACT into the Scheme and that if the NDIA cash reserves are depleted to a cash floor of one month, the Commonwealth and the ACT Government will renegotiate. Further work is now progressing to negotiate a new agreement for full scheme.

Operational Working Group

The Operational Working Group (OWG) provides strategic and operational support for the NDIS implementation. This group is co-chaired by the OfD and the ACT NDIA. Membership of this group consists of officials from ACT Government directorates impacted by the NDIS and the NDIA:

• ACT Health including Mental Health;
• ACT Justice and Community Safety Directorate (Correctional Services and the Public Trustee and Guardian);
• ACT Education Directorate; and
• ACT Community Services Directorate (Child Development Service and Children Youth and Families).

A series of working groups are being established to support the work of the OWG and to implement the work plan. These include working groups on the priority action areas of complexity, mainstream interface and market readiness.

Inter Directorate Committee

To provide high level strategic and policy advice on the implementation of the NDIS in the ACT, an ACT Government Inter Directorate Committee (IDC) has also been established.

The role of the IDC is to facilitate cross-government interaction on the implementation of NDIS and ensure the Territory has a comprehensive understanding of the financial and operational implications as it moves to full scheme. Membership of the committee includes senior ACT Government officials from the Health Directorate, Education Directorate and also has representatives from Chief Minister, Treasury and Economic Development Directorate.

The working relationship between the NDIA and the ACT Government changed after the trial ended in the ACT in 2016. At this point, the ACT became part of the NSW South Region of the NDIA. The NDIA’s priority changed to national full scheme implementation and in particular the roll-out in New South Wales. This resulted in less of an emphasis on the concerns and issues of the ACT Government. This has now improved and a strong working relationship has been re-established.

The NDIA temporarily appointed a Senior Manager to focus in particular on the ACT and committed other resources to this purpose. The ACT Government believes that this should be a permanent arrangement and the Minister has expressed this view to the Chief Executive Officer of the NDIA.

The ACT Education Directorate noted that it has established a strong relationship with the NDIA during the early stages of trial through co-chairing of the cross-sectoral Education Portfolio Working Group. This facilitated a collaborative approach to supporting young people and their families to engage with the NDIS and address operational interface issues (particularly during the scheduled phasing period).

In the ACT, the Education Directorate and the non-government school sector have partnered successfully with the NDIA to deliver the School Leavers Employment Supports Initiative in 2015, 2016 and 2017. This initiative has resulted in close to 200 year 12 school leavers from ACT public schools receiving a package of funded supports to bridge the gap to open employment.

WORKFORCE

The ACT consistently has high labour-force participation and low unemployment rates compared with other jurisdictions. A working-age Canberran is more likely than the average Australian to have a

post-school qualification at Certificate III level or above. A young person (aged 18-24) in the ACT is more likely to be fully participating in post-school education/training, employment or a combination of part-time employment and part-time education/training than a young person in the rest of Australia.

National and local disability sector workforce issues have been identified as a significant pressure. Forecasts estimate that approximately 500 additional workers will be required each year for the next four years in the disability services sector alone. Even if the forecasts are overestimated we still expect that the disability, health and aged care sectors will continue to grow and experience workforce shortages and competition for workers in the future, regardless of the NDIS, because of the ageing of the population.

Many of the workforce issues in the disability sector present as adaptive challenges, they are complex and the solutions may be unclear and/or multifaceted. The issues interrelate with public perceptions about disability service occupations, workforce productivity, managing service user/client choice, labour costs and the current NDIS pricing schedule.

In 2015, the ACT Government undertook work to analyse and forecast ACT sector workforce needs and issues. The work included consultation with stakeholders in the ACT disability sector and across vocational education training (VET) programs. The analysis also drew on national and international research, existing models of successful practice and took into account available assets and resources. This research ‘Investment in sector development: Building the capacity of the ACT disability services workforce’ is at Appendix C.

The ACT Disability Workforce Snapshot (provided by the DSS) indicated that:

• in 2016, 2,015 people worked in the Aged and Disabled Carer workforce (NDIS proxy), an increase of 459 since 2011;
• 58% of Aged and Disabled Carers are employed on a part-time basis;
• in 2016, 48% of the Aged and Disabled Carer workforce was aged between 20-39 years;
• 72% of the Aged and Disabled Carer workforce is female;
• 32% of the Aged and Disabled Carer workforce possess a Certificate III or IV qualification; and
• 26% have year 10 or above secondary education.

As a fundamentally new approach to funding and delivering disability services, the NDIS has motivated ACT providers to seek out and consider new service delivery models and ways of using human capital. As a small jurisdiction with agility and ease of communication, the ACT is uniquely positioned to attempt an innovative approach to sustainably address workforce capacity issues through cross-sector transformation. Some of the key challenges include:

• uncertainty for providers - increased unpredictability for providers about the demand for their services could lead to short term increased use of casual workers;
• diversity - increased demand for workers able to work with socially and culturally diverse people; and
• job role change - increasingly providers will be seeking workers who are able to support people with complex mental health, disability and behavioural needs.

Supply gaps in VET qualified occupations are anticipated in the areas of direct support work, mental health peer support work, coordination and facilitation, supervision, allied health assistance, nursing support, administration and finance and office management. Relevant VET qualifications range from Certificate II to Advanced Diploma level.

Vocational Educational Training

Since July 2015, the ACT State Training Authority (Skills Canberra) has significantly increased its liaison with, and research into, the NDIS sector. Skills Canberra is working to understand the specific issues of NDIS service providers and to encourage the NDIS and VET sectors to work together to design possible solutions, including tailoring VET products to better meet the unique needs of the NDIS sector.

Skills Canberra continues to fund qualifications at the highest subsidy range to support the workforce needs of the NDIS through the Australian Apprenticeship and Skilled Capital programs. These qualifications include:

• Certificate III in Individual Support;
• Certificate IV in Disability; and
• Certificate IV in Community Services.

Traditionally the NDIS and community services sectors have not utilised apprenticeships as much as other sectors. Skills Canberra has adapted its non-apprenticeship programs to incorporate feedback from the Workforce Impact Collective (WIC) NDIS sector-wide workshop (please refer to p.13). This

group identified a number of key requirements in workforce capacity building which will be met by the following Skills Sets, to be funded through Skilled Capital in 2018:

• Induction to Disability; and
• Individual Support - Disability Skill Set.

It has been the ACT Government’s experience that the contribution that VET can make to addressing NDIS workforce planning issues is not well understood at the national disability reform sector level, nor at the local level. Equally, more effort needs to be made by the Skills sector to understand and respond to the workforce issues raised in the disability reform sector.

It is the ACT Government’s experience that NDIS service providers are underutilising the currently available VET products and services to address skills shortages. There are various and complex reasons for this, including:

• employers’ perceived lack of relevance of accredited training to meet their workforce needs;
• systemic barriers to employing trainees; and
• severe shortages of student work placement opportunities.

The lack of VET-appropriate data and research poses a fundamental limitation on the Skills sector’s ability to identify NDIS workforce training and development priorities in terms of VET products. The specific issues include:

• the disability reform sector’s modelling of workforce estimates does not produce occupation specific outputs;
• the Skills sector, on the other hand, maps VET qualifications to the Australia and New Zealand Standard Classification of Occupations (ANZSCO) occupation codes. State Training Authorities do the same when modelling future workforce skills needs for the purposes of allocating training subsidies;
• this mismatch of modelling approaches places substantial limitations on the Skills sector’s ability to respond effectively to NDIS workforce shortages; and
• It also creates barriers for National Centre for Vocational Education Research (NCVER) to undertake research, which is needed in order to advance our understanding of the utilisation of the VET system by the NDIS sector.

There are real questions about the suitability of the current traineeship model for the NDIS sector. There is the potential to utilise funds through the Skilling Australians Fund to help the ACT to meet

the challenge of the underutilisation of traineeships in the NDIS sector. For example, Skills Canberra is open to exploring alternative models for traineeship supervision that better meets the needs of disability services workers and employers (as well as the people living with disability who are purchasing support services).

The Canberra Institute of Technology (CIT) has been working closely with NDIS stakeholders to ensure its services contribute to addressing the workforce development needs arising from the implementation of the NDIS.

Since the introduction of the NDIS in the ACT in 2014, CIT has implemented a range of strategies to gather information from the disability sector about its workforce needs. This information has been used to develop program offerings tailored to the specific workforce challenges faced by workers and disability support services organisations under the NDIS. In addition, CIT has conducted promotional activities aimed at improving awareness within the NDIS sector of the range of offerings and world-class training facilities available to existing and potential disability support and allied health workers.

There remains an ongoing need for a broader range of NDIS stakeholders to more fully engage with the training sector, including CIT, to communicate their workforce development needs. This will assist CIT to continue to design and pilot relevant training that responds to the needs of employers, workers and people with disability.

Workforce Impact Collective

On 11 May 2017 the ACT Community Services Directorate, on behalf of the ACT Government, entered into a Services Agreement with National Disability Services to respond to the forecast increased demand for non-professional disability support workers in the ACT.

The project will assist in building the capacity of the ACT disability sector workforce through a ‘Collective Impact’ approach. This means that the commitment of key stakeholders will be sought to a common agenda for solving the shortage of workers with appropriate capabilities and attributes to meet the growing demand for services under the NDIS. Using a ‘Collective Impact’ approach, key stakeholders will be engaged by the contractor to explore, choose and develop ways to strengthen the base of potential and existing workers who are aware of, positively disposed toward and capable of, working in the disability sector.

The project will develop and implement an application and allocation process though which community partners are able to equitably, transparently and accountably access the financial support required to undertake their proposed pilot project.

This must include the development of a decision making framework to inform decision making about access to pilot funding. Decisions on the choice and undertaking of pilots and on spending will be made by the contractor with the relevant collective impact groups, including the pilot reference groups, in accordance with commonly accepted rules and practice relating to probity.

As of December 2017 the key achievements of the project include the:

• establishment of the Steering Group;
• development of the decision making framework;
• creation of a key performance indicator framework;
• collation of relevant reports and data; and
• development of a common agenda.

Cross Government Steering Committee

A Cross Government Steering Committee (CGSC) has been established to oversee the development, delivery and evaluation of the project. Membership of this group consist of officials from key ACT Government directorates including Skills Canberra, ACT Education Directorate, ACT Health, Community Services (Industry Reform), as well as the Director of ACT Council on Social Services (ACTCOSS). The group is chaired by the Director of the OfD.

The role of this committee includes:

• being champions of the Project;
• monitoring the National Disability Services performance against the deliverables and strategic intent of the project, providing advice, information and policy guidance to National Disability Services regarding cross-sectoral challenges and opportunities, particularly with the health, disability, employment, education and training sectors; and
• monitoring risk and reducing overlap of the work of National Disability Services in delivering the project.

Allied Health Project

In November 2016, the ACT Government invited expressions of interests from three local organisations to undertake a short-term project to assist the ACT allied health sector to thrive under the NDIS and meet the needs of participants. The Community Services Directorate allocated $50,000 for this work from the Commonwealth’s NDIS Sector Development Fund.

National Disability Services delivered this project, which concluded in August 2017. Some key achievements included:

• The NDIS in Practice conference for ACT allied health practitioners on 12 August 2017. The conference provided a forum for ACT allied health practitioners (from a variety of disciplines) to be informed about changes that are transforming the ACT disability sector and hear how others are responding to the opportunities and challenges.
• Three webinars were delivered during the project. The first webinar covered the topic of creating your vision for starting a private practice (6 June 2017) and the second followed on from that with the topic of preparing yourself to start a business (14 June 2017). The topic for the third webinar was ‘A Snapshot of the ACT Allied Health Workforce.’ (29 June 2017). This was delivered by NDS’ National Manager Workforce and Care Careers.
• A fourth webinar was held on 19 October 2017 on how to become a registered NDIS provider in the ACT. This webinar was delivered jointly by the NDIA and the ACT Human Services Registrar.
• Three speed dating events were held which allowed allied health practitioners to network and meet other practitioners. The steering group sees these events evolving into regular quarterly networking events with a guest speaker.
• An information hub has been established which will be hosted by National Disability Practitioners.

PSYCHOSOCIAL DISABILITY

There has been considerable concern and anxiety expressed regarding the inclusion of people with psychosocial disability in the NDIS. In particular the issues of the language of ’permanent’ versus ’recovery’, issues regarding the funding of programs that were transitioned into the NDIS and arguments around the continuation of block funding for mental health programs.

To address these concerns and ensure that the mental health sector and participants were prepared for the NDIS, a specialist mental health officer was seconded from the ACT Health to work in the ACT

NDIS Taskforce. This officer worked across the community sector, ACT Health and the ACT Community Services Directorate.

It was anticipated that approximately 900 people would be eligible for the NDIS including the approximately 350-400 people who were accessing in scope programs. Due to the ages and stages approach it was expected that people with psychosocial disability would transition with higher numbers into the NDIS in year two.

ACT Trial Readiness Activity

Three projects were funded $160,000 under the Commonwealth’s NDIS Sector Development Fund particularly focused on mental health. These included: supported decision making for people with a psychosocial disability, connecting communities and peer workforce development. All Mental Health providers had access to resources under the Commonwealth’s NDIS Sector Development Fund. This included access to the NDIS readiness toolkit, Governance and Financial Management Reform Packages and Business Investment Packages.

In addition in 2015, an extensive project was developed and commissioned to deliver participant readiness activity. A consortium of the Mental Illness Fellowship, Imagine More and Community Connections was selected through an open tender held in February 2015 to deliver a program to support participant preparation for the NDIS in the ACT. This program entitled ‘Your Voice Your Choice, Good Life Planning’ was delivered until December 2016. The program supported people to:

• consider what constitutes a good life for them and to set life goals and objectives to work towards that vision;
• build their capacity to make informed decisions;
• maximise opportunities the NDIS may afford them to exercise choice and control over the supports and services in their lives; and
• assist families to promote and support their family member to exercise personal agency and meaningful citizenship.

Other key deliverables of the project was the Your Voice Your Choice, Good Life planning program would work to raise awareness about the NDIS among people who may not have traditionally engaged with the disability system. Outreach assistance was provided to approximately 100 people targeting those from culturally and linguistically diverse backgrounds, those who may be socially isolated and/or people living in institutional settings.

Working with sector and clinical services

A regular forum was established co-hosted by the ACT NDIS Taskforce, NDIA, ACT Health Community Coalition and the Capital Health Network. Issues covered by the forums have included access and preplanning, and the ‘Mental Health Plan.’ The forum also heard from providers in other trial sites. It was anticipated that due to the eligibility requirements of the NDIS that most people with psychosocial disability would be known to clinical mental health services. Therefore, an extensive implementation plan and communication plan was initiated.

A champions group was established in early 2014. This consisted of clinicians across the public health system. The clinical leader’s network was a change champion network that assisted to facilitate the implementation of the NDIS.

Key products from this group included:

• access video training tool;
• Supported Decision Making Training;
• Evidence of Disability Tip Sheet; and
• Motivational Enhancement Interventions training - to facilitate readiness for change for people in recovery with severe mental illness.

NDIA Activity

A specialist team was established by the NDIA to support access and plan development for people with psychosocial disability. The NDIA was active and visible and worked proactively to support both the sector and participants engage with the Scheme.

Ongoing Issues since completion of trial

As at 31 December 2017, 755 people with psychosocial disability have a NDIS plan in the ACT. This represents 13% of total ACT participants currently in the NDIS. This is a significant achievement and represents some extensive work undertaken by the NDIA and the mental health sector, including clinical services to support people with psychosocial disability enter the Scheme during trial.

It is important to understand the work that was done during trial, as this provides context for the number of issues and concerns expressed by the mental health community since the end of the trial period in 2016.

The experience of the ACT Health Division of Mental Health, Justice Health, Alcohol and Drug Services (MHJHADS) and the OfD is that successful engagement of people with psychosocial disability depends upon strong clinical engagement and advocacy from the clinician who is working with the client. This engagement includes clients who may be subject to Mental Health Orders who are unwilling to engage, or those unable to engage meaningfully in terms of making an application to the NDIS.

ACT Health advised that as a result of clients experiencing difficulty engaging with the NDIS, support that should be provided through an NDIS plan is being cost shifted to ACT Health funded and provided services. An example includes the MHJHADS Recovery Support Officers who provide transport to appointments, assistance with activities of daily living such as shopping, cleaning, etc.

ACT Health has made a provision of approximately $500,000 to be available to community organisations during the NDIS transition to support eligible mental health consumers whose transition to the NDIS was delayed.

There are particular challenges when a person with a psychosocial disability may have a co-morbidity with a psychiatric condition. Although there are guidelines (Applied Principles and Tables of Supports [APTOS], discussed in more detail later in this document) to define the responsibilities of the health system in relation to co-morbidity, operational realities mean that these definitions are not always clear, reinforcing the need for strong clinician engagement.

The episodic nature of mental illness means that plans often need to be modified quite rapidly to support someone who is becoming unwell. However, the process of plan reviews and modifications can take several months. At the same time, regular NDIS plan reviews for mental health clients have been conducted over the telephone with NDIA staff contacting participants without the prior knowledge of the person’s support co-ordinator (this has occurred for residents of Brian Hennessy Rehabilitation Centre for example). Not involving the support co-ordinator increases the risk of inadequate supports being included in a new plan and discharge staff having to submit a request for a new review. ACT Health is also aware that some plans have been ‘auto-renewed’ removing any possibility of the participant changing the goals articulated in their plan. This is of particular concern if there has been a change in functional capacity.

ACT Health also advises that in mental health inpatient units, it is very challenging to obtain visibility of plans, and therefore to link or craft them with a view to discharge. It is also unclear what supports are considered clinical and what can be in a plan. For example, despite general agreement at the OWG that it should fall under NDIS service provision, clinicians have struggled to get ‘medication prompting’ for patients included in a plan, as opposed to medication administration and prescription, which are clearly clinical functions. Medication prompting could, however, be considered a critical service for people with psychosocial disability in order to maintain their independence and participate in the community and employment.

ACT Health has experienced difficulties with NDIS eligibility where a primary diagnosis accepted for NDIS funding is a mental health issue but the supports required for physical deficits which may arise as a consequence of that issue are not covered in plans.

A specific gap that has emerged in NDIS plans is support for people with psychosocial disability where their behaviour manifests as a public safety issue. Under the Mental Health Act 2015 the ACT Civil and Administrative Tribunal (ACAT) may place an individual under a Community Care or Forensic Community Order. The NDIA has consistently stated that support to address public safety issues arising in relation to an NDIS eligible participant is the responsibility of mainstream services.

A current case is costing ACT Health $250,000 to $300,000 per annum to manage. Costs include the provision of supports not covered by the NDIS plan, remuneration for a delegate to oversight the care, as well as administrative and quality/regulation requirements. ACT Health did not anticipate meeting such costs, given these relate directly to a participant’s ability to live in the community and, in our view, do not fall into the category of reasonable adjustment to a mainstream service. The current project work on the Health mainstream interface with the NDIS will assist in clarifying roles and responsibilities in relation to ongoing funding.

The ACT Public Trustee and Guardian (PTG) acknowledge that the interface with NDIS for people with psychosocial disabilities is complex and frequently changing. In practice the NDIS’s “reasonable and necessary” test is arbitrary, with an unclear criteria for determining what is related to a disability and what is related to mainstream supports.

Participant Pathway work

Following extensive feedback, the NDIA has acknowledged that the participant experience of the NDIS has not always been positive. In response a new participant pathway has been developed. Key features of this new pathway include:

• pairing participants with a consistent point of contact based on an individual’s needs;
• a re-designed plan to make it easier for participants to see how their goals have been recorded and linked to community, other government services and funded supports;
• face-to-face planning meetings with a Local Area Coordinator, the participant and an NDIA planner to finalise their NDIS plan; and
• participants being able to see a working version of their plan as it is being developed and having an opportunity to ask questions and provide feedback during the planning meeting, to allow for any queries to be discussed and addressed before the plan is finalised.

As part of the pathway work the NDIA has acknowledged that some people with disability will need a tailored response. This includes people with psychosocial disability. Other groups include young children, people with more complex needs, Aboriginal and Torres Strait Islander communities, people from culturally and linguistically diverse backgrounds, and people in remote and very remote locations.

The NDIA is currently holding an extensive consultation to develop the new tailored pathways. The ACT Government has expressed a strong interest in trialling the Psychosocial Disability Pathway in the ACT, given the significant expertise of the sector in this work.

In its final report the Productivity Commission National Disability Insurance Scheme (NDIS) Costs, Study Report (October 2017) recommended that ‘The NDIA should implement a psychosocial gateway. The gateway should be the primary pathway that people with psychosocial disability enter the NDIS. The gateway should: use specialised staff; operate on a face-to-face basis to the greatest extent possible; consider models of outreach to engage people with psychosocial disability who are unlikely to approach the scheme; provide linkages to both clinical and non-clinical services and supports outside the scheme and collect data on both entrants into the scheme and people linked to services and supports outside the scheme1.’ The ACT Government supports this recommendation.

1 Productivity Commission: NDIS Costs Study Report, October 2017, p 51 (Recommendation 4.4)

EARLY CHILDHOOD INTERVENTION

In the last three years the ACT landscape for the provision of Early Childhood Early Intervention services has changed significantly. In April 2014 the ACT Chief Minister announced a phased withdrawal of the ACT Government from provision of disability services including therapy and early intervention (EI) services. During 2015, therapy and EI services transitioned to the non-government sector. At the same time the ACT Government established the ACT Child Development Service (CDS) as a mainstream service, to ensure continuity of support for children who may not be eligible to participate in the NDIS.

CDS became operational in January 2016, utilising co-located medical and allied health staff to provide a seamless service for young children and their families. These services include assessment and referral for children aged 0-6 years, as well as autism assessment for children up to 12 years of age. CDS promotes appropriate referral pathways, and prior to the commencement of the Early Childhood Early Intervention (ECEI) Partner it has played an important role in referring to the NDIS and other mainstream services. CDS has continued to maintain a focus on assessment and referral, including providing information and advice to families of children aged 0-6 at risk of developmental delay.

The NDIA introduced the ECEI approach to the ACT in May 2017, with the contracted ECEI partner for the ACT, Victorian Non-Government Organisation EACH. In early May 2017 the ECEI partner, EACH, commenced the stand up of its service in the ACT, co-located with the CDS in Holder.

NDIS EACH is the first point of contact for a family with a child who has a developmental delay. NDIS EACH will work with the family to determine if the child’s developmental delays meet thresholds for eligibility to the Scheme. A recommendation to the NDIA for eligibility to the Scheme will be made by NDIS EACH where there is sufficient evidence that the child’s delay is having a significant functional impact in a number of areas and the young person would benefit from funded supports.

NDIS EACH will refer and link families to mainstream services and may also provide short term intervention and support for children who do not meet the NDIA EI eligibility criteria but who would

still benefit from short term supports outside of access to the Scheme. NDIS EACH will also provide interim supports for children who are waiting for access to the Scheme.

The ACT remains committed to the important role early assessment has in effective early intervention strategies. The ACT Community Services Directorate will continue to monitor any potential overlap of services between CDS and the ECEI provider as operations mature, acknowledging the agreed role of the Commonwealth in this area of provision.

Currently CDS provides assessments of development by allied health professionals, and referral and linkages for families of children up to six years of age, at risk of developmental delays. Where a child is identified as requiring ongoing early intervention supports, the family will be linked with NDIS EACH. If ongoing access to supports is unlikely, CDS will provide advice and information to parents to support their child’s development.

Delays

Parents report they experience delays throughout the NDIS process, including eligibility decisions, planning meetings, engaging providers and then additionally awaiting plan reviews. In addition to delays in NDIS processes, feedback from families indicates that some feel they are unable to access all necessary supports because these services are either not provided for, or not funded sufficiently in participant plans.

Since commencement in May 2017, NDIS EACH has focused primarily on undertaking plan reviews for all participants in the ACT aged 0-6 years. This focus on plan reviews has come at the expense of other functions NDIS EACH has been contracted to undertake. This includes community outreach, working with families of children who are not already NDIS participants who have contacted NDIS EACH to seek support and developing NDIS plans for new participants who have met access criteria.

Communication

Concerns have been raised by many service providers regarding the generic nature of NDIS communications to date and an ongoing lack of clarity regarding issues such as referral pathways for access to early intervention, and the interface between NDIS EACH and mainstream service providers.

The NDIS environment is complex, involving multiple agencies. A child may often receive services under NDIS packages and from community support agencies, as well as ACT Health and Education directorates. Communication is not always as effective as it needs to be, nor are the pathways clear. There are often multiple NDIS agencies providing service which can cause confusion and disjointed care for the child and the parents.

Families of children with disabilities have expressed concern to Healthcare Access at Schools staff, regarding their interaction with NDIS. Comments have included:

• difficulty with using the portal;
• lack of communication from the NDIS;
• lack of consideration for access – for example, asking carers to attend evening information sessions even though they are full-time carers;
• lost paperwork;
• requirement for repeat applications;
• early intervention not occurring due to time delays or eligibility issues; and
• significant time delays to access services.

Access to NDIS EACH currently requires families to make contact via a 1300 number. This has proven difficult for families who experience additional challenges and has also limited the ability to share information between services to support these families on their journey.

NDIS EACH is co-located with the CDS and work has been ongoing between the two services to streamline referral pathways. This work has included the development of accessible communication materials for stakeholders, as well as work towards a ‘warm referral’ process between services, to allow families to be introduced to a person, rather than be expected to cold call. This process would also allow services to share information directly to support families through the access process.

In addition, NDIS EACH has undertaken to ensure, in future, that families are provided with the name of an NDIS EACH coordinator within one day of contacting the 1300 number, as well as a future appointment time with their NDIS EACH coordinator.

The ACT Education, Health and Community Services directorates are working collaboratively with the NDIA and NDIS EACH to develop a joint communications strategy in relation to the provision of early intervention services in the ACT. The strategy will ensure development of clear and consistent messaging and resources for stakeholders in relation to the interface between the NDIS, NDIS EACH, and the Child Development Service, including access and referral.

Therapeutic Supports and ECEI approach

There continues to be a lack of clarity around eligibility for children with developmental delay to access short to medium term therapeutic supports through NDIS EACH, and around what supports will be provided. In addition, due to the staffing profile of NDIS EACH, a lack of clarity persists concerning their capacity to be responsive to the needs of children and families at risk. This may be crucial, for example, when a child with aspiration risks requires the family to receive timely supports to meet the feeding and positioning needs of a child.

ACT Health have concerns that the providers who take a ‘key worker’ approach may, in some cases, not be serving the families appropriately. The Community Paediatric and Child Health Service has experience of children with severe language delay having an Occupational Therapist visit under the ‘key worker’ model to provide speech development exercises to the parent – not direct speech therapy to the child.

There are a number of families where advice and information is insufficient to support a child’s development, but NDIS EACH have deemed the child’s needs are not sufficient to access supports. For example, children who stutter or who have delayed or disordered speech sound development. These families currently have no option but to access intervention privately, or via private health insurance and Medicare where available. Evidence indicates that not providing adequate early intervention for these developmental issues can result in long-term communication and/or learning issues for children.

Access and collaboration with the CDS

Towards the end of 2017, NDIS EACH began to deliver some services to those families requiring short to medium-term early intervention supports. The co-location of services has provided NDIS EACH with access to a suitable space to commence a regular playgroup as part of these early intervention supports.

Further negotiations are currently underway for expansion of the co-location of NDIS EACH into Child and Family Centres to allow more flexible place-based access to NDIS EACH. It is expected that from early 2018 families will be able to be supported by Child and Family Centre workers to meet with an NDIS EACH coordinator on site to discuss any concerns regarding their child and to access appropriate supports.

Availability of Therapeutic Services

The development of the service sector is in some cases not keeping up with demand. Even with an approved NDIS plan and funds, a participant may experience issues accessing appropriate providers for services such as speech pathology or psychology. Further growth in the sector may need to occur to better meet the principle of choice for families.

The ACT welcomed the introduction of the ECEI approach, which includes linking families to appropriate supports and providers. However, the significant delays in its establishment has been a source of concern and there is no evidence as yet to assess the impact of the approach.

HEALTH MAINSTREAM INTERFACE

The comments below are intended to highlight opportunities for improvement in the interface between health services and the NDIS.

The NDIS and mainstream health systems will share a significant number of consumers, both in terms of the specific health care required as a consequence of disabilities and the more general health needs of people with disability.

The ACT transitioned to the NDIS earlier than other jurisdictions and in that process ACT Health experienced a range of issues that impacted on service delivery and on individuals who:

• were NDIS participants with plans;
• were NDIS eligible but were awaiting finalisation of plans;
• had finalised plans which did not adequately cover their needs;
• had yet to transition to the NDIS; or
• had functional impairment but were assessed as not eligible for the NDIS.

It has since emerged that virtually all issues experienced by ACT Health in relation to the intersection with the NDIS are now shared nationally by State and Territory health departments. Following a meeting convened by NSW Health in August 2017, which identified priorities for resolution with the NDIA, a workshop was held with the participation of representatives from the DSS, the NDIA, and State and Territory health departments.

The workshop agreed to propose the establishment of a Health Sub-Group of the DRC SOWG to support resolution of these issues. Through a subsequent teleconference, consideration was given to the terms of reference and work plan of the proposed Sub-Group. This has now been agreed by the SOWG and was supported at the December 2017 meeting of the Australian Health Ministers’ Advisory Council (AHMAC).

The immediate work plan of the Health Sub-Group includes actions through to March 2018. After March 2018, the work plan will be reviewed. Key priorities identified in the work plan include:

• clarity on the application of the APTOS and consistent definition of key terms;
• mapping Quality and Safeguards levers;
• clarification on tapering of supports;
• nationally consistent data and information sharing approaches;
• nationally consistent approaches for prioritisation, escalation and resolution of urgent issues; and
• identification and referral of market issues.

ACT Health anticipates that resolution of these issues at the national level will significantly ease some of the operational issues outlined below.

The working group has identified key areas for improvement which have been incorporated into the Health Sub-Group’s work plan.

Definition of terms

A key implementation issue has been the lack of clear definitions for terms used within the context of the NDIS. For example, the NDIS will fund ‘reasonable’ and ‘necessary’ supports in relation to a person’s disability. Neither term is fully defined in the relevant legislation. Other terms frequently

used by NDIA include: ‘universal service obligation’, ‘ordinary life’, ‘prevention’, ‘rehabilitation’, ‘maintenance’, ‘acute care’, and ‘chronic condition’.

Health clinicians and NDIS planners may well have different understandings of such terms which has led to confusion and uncertainty.

The Applied Principles and Tables of Supports

A related issue has been inconsistent interpretation and application of the Applied Principles and Tables of Supports (APTOS), agreed by COAG. This issue was recognised by the Australian Productivity Commission in its October 2017 Study Report on an inquiry into NDIS costs. The Productivity Commission noted that ’while the principles agreed to by COAG on the boundaries between the NDIS and mainstream services are clear, greater clarity is required at the operational level. This will prevent duplication, gaps and cost shifting by the NDIA, and the Australian, State and Territory Governments.’2

Six broad principles, agreed by COAG, determine the responsibilities of the NDIS and other services systems. Under Principle 2: The NDIS will fund personalised supports related to people’s disability support needs, unless those supports are part of another service system’s universal service obligation (for example, meeting the health, education, housing, or safety needs of all Australians) or covered by reasonable adjustment (as required under the Commonwealth Disability Discrimination Act or similar legislation in jurisdictions).

In addition to the six general principles, applied principles have been developed for a range of other service systems to define funding responsibilities in relation to the NDIS. There is also a table of specific activities funded by the NDIS and by other systems, including health and mental health. Together this document is known as the APTOS.

Key applied principles in relation to health include:

• The health system will remain responsible for the diagnosis, early intervention and treatment of health conditions, including ongoing or chronic health conditions. This may involve general practitioner services, medical specialist services, dental care, nursing, allied health services,

2 Productivity Commission: NDIS Costs Study Report, October 2017, p 31

preventive health care, care in public and private hospitals, and pharmaceuticals (available through the PBS);3

• Health systems are responsible for funding time-limited, recovery-oriented services and therapies (rehabilitation) aimed primarily at restoring the person’s health and improving the person’s functioning after a recent medical or surgical treatment intervention. This includes where treatment and rehabilitation is required episodically4; and
• The NDIS will be responsible for supports required due to the impact of a person’s impairment/s on their functional capacity and their ability to undertake activities of daily living. This includes ‘maintenance’ supports delivered or supervised by clinically trained or qualified health professionals (where the person has reached a point of stability in regard to functional capacity, prior to hospital discharge (or equivalent for other healthcare settings) and integrally linked to the care and support a person requires to live in the community and participate in education and employment.5

Key applied principles in relation to mental health include:

• The health system will be responsible for:
  • treatment of mental illness, including acute inpatient, ambulatory, rehabilitation/recovery and early intervention, including clinical support for child and adolescent developmental needs;
  • residential care where the primary purpose is for time-limited follow-up linked to treatment or diversion from acute hospital treatment; and
  • the operation of mental health facilities.6
• Where a person has a co-morbidity with a psychiatric condition:
  • the health or mental health system will be responsible for supports relating to a co-morbidity with a psychiatric condition where such supports, in their own right, are the responsibility of that system (e.g. treatment for a drug or alcohol issue);
  • the NDIS will be responsible for additional ongoing functional supports associated with the co-morbidity to the extent that the co-morbidity impacts on the participant’s overall functional capacity. This applies equally where the impairment is

3 Applied Principles and Tables of Supports (APTOS), 1. Health, Point 2, p.3 4 Applied Principles and Tables of Supports (APTOS), 1. Health, Point 3, p.3 5 Applied Principles and Tables of Supports (APTOS), 1. Health, Point 3, p.3 6 Applied Principles and Tables of Supports (APTOS), 2. Mental Health, Point 1, p.6

attributable to a psychiatric condition and/or is the co-morbidity to another impairment7; and

• the NDIS will be responsible for ongoing psychosocial recovery supports that focus on a person’s functional ability, including those that enable people with mental illness or a psychiatric condition to undertake activities of daily living and participate in the community and in social and economic life. This may also include provision of family and carer supports to support them in their carer role, and family therapy, as they may facilitate the person’s ability to participate in the community and in social and economic life.8

The accompanying Tables of Supports are intended to clarify which operational aspects are the responsibility of the NDIS or mainstream services. The ACT Health experience has been that inconsistent application of the APTOS and unilateral decisions by the NDIA as to what is and what is not ‘in scope’ have led to suboptimal outcomes and delays in both the finalisation of participant plans and, most importantly, in discharge from acute care. This experience is shared by other jurisdictions and is a priority for the Health Sub-Group.

The uncertainty has been particularly prominent in responding to the needs of people who have acquired a disability (for example, because of a stroke or brain injury) and require rehabilitation and then ongoing maintenance. This has impacted on the ACT Health Division of Rehabilitation, Aged and Community Care (RACC).

According to the APTOS:

• The health system is responsible for ’rehabilitative health services where the purpose is to restore or increase functioning through time limited, recovery oriented episodes of care, evidence based supports and interim prosthetics, following either medical treatment or the acquisition of a disability (excluding early interventions). When a participant is receiving time limited rehabilitation services through the health system, the NDIS will continue to fund any ongoing ‘maintenance’ allied health or other therapies the person requires and that are unrelated to the health system’s program of rehabilitation;9’ and

7 Applied Principles and Tables of Supports (APTOS), 2. Mental Health, Point 2, p.6 8 Applied Principles and Tables of Supports (APTOS), 2. Mental Health, Point 3, p.6 9 Applied Principles and Tables of Supports (APTOS), 1. Health, Other Parties, p.4

• The NDIS is responsible for ’allied health and other therapy directly related to maintaining or managing a person’s functional capacity including occupational therapy, speech pathology, physiotherapy, podiatry, and specialist behaviour interventions. This includes long term therapy/support directly related to the impact of a person’s impairment/s on their functional capacity required to achieve incremental gains or to prevent functional decline.’10

In practice this distinction has not always been clear. For example, ACT Health has continued to fund costs associated with two participants living in the community with respiratory issues and who require ventilation, amounting to $1,273,000 per annum. This includes support from Registered Nurses for tracheostomy and catheter changes and direction to support staff such as Assistants in Nursing. Based on the APTOS, ACT Health believes that these supports (including assistive equipment requirements) are essential maintenance supports for these clients and are directly related to their disability. The NDIA interpretation of the APTOS is that these services are the responsibility of mainstream health services.

Similar difficulties have been experienced in terms of assigning and funding responsibility for supports that must be provided by a qualified clinician and those that, whilst clinical in nature, can safely be delegated to a non-clinician (such as the participant, family member or carer).

Under the APTOS the NDIS is responsible for:

• ‘Allied health and other therapy directly related to maintaining or managing a person’s functional capacity including occupational therapy, speech pathology, physiotherapy, podiatry, and specialist behaviour interventions. This includes long term therapy/support directly related to the impact of a person’s impairment/s on their functional capacity required to achieve incremental gains or to prevent functional decline. Also includes allied health therapies through early intervention for children aimed at enhancing functioning11;’ and
• The delivery of nursing or delegated care by clinically trained staff (directly or through supervision), where the ’care is required due to the impact of a person’s impairment/s on

10 Applied Principles and Tables of Supports (APTOS), 1. Health, Reasonable and Necessary NDIS supports for eligible people, p.4 11 Applied Principles and Tables of Supports (APTOS), 1. Health, Reasonable and Necessary NDIS supports for eligible people, p.4

their functional capacity and integral to a person’s ongoing care and support to live in the community and participate in education and employment (including, but not limited to, PEG feeding, catheter care, skin integrity checks or tracheostomy care (including suctioning). The delivery of routine personal care required due to the impact of a person’s impairment/s on their functional capacity to enable activities of daily living (e.g. routine bowel care and oral suctioning) including development of skills to support self-care, where possible’.12

In practice, the NDIS has begun decreasing funding for services that must be delivered by qualified health practitioners and which cannot be delegated. In addition, the NDIA has advised participants and health services that supports traditionally considered ‘maintenance care’ will now be considered as ‘preventative health care’. This has the potential to significantly increase demand for clinical services.

This has particularly impacted on care delivered in the community by RACC clinicians and clarification is being sought as to the funding responsibility for:

• dietetic support for home enteral nutrition (HEN) and consumables;
• tracheostomy care - including costs associated with changing the tracheostomy, as well as consumables;
• catheter care - including change and consumables;
• pressure care - including assistive technology;
• medication support (assistance to self-administer medication where the participant’s need for assistance is directly related to a functional impairment);
• therapy to prevent decline or to maintain or achieve slow/incremental gain in function; and
• general consumables – for example, gloves.

NDIA process impacts on mainstream health

ACT Health is in a position to recognise many patients who would be NDIS eligible and has supported them to engage with the NDIA. Access and engagement with the NDIA has been problematic for:

• people with complex needs;

12 Footnote missing/blank in original text.

• people with psychosocial disability, those with combined intellectual and psychosocial disability, and forensic mental health patients;
• Aboriginal and Torres Strait Islander people;
• people from culturally and linguistically (CALD) diverse backgrounds, including migrants and refugees;
• children with developmental issues or newly diagnosed disability;
• people who are homeless or at risk of homelessness; and
• parents of children with complex needs.

ACT Health staff have assisted where possible with access issues. Many applicants who did not lodge an Access Request Form during the transition phase are experiencing lengthy delays in receiving feedback regarding their eligibility. Potential participants are reporting that their applications are not processed due to an NDIA identified lack of evidence. However, the applicants are not informed of this fact for extended periods of time (often several months). It is only after clients have been informed that further information is needed, and only when the NDIA confirms receipt of all relevant information from the applicant, that the NDIA deems the 21 day period to have commenced for an Access Request Decision to be made.

Potential applicants are also frequently experiencing applications being rejected as they have difficulty completing their applications in a way that clearly articulates their need for support and, therefore, their eligibility. Appeals against eligibility decisions can take extended periods of time (again, often for several months). In addition, clients often report they find the process confusing. Applicants’ capacity to be responsive can also impact on the ability for the appeal to progress.

Timeliness and delays

ACT Health believes that there are risks if NDIA planning decisions are not consistent with legislated provisions and applied principles.

The time it takes to get an NDIS plan from the time of application lodgement (generally four to six months) is of concern. Almost all areas of ACT Health are reporting considerable delays with assessment processes that impact on hospital length of stay or support from mainstream health services.

The NDIA is currently unable to identify timeframes between clients being found eligible, for planning to commence, and when a plan will be in place. The only timeframe identified is related to the determination of eligibility once the NDIA has received all relevant information.

In addition, there are inconsistent timeframes and significant delays in approval of funding/quotes for assistive technology and home modifications. This places participants at high clinical risk and delays service throughput. There appear to be no NDIA Performance Indicators around approval timeframes. Processes and communication around approvals are not consistent. This often results in the clinician becoming the point of contact as NDIA responses are not reliable. As a result more hours are used in non-clinical aspects of the case, and participants are frustrated by lack of clarity.

There continue to be long wait times for children with disabilities to be assessed as eligible, have a plan developed and then implemented. During this process eligible children have no access to NDIS funded disability services. The NDIA has consistently stated that unless the plan is approved, it is the responsibility of ACT Health to provide such a service while people are on the waitlist.

ACT Health Divisions of RACC and Women, Youth and Children (WYC) are continuing to fund supports for individuals (including children) who are eligible for in-scope services but where the time they would need to wait for support creates a clinical risk to their well-being and/or would result in their condition deteriorating significantly. ACT Health has also had to fund services for non-eligible children who may have accessed support from Therapy ACT prior to the transition to the NDIS. The supports provided by the Healthcare Access at Schools program are regarded as essential to allow children to start school with their peers or to attend school in a timely fashion.

There have been a number of patients aged under 65 in the Canberra Hospital who have extended lengths of stay and complex needs who are dependent upon support from the NDIS to be discharged into the community. The NDIA has made it clear they will not provide 24 hours’ support. For the small number of people who require 24-hour support, identifying and securing suitable and appropriate accommodation is incredibly challenging. ACT Health has supported these individuals to access the NDIS. Previously, Disability ACT played a key role in assisting individuals and their families to identify opportunities for suitable participants to share living arrangements.

Clinician input into the planning process

Under the APTOS, clinicians provide essential inputs into the planning process, including in providing advice on NDIS eligibility through preliminary assessments and disability diagnosis. Clinicians also provide advice on the health-related supports required by individual participants. The NDIA is also responsible for funding further assessment by health professionals for support planning and review as required. In practice this advice is often not reflected in finalised or revised plans, leaving participants with what ACT Health perceives are inadequate supports. Protocols around approvals are inconsistent. NDIA staff may or may not consult with the service provider around clinical recommendations in order to clarify justification for funding.

It has been recognised nationally that NDIA planners may not have the knowledge of the specific disability (its causes, impact and required supports). This makes the input of clinicians and appropriate NDIA responses to that input all the more important.

During the early phases of the NDIS trial ACT Health offered, and on occasions this was accepted, education and training for NDIA assessors. This training was provided at no cost to the NDIA. ACT Health also met $150,000 per annum staff costs from the period March 2014 to December 2016 to assist with the transition.

Assistive Technology (prosthetics, orthotics and other equipment)

Up to 50% of NDIS participants require some form of equipment or assistive technology (AT). In transitioning to the NDIS, ACT Health ‘cashed out’ the ACT Equipment Scheme (ACTES) and ownership of equipment was transferred to the recipient. The cost of repairs and maintenance of equipment has remained as an ‘in-kind service.’ Equipment policies were modified to reflect the introduction of the NDIS. However necessary support items (repairs and maintenance) are often not included in plans. In addition, while estimates of standard maintenance costs are provided when possible, there are often unexpected equipment breakdowns which cannot always be predicted. A large number of participants with AT such as hospital beds, wheelchairs and hoists, require them for daily function and cannot afford to manage without them even for short periods of time.

While there is reportedly capacity for equipment hire to be funded via the NDIS while the client is awaiting permanent equipment provision and/or repairs , the process of having this need identified and added to the plan means that, to date, this has not occurred. Adding equipment hire to an

existing plan would inevitably lead to delays and other difficulties similar to those experienced whenever a plan is required to be modified.

The anticipated decrease in demand for equipment through ACTES has occurred. However, ACTES funding for NDIS eligible individuals has fluctuated for a range of reasons, including:

• people waiting for their plans to be approved;
• plans not including the full suite of supports; and/or
• individuals who are yet to transition to the NDIS.

ACT Health continues to fill the gap for clients whose equipment needs should be met by the NDIA. As a result of concerns relating to the planning, combined with extended delays in the approval process for assistive technology and equipment supports in NDIS plans, there is some cost shifting to ACT Health.

There is evidence that some people are seeking support from non-government organisations (NGOs) to fill the gap while they wait for their plans to be approved. There are examples where equipment is either provided as an ‘extended’ loan from the short-term ACTES and/or is purchased outright. ACTES support is not specific to NDIS clients. However, due to the extended period of assessment and approval, a number of NDIS participants have required access to ACTES equipment beyond the ACTES maximum three-month loan period.

This has resulted in some AT resources not being available when required for non-NDIS clients and some increased administrative burden associated with the extension of the loan periods while clients wait for their NDIS funded equipment. ACTES has continued to retain responsibility for the supply of items not provided by NDIS (such as compression garments, custom footwear and items for people 65 and over).

NDIS participants needing equipment are often already clients of the health system and well known in the system. ACT Health is working with the NDIA to provide a quality, seamless service. With prostheses for example, ACT Health is responsible for the provision of the interim device while the NDIA is responsible for the definitive prosthesis, and any subsequent replacements. While the replacement of prostheses should be anticipated and straightforward, participants are reporting delays and/or mistakes associated with the replacement of such devices. If the cost of an AT item is identified as being above benchmark then it needs to be forwarded to the NDIA Technical Advisory

Team (TAT) for consideration. ACT Health views the benchmark as quite low for many items that are already supplied to clients.

So far the NDIA has been unable to provide, in advance, the benchmark amounts for AT items for each client. Lack of information has become a challenge for ACT Health in-kind service providers, who spend considerable time and effort clarifying the cost of services. Even when ACT Health has provided advance advice regarding expected client needs before planning occurs, this information appears not to be reflected in prices on a participant’s plan.

Additionally, items which are referred to the TAT for approval or review can result in extensive delays for a decision. There are examples where an urgent review was required and has taken six to nine months for fairly straightforward equipment. The NDIA does not fund supports until they are included in approved plans. When individuals are at risk, ACT Health has therefore chosen to fund the supports.

As indicated above, enteral feed supplies and dietetic support is included in the APTOS. In conjunction with the national roll-out it is, however, evident that there is increasingly reduced approvals or coverage of these supports in plans.

Data and Information Sharing

The issue of data and information sharing is included in the work plan of the Health Sub-Group with the objective of establishing consistent data sharing approach to support enhanced interface between health services and the NDIA and improved participant experience of both service systems. It has been suggested that it would be useful if NDIS information were available through the My Health Record and linked with the Medicare number.

There are challenges posed by barriers to information sharing both (i) between NDIA and states and territories (including technical constraints) and (ii) within jurisdictions (including privacy concerns). Resolution of these issues would, however, improve the ability of health services to appropriately plan and respond to the NDIS, including meeting the needs of individuals who either cannot access the NDIS or for whom NDIS funding is inadequate.

The issues described above (particularly delays in the NDIS planning process, delays in home modifications and the provision of appropriate AT) have either resulted in or have the potential to result in cost shifting from the NDIA to ACT Health.

Delayed discharge

Delayed discharge or unnecessary retention in hospital is a major factor in increased costs. ACT Health cannot discharge an NDIS participant without being confident that the participant will be discharged into a safe environment where their supports are in place. In many cases ACT Health has been able to discharge participants safely by providing what are, in effect, NDIA deliverables by providing bridging services such as loaning AT (wheelchairs, lifting hoists, etc.) or providing prosthetics and orthotics.

An additional factor in safe discharge has been that of NDIS Quality and Safeguards, particularly in relation to NDIS registered service providers who will often be providing services to participants on discharge. Until recently the NDIA appeared reluctant to acknowledge any ‘duty of care’ responsibility in relation to service providers. NDIA representatives described the NDIA as a funding body only, with no levers to influence provider quality or behaviour as the NDIA is not a party to the service contract agreed between the participant and the provider. If a participant required hospital admission or frequent readmissions in relation to pressure ulcers or falls attributed to inadequacies in the care delivered by the provider, the avenues for recourse were unclear.

ACT Health welcomes the establishment of the NDIS Quality and Safeguards Commission and the release of the NDIS Quality and Safeguarding Framework, which is intended to provide a nationally consistent approach to help empower and support NDIS participants to exercise choice and control, while ensuring appropriate safeguards are in place and expectations established for providers and their staff to deliver high quality supports.

INFORMATION LINKAGES AND CAPACITY BUILDING

Information, Linkages and Capacity Building (ILC) is the component of the NDIS that provides information, linkages and referrals to efficiently and effectively connect people with disability, their families and carers, with appropriate disability, community and mainstream supports.

ACT Government funding for ILC ceased on 1 July 2016 as it transitioned to the NDIS. Because the NDIA had not completed the ILC commissioning framework and was therefore unable to implement the ILC in time for the end of ACT responsibility, $1.3 million was provided by the Commonwealth in 2016-17 for transitional grants to organisations that had previously been funded by the ACT Government to deliver ILC type services.

Initially, 14 organisations were assessed as eligible for ILC transitional funding. Two of these organisations were funded at 50 % of their original contract and the remainder at 100 %. Subsequently, an additional organisation was funded for transitional support at a later date, while one organisation transferred its funding to another organisation.

The first NDIS ILC Grant application round opened on 24 January 2017 and applications closed on 8 March 2017. Unfortunately a small number of organisations were not successful in their application for ILC grants.

The ACT Government negotiated a further six months funding for four of those providers who were not successful. The NDIA agreed to this further assistance on the basis:

• that the activities the four organisations deliver align with ILC and have the potential to contribute to ILC in future, and/or
• there is a risk to their viability and a flow-on risk that valuable sector capacity could be lost.

The ACT Government ensured organisations impacted by ILC were supported during this difficult period by making available some small grants via the Commonwealth’s NDIS Sector Development Fund. These grants were available to help organisations with non-recurrent costs associated with continuing, adjusting or winding up programs.

In the addition to the small grants made available to impacted providers the ACT Government commissioned the ACTCOSS to deliver some workshops on grant writing. These workshops were held in October and early November 2017 and were open to those providers who were impacted by ILC or new providers who may be considering applying for an ILC grant.

The NDIA announced a new round of ILC grants of $4 million dollars in the ACT. These grants opened on 24 October 2017 and closed on 30 November 2017. Organisations were able to apply for grants of up to two years. The outcome of the grant round has not been announced.

The ACTCOSS recently released Choice and Control: Strengthening human rights, power and inclusion for people with disability, which identifies a number of concerns regarding the way ILC is currently being implemented in the ACT. The ACTCOSS is concerned about the current resourcing for ILC, especially in the context of the majority of ILC funding sitting with the Local Area Coordination (LAC) provider.

There are also concerns about the framing of ILC funding as project funding, and the implications this may have for organisational sustainability and their ability to plan for the future.

As ILC develops there is a potential loss of social capital developed by those organisations which will not have access to NDIS funding, via either individual funding packages (IFPs) or ILC funding, but which provide services and connections of value to people with disability and the community as a whole.

Whilst the Commonwealth investment into ILC brings a new mix of programs that build capacity of people with disability across the board, further work is required to develop the ILC ‘market’ to ensure that the aims of ILC policy can be realised. The ACT Government is working closely with the ILC team in the NDIA who have acknowledged that a joint market stewardship approach is required. Work is underway to develop this approach.

LOCAL AREA COORDINATION

The Local Area Coordination (LAC) role is embodied in the ILC policy framework which describes five ‘streams’ of ILC, these are:

• Information, Linkages and Referrals;
• capacity building for mainstream services;
• community awareness and capacity building;
• individual capacity building; and
• Local Area Coordination.

The NDIA states that just as ILC is essential to the overall success of the NDIS, LAC is central to the success of ILC. LACs are the single largest investment by the NDIA in delivering outcomes for ILC. LACs will have three main roles:

• work directly with people with disability over the age of seven years old who have an NDIS plan to connect into mainstream services and community activities and get their plan into action;
• provide short term assistance to people who do not have an NDIS plan to connect into mainstream services and community activities; and
• work with their local community to make it more accessible and inclusive.

In March 2017, the NDIA announced that Feros Care was selected as the successful partner to provide LAC services in the ACT to support the NDIS. Participants in the ACT that do not have coordination of supports or specialist support coordination in their plan will receive support connection through Feros Care.

The LAC also have a planning role and have been undertaking the plan development for a significant number of participants. The OfD has received anecdotal feedback that the LACs have struggled to meet the demands for service in the ACT and that this has impacted on the consistency and quality of their service, including failing to advise participants that their plan has been approved.

There is no evidence that LACs have been able to provide short term assistance to people who do not have an NDIS plan to connect into mainstream services and community activities.

Whilst the LACs have worked with the OfD in the grant assessment of the 2017 International Day of Disability (I-Day) Grants, there is no evidence that they have commenced any work with the local community to make it more accessible and inclusive.

The ACT Government understands that the LAC role in the ACT is developing and it is early days in its implementation however the OfD has raised its concerns with the ACT NDIA. The OfD will continue to monitor concerns raised.

MARKET READINESS

The ACT Government believes that the key issue regarding the introduction of a greater supply of providers is the issue of fixed pricing.

The current Fixed Pricing Structure for NDIS services has affected the overall development of sustainable business models. There appear to be services that are not, or are perceived to not be financially viable. For example: therapy hours which do not allow or acknowledge the time taken to

research conditions and design treatments; the limited ability for workers to receive training and professional development; and the cost of the NDIS administration related to any invoice for service.

One of the key areas which has highlighted the issue of fixed pricing was the recent issues regarding Short Term Accommodation (STA). STA is registered and funded under the NDIA’s registration group ‘Assistance with daily life tasks in a group or shared living arrangement [Daily Tasks/Shared Living]’. This registration group incorporates assistance with and/or supervising tasks of daily life in a shared living environment, which is either temporary or ongoing, with a focus on developing the skills of each individual to live as autonomously as possible. This registration group includes short-term accommodation and assistance (e.g. respite care).

STA was funded at a flat rate of $501.71 per person per 24 hour period, which unlike the funding of other supports, did not recognise complexity of support or differentiation in cost of service provision due to different industrial wage costs for different time periods. In 2014-15, prior to transitioning out of the delivery of STA, the ACT Government was providing $3,105,800 per annum to five different community organisations.

On 26 July 2017, the OfD became aware of a significant and emerging market issue regarding the provision of STA in the Territory. This was heightened when a major service provider stated that it was unable to provide STA to people with complex needs. Despite considerable effort by the provider, the local NDIA and the OfD, it was apparent that no other providers were able to offer families STA at the NDIS price.

An interim solution was put in place to support the provider to provide services and after considerable advocacy from the ACT Government the NDIA changed the pricing regime to better reflect complexity and the payment of penalties in salaries for staff that work outside of business hours.

NDIS Independent Pricing Review

In 2017 the NDIA commissioned McKinsey & Company to complete the NDIS Independent Pricing Review (IPR) to look at fixed pricing in the NDIA the terms of reference for this report included. Provide recommendations in relation to improved pricing effectiveness, including but not limited to:

• National versus regional pricing;
• Pricing of services with different levels of complexity;

• Pricing of respite services;
• Thin and undersupplied markets, particularly in regional and remote areas;
• Relative provider efficiencies, including overheads;
• Adequacy of provider returns;
• Effectiveness of the Hourly Return approach used to set prices; and
• Provide recommendations in relation to the potential early deregulation of price in more mature sub-markets and the glide path for the eventual deregulation of price more generally.

The report was released in March 2018 and the key findings of the IPR include (McKinsey & Company):

While there is not yet evidence of generalised supply shortages, data on market development is mixed and there are certain markets for which undersupply is a risk in the future:

• Across support types, provider entry and exit data suggests market growth is keeping pace with demand and utilisation data does not provide compelling evidence of supply shortages:
• The rate of growth of month-to-month provider registration outpaced the rate of growth of participant registration throughout 2017.
• Utilisation data from the trial sites suggests lower than expected utilisation was driven by participants being unfamiliar with the NDIS and how to use their supports, rather than a supply shortage.13

The report goes on to say that:

• In the attendant care market, there is not yet compelling evidence of participants being unable to access supports, but there are signals that are concerning, including a significant proportion of providers that currently have unprofitable operating models.
• There are cohorts of participants for which supply shortages are high-risk due to the increased cost of service provision and limited availability of workforce, including those who: are in outer regional, remote or very remote areas; have complex needs; are from culturally and linguistically diverse backgrounds; are Aboriginal and Torres Strait Islander Australians; or have acute care needs such as in crisis situations.
• While some providers have operating models that are profitable at current price points, many are struggling, particularly traditional providers delivering attendant care supports:

13 Independent Pricing Review, National Disability Insurance Agency, McKinsey & Company, p. 5

• In the attendant care market, there is significant variation (from <$40 to $55+ per hour) in the cost of service delivery between providers. There are examples of low cost models that are profitable at current price points, including the online platform model and lean-operating model. However, many traditional providers are struggling to operate profitably at current price points. This is attributable to a combination of factors: higher overheads; challenges in adapting to unit pricing and NDIA systems improvement opportunities; lower utilisation of workers; and higher labour costs.

• In therapy, the single price point is working for some providers, such as physio and speech therapy providers and many sole traders. However, it is not working so well for some others, such as psychological therapy for more complex participants.

• In Supported Independent Living (SIL), Support Coordination and Plan Management, feedback indicates that most providers can operate profitably at current price caps/benchmarks for lower complexity participants. However, the rollout of a more accurate SIL pricing process may make it more challenging for providers to cross subsidise other supports in the future.

• Benchmarking of NDIA support price caps against comparable schemes highlighted that the NDIA price is broadly aligned with prices of accident compensation schemes, including the Transport Accident Commission and WorkSafe, although market prices for some similar aged care services are higher.14

The report makes twenty five recommendations which have all been accepted by the NDIA. Of note some of the key recommendations include a number of measures to increase the prices for services provided to people who have more complex needs. This includes group based and centred based services where skilled staff are required. There is also a recommendation that the NDIA should develop a definition of complexity linked to the skills required for the participants needs. These recommendations are welcome and the ACT Government looks forward to the development of this work.

The report recommends a single national pricing structure with a trial of outcomes based pricing. They recommend that there was no clear pathway to deregulation and that significant work was required to strengthen participant and provider readiness.

The ACT is keen to ensure that the development of markets including the possible impost on other mainstream services is examined as a local response and believes that jurisdictional input is essential.

14 Independent Pricing Review, National Disability Insurance Agency, McKinsey & Company, p. 5

In particular the ACT believes that local tailored solutions particularly for Aboriginal and Torres Strait Islander Services and services for people who have high and complex needs is an effective approach to address thin or potentially thin markets.

As part of the ACT NDIS readiness the ACT Government commissioned the Building Culturally Sensitive Disability Services (in the NDIS Context) project to look at developing culturally appropriate Aboriginal and Torres Strait Islander services in the ACT. Some of the recommendations from that work include:

• Assurance that participation in the NDIS will not jeopardise block funding arrangements;
• A funded ‘transition phase’ to provide reassurance about the financial risks of embarking on operating a fee for service model;
• Specific assistance for small Aboriginal and Torres Strait Islander run organisations to navigate the registration processes; and
• Linkages between the NDIA and small business support programs for Aboriginal and Torres Strait Islander run organisations.

The NDIA has yet to develop a market intervention strategy to be able to monitor the market and where appropriate apply suitable interventions where the market is not meeting the objectives.

In November 2016 the NDIA developed its market stewardship strategy the NDIS Market Approach - Statement of Opportunity and Intent. The purpose of this document is to set out the role of the NDIA as a market steward in the new disability marketplace during the national transition phase to full scheme in 2019-20. By doing so the NDIA is seeking to provide greater certainty for existing providers and potential new entrants as they assess opportunities the NDIS brings to serve participants within the NDIS.

The document describes the NDIS Market approach at a high level and is designed to:

• ensure that the NDIS community understands the roles and responsibilities the NDIA has in this new disability marketplace;
• build confidence in the marketplace;
• ensure accountability for the NDIA; and
• create predictability about how this newly developing marketplace will operate.

The ACT Government has developed working arrangements with the NDIA to establish an agreed methodology to respond to thin market issues and service disruption. Responses could include the establishment of a virtual team with ACT Government, NDIA and DSS staff to develop a response plan and identify and implement arrangements which are determined on a case by case basis, to minimise any disruption in service to participants.

The OfD continues to work with disability sector, the NDIA and the Commonwealth Government to monitor the market in the ACT. Whilst stewardship of the market now lies with the NDIA, the ACT remains committed to working towards a vibrant market ensuring that people with disability have real choice and control. Working arrangements have been established with the ACT Government the NDIA and DSS and include a focus on key areas including: Assistive Technology, Support Coordination and Specialist Disability Accommodation.

EMERGING GAPS

Home Modifications

ACT Health report that there are a range of accommodation issues that are negatively affecting participant outcomes and impact on ACT Health’s confidence in safely discharging NDIS participants (both those with plans and those awaiting plan finalisation) from the tertiary inpatient setting. Discharge delays are not uncommon.

This is particularly relevant when home modifications are required. Issues include: NDIA funding for home modification assessments has been restricted for some participants; there are sometimes very long delays in considering requests for home modifications; the inclusion of funding for Specialist Disability Housing (SDA) support in NDIA plans has been uneven since its launch in early 2017.

There is a lack of consistent processes and no performance indicators in the NDIA generally, including no prioritisation system for higher priority cases. The specific and individualised nature of home modification assessment and design, results in additional processing following the OT assessment, which is often not included in Support Plans and amendments are not readily available. Other funding systems such as the Department of Veterans’ Affairs and My Aged Care, have more straightforward and clear processes that assist both clinician and client in understanding the limitations of approval processes.

There are currently only four builders in the ACT registered to provide NDIS home modifications and this often leads to significant delays in home modifications being completed, and accommodation being made safe and effective. This is mainly due to: the existing waiting lists the builders already have; registered builders being unresponsive; and builders not willing to take on ‘small’ jobs. If the number of registered builders were increased (and the process of doing this is simplified) or if there was not a requirement for builders delivering home modifications to be NDIS registered, these issues would be addressed.

These accommodation issues are contributing to difficulties implementing solutions for participants, aggravating existing functional impairments for some participants, and driving inappropriate entry of individuals to residential aged care. There are also particular accommodation issues for people with psychosocial disability.

Voluntary Out of Home Care

There remains uncertainty for families with children with disability who require a specialist disability accommodation response due to:

• a lack of sufficient supports and respite care to assist families before they reach crisis point;
• limited maturity of community services to provide intensive, specialist services in response to complex needs and behaviors; and
• limited assertive case coordination when families are escalating into crisis to either maximise supports available within an existing plan or to seek a plan review.

Accommodation options for people younger than 18 years who remain in the care of their parents but who cannot live in the family home is proving challenging for both the NDIA and jurisdictions.

The NDIA are currently undertaking a trial involving a small number of individual children called Children in Voluntary Out Of Home Care. This trial aims to maximise NDIS-based supports to prevent children needing an accommodation response outside of the family home. This trial has not progressed sufficiently in order to determine the impact for families.

The ACT is concerned that the NDIA retains the view that it is the responsibility of the statutory child protection system to provide an accommodation response for children with a disability, even when

there is no abuse or neglect evident and where parents are still actively asserting their parental responsibility.

The ACT retains the view that it is not in a child’s best interest for them to enter the child protection system in order to receive an accommodation response as a result of their disability.

Support coordination

Overwhelmingly the common theme for both participants and providers is the issue of support coordination and case management.

Concerns have been raised by the ACT Public Trustee and Guardian (PTG) and ACT Health and Child Protection service in this submission about the lack and quality of support coordination provided through NDIS. The PTG report states that the NDIS has significantly increased the need for case coordination and documentation (often too complex for a participant to manage alone) and that they have seen an increase in guardianship applications specifically to ‘assist people to navigate the complex NDIS pathway and signing the highly complex contracts’. This has increased the work of PTG and the ACT Civil and Administrative Tribunal.

The role of the NDIA is to administer the NDIS. The NDIA does not provide services and support to people with disability rather it facilitates the planning and purchasing of supports to individuals with disability either directly via an NDIA planner or via partner organisations such as Early Intervention providers and Local Area Coordinators.

The role of the NDIA is completely different to the previous role provided by Disability ACT and Therapy ACT which although welcome has highlighted some key concerns particularly in regards to the loss of an authorising environment previously in place before the trial of the NDIS. This is particularly evident where a person may have more complex needs and be in contact with multiple services and service systems. Where previously Disability ACT was able to navigate and negotiate this for clients, some support coordinators appear not to have the skills to do this and do not always have the authority when dealing with ACT Government directorates.

PTG has noticed increasing difficulty with the interpretation of what is ‘reasonable and necessary’ supports for a person. This has led to high risk situations and a continual resignation of

services/agencies who are unwilling to accept the risks of being involved with participants whose needs far exceed the funding allocated by the NDIS.

Strong advocacy and liaison with NDIA staff have continually failed to increase funding allocation with the consistent response from NDIA staff to refer the person to mainstream supports, usually ACT Health (a service which prior to the NDIS was only infrequently accessed for medical issues).

The Justice and Community Safety Directorate also note that there are emerging issues in regards to people exiting detention and interactions that people with disability have with the Justice Sector including access of supports for those with disability in particular to meet community corrections supervision expectations upon transition to release from custody.

Complex needs

The ACT Government remains concerned about service gaps for people who have more complex needs. The PTG has concerns about service gaps for clients who present behavioral challenges or hygiene challenges as part of their disability, particularly with no service provider of last resort, in a market-based environment established by the NDIS.

The NDIA have been developing a ‘maintaining critical supports response’ which outlines an approach for those people whose supports fail or for whom a provider cannot be sourced. The ACT Government has been involved in consultations about this approach and will be working with the NDIA to ensure that is implemented as soon as possible.

HUMAN SERVICES REGISTRAR

The Quality, Complaints and Regulation (QCR) Branch has developed a productive working relationship with a number of stakeholders involved in implementing the NDIS in the ACT. Undertaking a number of roles in the implementation, the relationships QCR has established achieve a number of objectives.

National Policy Development

QCR has taken the lead in progressing the ACT component of the National Quality and Safeguarding Framework. Commonwealth and NDIA stakeholders have been collaborative and compromising in the achievement of common goals. A key challenge has been the scope of this work and the

timeframes for implementation, both requiring limited resources to be devoted to wide array of governance and working groups. Progress continues to be made with significant milestones reached.

Registration and Regulation of Services

The Human Services Registrar (HSR) sits within the QCR Branch. In accordance with Working Arrangements agreed with the NDIA, the HSR makes recommendations for the registrations of providers of NDIS services. Services are also monitored for compliance by the HSR.

In the operation of these roles the HSR meets regularly with officers from the NDIA local office and national registrations office. This is a mechanism by which all parties can seek resolution to issues as they arise. Without the relationships built through these meetings, gaining information from the NDIA can be problematic. The Working Arrangements between the HSR and the NDIA are currently being updated to reflect total transition of ACT participants to the NDIS.

The cost of regulatory oversight in this space was greater than anticipated. A significant increase of new registrations has occurred over the last 12 months with costs of regulation for this single sector exceeding the total budget for human service regulation (an additional two sectors).

There have been oversights and inconsistencies in the provision of information from the NDIA regarding the registration requirements in the ACT. While these have been corrected, it is demonstrative of some of the information sharing challenges within the NDIA. They have often impacted adversely on providers’ ability to finalise registration or receive payment.

The HSR has, on occasion, made representations to the NDIA on behalf of individual providers to seek clarification or updates on registration. These occasions are becoming fewer and farther between, indicating that the communication loop between the HSR, the provider and the NDIA itself, may be improving.

Official Visitor and Visitable Places

Official Visitors for Disability Services (OVDS) in the ACT operate as independent mechanisms by which people living in places that are not their private home may make complaints or seek support to resolve a conflict with providers. The OVDS, and the OV Scheme more broadly, is an important component of a broader system of oversight to ensure the protection of and quality outcomes for vulnerable people in the ACT. Who the OVDS may visit is guided by legislation and the advent of the

NDIS and the subsequent transfer of disability support provision entirely to the community sector has meant that the identification and recording of places an OV may visit is not easily undertaken. Legislation amendments may need to be sought to address the challenges raised.

ACT Health have concerns regarding NDIS Quality and Safeguards, particularly in relation to NDIS registered service providers who will often be providing services to participants on discharge. Until recently the NDIA appeared reluctant to acknowledge any ‘duty of care’ responsibility in relation to service providers. NDIA representatives described the NDIA as a funding body only, with no levers to influence provider quality or behaviour as the NDIA is not a party to the service contract agreed between the participant and the provider. If a participant required hospital admission or frequent readmissions in relation to pressure ulcers or falls attributed to inadequacies in the care delivered by the provider, the avenues for recourse were unclear.

ACT Health welcomes the establishment of the NDIS Quality and Safeguards Commission and the release of the NDIS Quality and Safeguarding Framework which is intended to provide a nationally consistent approach to help empower and support NDIS participants to exercise choice and control, while ensuring appropriate safeguards are in place and expectations established for providers and their staff to deliver high quality supports.

The PTG has concerns regarding opportunistic business practice issues with the agency/service provider market that is hampering client’s choice and control. Often a service is offered to a client as long as they also accept another service from the same or sister company. PTG is highly concerned about these practices and hopes that the quality and safeguarding frameworks will seek to improve.

PTG additionally states that, service agreements created by agencies are very complex and legalistic with most agencies having obtained legal advice to create the documents. PTG consistently finds issues and inequalities in these service agreements and advocates for these contracts to be amended.

Human Rights and Complaints

The ACT Human Rights Commission notes that at the moment, NDIS participants who have made complaints about the provision of services by the NDIA are unable to obtain a remedy through the Commission because the NDIA has asserted the Commission does not have jurisdiction over the NDIA.

This leaves a gap in complaints resolution because the only redress mechanisms available at a federal level to individuals are the Commonwealth Ombudsman who is limited to investigating government administrative actions and the Australian Human Rights Commission which is limited to receiving complaints of alleged discrimination including disability discrimination or an alleged breach of the Convention on the Rights of a Persons with Disabilities.

Unlike the ACT Human Rights Commission, neither of these bodies is able to receive complaints about the provision of disability services more broadly and offer alternative dispute resolution as a way to resolve a complainant’s concerns. Further, the proposed NDIS Quality and Safeguards Commissioner will not have the power to investigate complaints arising out of the provision of services by the NDIA.

The ACT Human Rights Commission complaint handling process would therefore fill a gap that currently exists in the options that are available to NDIS participants, their families and advocates who wish to make a complaint about the services they have received from the NDIA, where there is otherwise limited means for redress.

Despite the NDIS Quality and Safeguarding Framework stating that universal complaints and redress mechanisms will continue to be available to participants, this has not been the case in practice. The NDIA has consistently refused to engage with the ACT Human Rights Commission in the exercise of its lawful complaint investigation functions in relation to disability services provided in the ACT.

Prior to the rollout of the NDIA in the ACT, Disability ACT within the ACT Community Services Directorate had the responsibility for planning, developing strategic policy, allocating funding, and providing and monitoring services for people with disability in the ACT. As a public authority under the Human Rights Act 2004 (ACT), Disability ACT was required to act consistently with human rights and give proper consideration to relevant human rights when making a decision. With the removal of funding allocation and the provision and monitoring of services from Disability ACT, residents of the ACT can no longer formally require consideration be given to relevant human rights when decisions that affect them are made by the NDIA. ACT users of disability services are accordingly left with less protection of their rights under the transition from Disability ACT to the NDIA.

Conclusion

This submission describes a complex NDIS/Health interface area where many issues are yet to be resolved. There is also still significant work yet to be undertaken to assess and understand the impacts on the health system on the services that are currently delivered by ACT Health as an in-kind service and if these services could be “cashed out” and delivered by the private/NGO sector. These include issues of market readiness; the uncoupling of “disability” services from mainstream services and the impact this will have on the service system including potential costs.

The implementation of the NDIS in the ACT has been a major change for people with disability, service providers and the ACT Government as a whole. This has also been a considerable achievement for the ACT and for those disability advocates who for decades have fought for changes in how disability funding was delivered and for people with disability to have choice and control over their own lives.

With a change this significant and far reaching it is inevitable that there will be impacts on the service system. There are clearly systemic and transitional issues that are yet to be resolved both at a national and regional level. The ACT Government remains committed to the implementation of the NDIS and ensuring that people with disability receive the opportunities afforded by this important social reform.

APPENDIX A

ACT NDIS Sector Development Fund: Programs

Program	Output
Enhanced Service Offer (ESO) 2013 and 2014	Over 1,300 applicants were offered a grant to purchase an item or support they identified would make a difference to them.
NDIS Awareness	Project to strengthen the awareness of NDIS through community gatherings and targeted conversations. Undertake market soundings and Participant forums to develop advice information Government of options for commissioning for early intervention services for the ACT.
NDIS Governance and Financial Management Reform Package	Package assisted service providers to position themselves in a new marketplace that will be expanded also because of the

Program	Output
Your Voice Your Choice, Good Life Planning	Delivered supports and programs to assist people with psychosocial disabilities who were outside the formal service system to prepare for and transition to the NDIS.
NDIS Business Investment Packages (BIP) 2014, 2015, 2016 and 2017	Assistance to a maximum value of $50 000 was provided to address complex reform related to service design and/or establishment, financial viability, workforce redevelopment, human resource management, organisational structure and systems; and governance.
Community Participation Grants 2015, 2016 and 2017	For people with disability and families to take part in training and information events to assist them to prepare for NDIS; and for assistance with developing and implementing life plans and informal supports.
NDIS Workforce Awareness Tools	Provided plain English advice to ACT organisations and their workers. Resources include induction and training content including presentation material and Fact Sheets.
Gugan Gulwan Outreach Program	Provided to support members of ACT Aboriginal and Torres Strait Islander communities to prepare for the NDIS.
Ready4	Assisted in maturing the market by providing a central point of information and assistance to ACT disability providers. It delivered a range of NDIS preparation tools and resources, one-on-one and small group support; and business, system and governance model development to help providers to implement their NDIS development strategies.
Opening Doors	Assisted to build the availability of culturally sensitive disability services in the ACT.
Values in Action	Provided support to participating organisation’s workforces to operate in the person-centred environment of the NDIS.
Building the Capacity of the Disability Workforce	The project addressed the Allied Health sector to enable the sector to be best placed within NDIS.

• A two year project is ongoing to build the capacity of the ACT disability sector workforce through a Collective Impact approach. The project will coordinate and facilitate a process for ACT stakeholders to collectively: |

Program	Output
	- develop a shared understanding of systemic current and future workforce issues;

• develop a common agenda for addressing these issues;
• trial solutions, and
• share and communicate learning. |

APPENDIX B

Organisational Chart - ACT Government NDIS Working Groups

• Disability Reform Council (DRC): A COAG Council made up of Treasurers and Disability Minister’s from each state and territory. It is the decision maker for policy and invites jurisdictional representatives to special purpose meetings as needed
• Trilateral Working Group: National Office of the NDIA, Department of Social Services, the ACT Government’s Chief Minister’s, Treasury & Economic Development Directorate and the Office for Disability
• Senior Official Working Group (SOWG)
• Operational Working Group (OWG): ACT Office of the NDIA and ACT Government
• ACT NDIS Interdirectorate Committee (IDC)
• SOWG Working Groups
• OWG - Working Groups:
  • Mental health
  • VOHC/Statutory Services
  • Health
  • Education
  • Housing
  • Early Childhood
  • Market

CSD Community Services Directorate March 2018

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APPENDIX C

Investment in sector development: Building the capacity of the ACT disability services workforce

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INTRODUCTION

The research into this proposal took place in 2015 and took into account the known and potential investment in sector workforce development at the local and national level. It was informed by national and international research and existing models of successful practice. It was also informed by analysis and forecasts of ACT sector workforce needs and issues and consultation with key stakeholders in the ACT disability services sector.

The starting point for the strategies and projects outlined in this proposal was a shared recognition within the ACT disability services sector, government and community:

• of an imminent workforce crisis in the disability sector
• that existing service delivery models must change if providers are to survive and thrive under the new NDIS funding model and increasing competition in the service environment
• of the value of the support and carer vocation
• of the importance of expanding the capability, adaptability and diversity of the workforce
• of the importance of fostering innovation and mobilising collective action that transforms ideas into realities for the benefits of people with a disability, and their families and carers, disability service workers and organisations, the support industry and the ACT economy.

This proposal also builds on the strengths of the current sector, including a strong vocational narrative that is located around the notion of client care, shared by low- and high-skilled care workers alike, through which employers and employees can share a common dialogue.

Our collective goal is that Canberra will be a city where:

• people with disability feel welcome, can access all aspects of community life and can reach their full potential
• every person recognises they have a part to play in the creation of welcoming, supportive and accessible communities.

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CONSULTATION

The development of this proposal has been informed by consultation with the following key stakeholders:

• new and existing service providers, both profit and not-for-profit organisations
• Mental Health Community Coalition (MHCC) ACT
• Volunteering and Contact ACT
• Workforce Innovation Network (WIN)
• National Disability Services in the ACT, NSW and Tasmania
• Group training organisations
• Australian Services Union

Advice was also provided by experts in social and organisational psychology from the Australian National University and University of Queensland.

A discussion paper was prepared for disability service providers and other relevant stakeholders as part of the industry consultation process. Representatives from all the key stakeholders listed above attended the consultation forum, including 25 new and existing community and private providers.

The following proposal was also informed by input from the ACT NDIS Expert Panel and the ACT Government’s NDIS Project Board.

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WITH THE NDIS FRAMEWORK AND THE EXISTING SECTOR ENVIRONMENT IN MIND, THE FOLLOWING PRIORITIES, VISION AND PRINCIPLES INFORM THE PROPOSED INVESTMENT STRATEGY:

Strategies to:

• attract and retain workers, particularly direct support workers.
• support service providers as they explore potential business transformations, including designing and implementing enhanced service delivery models and high performing work practices.

To trial and evaluate an integrated set of innovative and evidence-based initiatives to assist ACT disability service providers to address workforce capacity issues within the NDIS funding model.

Principles

• operate efficiently within the NDIS funding model.
• encourage innovation.
• make people management a key priority
• involve staff in decision-making processes.
• deliver services that are responsive to client needs.
• enhance worker adaptability and capability
• encourage a learning orientation
• enable staff to fully use their skills and abilities at work.
• create a fair workplace environment.
• harness the existing shared vocational narrative and collective goals of the sector (i.e. a shared sense of “who we are”, “what we value” and “how we want to progress”)

‘Workforce capacity’ refers to more of the ‘right workers, in the right place at the right time’. It also refers to the diversity, adaptability, innovation, efficiency, and sustainability of the workforce.

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AN INTERRELATED, COHERENT SUITE OF PROJECTS

The projects are designed so that within each project there are a number of interrelated initiatives. Each project will involve a number of project partners who will necessarily cooperate with each other, as well as with service providers participating in the project. There are elements within each project that can potentially relate to the other project. That is, partners and stakeholders involved in each project can enhance progress and outcomes by working together across projects.

Projects	Summary of elements	Anticipated positive impacts on:
1. External and internal marketing and branding campaign	A tightly targeted attraction campaign. A one year pilot project designed to integrate attraction strategies with existing government programs that provide support and work-related training for job seekers in Canberra and the surrounding regions. Sustainable promotional resources. Internal marketing to existing staff about their roles and career pathways.	Attraction & retention Competitiveness Community perceptions of disability services occupations
2. A healthy community of providers	Access to expertise and assistance in the development of innovative, sustainable service delivery models e.g. self-managed teams; high performing work practices. Development of sector-wide structures and systems that foster unity and collaboration across providers, while simultaneously maintaining competition and concern with the outcomes for clients and their families/carers.	Retention Productivity/efficiency Communication & cooperation Viability & competitiveness Diversity & innovation Client satisfaction Advocacy Innovation & entrepreneurship Quality, innovative service provision

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ONE OF THE BIGGEST CHALLENGES FOR DISABILITY SERVICE PROVIDERS IN THE ACT IS ATTRACTING, RECRUITING AND RETAINING A CAPABLE, DIVERSE AND ADAPTABLE WORKFORCE TO MEET THE FUTURE NEEDS OF PEOPLE WITH DISABILITY.

Under the NDIS:

• clients have the power as consumers of services to choose their provider
• new and different forms of suppliers are entering the market, bringing competition for workers
• changed and increased demand for services is expected
• demand for socially and culturally appropriate services will grow

Growth:

forecasts for 2015-16 and 2016-17 predicted the ACT disability sector needs approximately 500 new workers each year. Of these, 170 extra direct support workers and 130 extra welfare support workers per year may be needed. This trend is predicted to continue to 2020 unless the low retention rates in the sector can be addressed.

Uncertainty for providers:

increased unpredictability for providers about the demand for their services could lead to short term increased use of casual workers.

Diversity:

increased demand for workers able to work with socially and culturally diverse people

Job role change:

increasingly providers will be seeking workers able to support people with complex mental health, disability and behavioural needs.

Workforce shortages:

In the past 12 months, the total number of people employed in the whole ACT economy grew by only 100. The ACT has the lowest unemployment and highest participation rates in the nation. Compared to the rest of the nation, an ACT working-age person is more likely to have a post-school qualification and adequate foundation skills, giving them access to a range of employment and career opportunities.

The high cost of living in the ACT makes it difficult to attract direct support workers from interstate.

Competition for workers:

from other rapidly expanding sectors, such as aged care and healthcare, and from sectors offering better wages, conditions and career progression.

Given the barriers in the ACT, retention strategies are likely to have the greatest impact on improving the sector’s workforce capacity. Internal marketing campaigns fostering positive identification with the sector, showcasing workers’ contributions and targeting those groups of workers most at risk of leaving the sector will be the most cost-effective. Universal attraction strategies are unlikely to have sufficient impact. Active marketing to specific groups of potential new workers and people who traditionally do not fully participate in the workforce is needed.

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THE MOST PRESSING ISSUE FACING THE DISABILITY SECTOR IS A CURRENT AND PROJECTED SHORTAGE OF DIRECT CARE WORKERS

Where are the largest supply gaps?

• Aged and Disabled Carers
• Disabilities Service Officer
• Lead Support Workers
• Peer Support Workers
• Mental Health Support Workers

Why are there workforce shortages?

• Lowest unemployment rates in nation
• Slow growth in total employment
• Employment opportunities in other sectors with better wages
• High cost of living
• High levels of education
• Poor job and career perception

While strategies for attracting employees into the sector are being developed, the sector will need to develop ways to retain and better use the existing workforce, including part-time and casual workers. This would include developing high performance work practices to improve productivity.

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ANTICIPATED SUPPLY GAPS IN NDIS-RELATED OCCUPATIONS PER YEAR

The supply gap each year is calculated at an occupation level as the demand in each year minus the previous year’s demand plus the number of occupational leavers in the previous year.

The number of occupational leavers is calculated at the aggregate level and distributed based on the number of people in each occupation.

ANZSCO Occupation	14/15fy	15/16fy	16/17fy	17/18fy	18/19fy	19/20fy	Total
Aged and Disabled Carers	67	184	164	104	111	118	748
Welfare Support Workers	50	137	123	78	83	88	559
Social Workers	15	41	37	23	25	27	168
Receptionists	11	24	20	13	13	13	96
Carers and Aides nfd	7	18	16	10	11	12	74
General Clerks	8	19	16	10	10	10	73
Physiotherapists	7	22	17	9	9	9	73
Nursing Support and Personal Care Workers	5	14	12	8	8	9	57
Speech Professionals and Audiologists	5	13	11	7	7	8	51
Podiatrists	4	11	10	6	6	7	44
Occupational Therapists	3	9	8	5	6	6	38
Health and Welfare Services Managers	4	9	7	5	5	5	34
Office Managers	4	9	7	5	5	5	34
Other Health Diagnostic and Promotion Professions	2	6	5	3	3	4	23
Practice Managers	3	6	5	3	3	3	22
Dietitians	2	5	4	3	3	3	19
Personal Assistants	1	3	2	1	2	2	11
General Managers	1	3	2	1	1	1	11
Total	200	531	468	295	312	330	2135

The data source is based on ABS data, workforce data provided by Disability ACT and estimates prepared by PricewaterhouseCoopers (PwC; 2012) for the Australian Government. Modelling was completed by a statistical analyst in the Skills Reform section at the Education and Training Directorate. Occupational growth was based on firstly applying an ACT context to the national PwC NDIS estimates. This then changes the growth figures in the ACT by converting to an ACT specific baseline. The growth rate was then normalised to ensure an aggregate growth of 100% between now and 2020. Annual growth rates vary due to the staged implementation of the NDIS, and are reflective of when the NDIS is likely to have the largest impact. The figures assume a similar number of people leave the occupation each following year as in the base year.

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PROJECT 1: INTERNAL AND EXTERNAL MARKETING AND BRANDING CAMPAIGN

Priorities

• Retention (esp. ‘at risk’ groups i.e. valuable workers who are difficult to retain over the longer term)
• Attraction (esp. target groups)
• Internal marketing (esp. materials for providers’ existing staff about their roles and career pathways)
• External marketing (esp. shaping the community’s perceptions of what it means to work in the sector)
• The production of sustainable promotional resources that last 2 to 5 years

Vision

A campaign to showcase support work, disability services, community service and Canberra as an occupation, a career, a vocation and a community of choice.

Principles

• Active, not passive
• Targeted, not universal
• Evidence-based targeting
• Cost-effective
• Integrating existing ACT and Australian Government workforce development programs
• Encouraging collaboration across government agencies and community organisations
• Offering attractive employment packages

Products

• A shared message that represents and champions the sector
• ACT specific information linked with CareCareers.com
• Hard copy and accessible online booklets promoting occupations, training opportunities and career pathways
• Distribution of materials to employers; schools, universities; RTOs, Centrelink; employment service providers, Adult Community Education providers; Australian Apprenticeships Centres, group training organisations; career centres; community organisations; libraries; hospitals; participants in ACT Government programs and networks
• Presence at careers markets and relevant community events

Research suggests that the most cost-effective interventions are (a) active (and preferably interactive) not passive; (b) targeted not universal; (c) aimed at those most at risk of leaving, rather than those who have already left the industry; (d) emergent not imposed.

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THERE ARE SIGNIFICANT CHALLENGES IN ATTRACTING NEW WORKERS TO THE DISABILITY SERVICES SECTOR, INCLUDING THE CHARACTERISTICS OF THE ACT WORKFORCE

Challenge 1: The characteristics of Canberra’s workforce

Average annual growth in numbers of people employed

The total number of people employed in the ACT economy grew relatively slowly last year (i.e. 100 additional people employed in the 12 months to June 2015).

Between the Census years 2006 to 2011, the total number of people employed in the ACT private sector grew by 4,863 (an average of 972 people employed per year).

Forecast for the disability services sector

Forecasts estimate that approximately 500 additional workers will be required each year for the next four years in the disability services sector alone.

Even if the forecasts turn out to be overestimated we still expect the disability, health and aged care sectors will to continue to grow and experience workforce shortages and competition for workers to some extent in the future, regardless of the NDIS because of the ageing of the population.

The average working-age Canberran

The average working-age Canberran is more likely than Australians generally to be already fully participating in employment, education/training, or a combination of both.

The ACT consistently has the highest labour-force participation and the lowest unemployment rates. A working-age Canberran is more likely than the average Australian, to have a post-school qualification at Certificate III level or above. A young person (aged 18-24) in the ACT is more likely to be fully participating in post-school education/training, employment or a combination of part-time employment and part-time education/training than a young person in the rest of Australia.

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THERE ARE CHALLENGES IN ATTRACTING MORE DIVERSE WORKERS TO ENTRY-LEVEL OR LOW-SKILLED OCCUPATIONS IN THE DISABILITY SECTOR

Challenge 2: Attracting more diverse workers

An individual with a Certificate III or above and adequate language and literacy skills has a greater choice of employment opportunities and is more likely to be fully participating in the ACT economy. They are able to do skilled work in varied contexts and use their knowledge as a pathway to future learning. In addition, earning capacity tends to increase with higher education and training levels.

The average working-age Aboriginal and Torres Strait Islander person living in Canberra

A working-age Aboriginal and Torres Strait Islander person living in Canberra is more likely than the average Aboriginal and Torres Strait Islander person living elsewhere in Australia, to have a post-school qualification at Certificate III level or above. They are also more likely to be in employment.

The average working-age Canberran from a culturally and linguistically diverse background

A lack of adequate English language and literacy skills can create a barrier for a person seeking employment and/or participation in training to develop their skills. Literacy levels of at least Level 3 are necessary for meeting the increasingly complex demands of work and study.

On average, working-age Canberrans from culturally and linguistically diverse backgrounds are more likely than a person in the same cohort in the rest of Australia, to have literacy skills at Level 3 or above.

The average working-age Canberran from the lowest socioeconomic background

According to the 2011 Census of Population and Housing, 2.09% (or 4,446 persons) of the total ACT population aged 20-64 years lived in the most disadvantaged areas. Quintile 1 is considered the most disadvantaged by the Socio-economic Index for Area (SEIFA): Index of Relative Socio-economic Disadvantage (IRSD). Variables related to disadvantage include low income, low educational attainment, unemployment, and dwellings without motor vehicles.

Working age Canberrans in the most socio-economically disadvantaged areas are more likely to have or be accessing education or training towards a non-school qualification than the same disadvantaged cohort across the whole of Australian.

In 2011, almost two in three (65.4%) ACT 20-64 year olds in Quintile 1 had or were studying for a non-school qualification. In comparison, one in two (50.2%) 20-64 year old Australians in Quintile 1 had or were studying for a non-school qualification in 2011.

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THERE ARE CHALLENGES IN ATTRACTING MORE, AND MORE DIVERSE, WORKERS FROM INTERSTATE RURAL AND REGIONAL AREAS TO ENTRY-LEVEL OR LOW-SKILLED OCCUPATIONS IN THE ACT DISABILITY SERVICE SECTOR

Challenge 3: Attracting workers from interstate

Attracting more workers to Canberra from interstate is part of an overall solution to workforce capacity issues.

This is a particular challenge for sectors, such as the disability sector, looking to attract more, and more diverse, workers to lower-skilled and entry level occupations.

This is mainly because (a) Canberra has a shortage of affordable housing and (b) Canberra’s high standards of living can also mean high costs of living. These factors can be significant barriers to rural and regional workers taking up employment opportunities in the ACT disability sector.

Therefore any strategy for attracting new workers to the ACT disability sector from rural and regional areas must address a range of issues including:

• job security
• additional work-related benefits, such as the opportunity to gain a nationally recognised qualification
• career prospects
• assistance with finding suitable, affordable accommodation
• assistance with connecting their immediate family, where necessary, with the community, school, childcare and employment.

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PROVIDERS FACE CHALLENGES IN OFFERING LONGER-TERM OR PERMANENT POSITIONS (WITH BENEFITS LIKE THE OPPORTUNITY TO PARTICIPATE IN NATIONALLY RECOGNISED TRAINING) TO ATTRACT NEW WORKERS TO ENTRY-LEVEL OR NON-PROFESSIONAL OCCUPATIONS IN THE DISABILITY SECTOR

Challenge 4: Offering an attractive employment package

The uncertainty providers face, at least in the short-term, about the ongoing demand for their services by NDIS participants provides additional challenges to attracting new workers to the sector.

One way to address these challenges is to attempt to attract more casual workers to the sector. Of course, there are workers who are attracted to casual positions for different reasons but generally this will be due to their need for flexible and/or short-term work. Some workers may be looking for a second job or a job to supplement their income while studying full-time or in retirement.

Casual workers however, are excluded from ACT Government-subsidised traineeship opportunities. Employers of casual workers are also ineligible for Australian Government financial incentives for employing trainees. Part-time workers and their employers have access to these opportunities and incentives.

Other strategies, besides increasing the casual workforce, are needed if the sector is to attract more, and more diverse, workers while also allowing for the flexibility employers need in times of business uncertainty and/or transformation.

Many job seekers are looking for employment opportunities that provide a greater level of security, more hours and/or additional benefits, such as nationally recognised skills training. Many employers are looking for easier ways to source workers and more flexible workforce management solutions. Examples may include a shared pool of available, appropriately prepared workers or two employers sharing a full-time worker.

While many people work part-time by preference, for others it may reflect underemployment as they would like and are available to work more hours. Underemployment has been found to be particularly common among people from low socio-economic areas and disadvantaged cohorts within groups such as Aboriginal and Torres Strait Islanders, people with a disability, people from culturally and linguistically diverse backgrounds, women seeking to return to work after an extended absence caring for children and older Canberrans (i.e. people 55 years and over).

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EXISTING MARKETING STRATEGIES IN THE CARE INDUSTRY: CARECAREERS.COM.AU

The Commonwealth is funding the expansion of CareCareers.com.au into the ACT until September 2017.

The website:

• Promotes jobs, training and careers advice for the community sector covering disability, aged care, community care (this is also referred to as the “Care sector”)
• NDIS registered service providers can place free job advertisements which are reposted on other sites, including large job portals, at no extra charge
• Blogs, testimonials, stories and photos submitted by workers in the sector
• CareCareers YouTube Channel; behind-the-scenes Q&A videos; showcasing workers and roles
• Job seekers can speak to career advisors; receive job alerts and request follow-up support from a career advisor after a job application/interview
• Advertisements for community or job seeker events such as open days, awareness weeks and expos

Main gaps

• Showcasing of the ACT disability sector and ACT workers
• Links to ACT training opportunities and events
• Presence at careers market/expos in the ACT will be limited

CareCareers is likely to impact positively on retention although in an indirect way. There is space for the ACT attraction and retention campaign to address the main gaps in the services provided by CareCareers

On the whole CareCareers is a tailored, and to some extent interactive, attraction strategy. It is still a relatively universal strategy. The ACT attraction campaign in this proposal needs additional, more tightly targeted attraction and recruitment strategies that leverage off existing ACT Government workforce development programs.

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EXISTING MARKETING STRATEGIES IN THE CARE INDUSTRY: PROJECTABLE

The Commonwealth is funding the expansion of ProjectABLE into the ACT until September 2017

The project:

• Provides free 1/2-day programs for students in years 10, 11 and 12
• Interactive disability awareness and career workshops
• Emphasis on education, training and workplace experience
• Includes raising awareness of volunteer opportunities

Main gaps

• Limited scope for promoting and facilitating school-based traineeships
• Limited information about the range of training opportunities, learning supports and employer incentives available
• Limited scope for linking students and employers and for follow-up support
• Limited ability to measure longer term impact

ProjectABLE is a tightly targeted, interactive attraction campaign.

There is space for ACT strategies to address the main gaps in the services provided by ProjectABLE. For example, by improving its links to existing ACT Government programs that support student transitions from school to work and/or further training in the disability sector.

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AN ATTRACTION CAMPAIGN FOR THE SECTOR NEEDS TO TARGET WORKING AGE CANBERRANS WHO DO NOT CURRENTLY PARTICIPATE, OR DO NOT FULLY PARTICIPATE, IN EMPLOYMENT AND/OR POST-SCHOOL EDUCATION/TRAINING.

While Canberra has higher than average participation rates, there is room for improvement.

Target cohorts

If the number of people employed in the ACT disability sector is to grow at the rate required, an attraction campaign for the sector needs to also actively and tightly target working-age Canberrans who do not currently participate, or do not fully participate, in employment and/or post-school education/training.

People in the following cohorts often experience barriers to participating, or fully participating, in paid employment:

• Aboriginal and Torres Strait Islander people
• Culturally and linguistically diverse (CALD) people (including migrants and refugees)
• Women returning to work after an extended absence
• Young people
• People with a disability
• Older Canberrans (55 years and older)
• Job seekers in rural and regional areas

Barriers to employment

In general, underemployment is very often accompanied by a lack of education, work-related skills or experience, foundation skills (language, literacy, numeracy, ICT) and/or other social, health or economic barriers.

Such barriers limit the range of employment opportunities people can access or impact their ability to maintain employment. Thus any strategy for attracting more workers to the sector by targeting underutilised cohorts must also address their needs for skills development and support mechanisms.

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AN INITIATIVE IS NEEDED THAT INTEGRATES FOUNDATION SKILLS DEVELOPMENT, TRAINING AND WORK WITH THE PROVISION OF SUPPORT SERVICES FOR PEOPLE WHO MAY BE EXPERIENCING BARRIERS TO EMPLOYMENT OR MAY BE DISENGAGED FROM THE LABOUR MARKET

Aim

This initiative would aim to enhance engagement of people in target cohorts with opportunities to participate in training and work in the disability sector.

What is the initiative?

An effective response to underemployment requires collaboration across government agencies and community organisations.

The initiative would be a one year project which integrates attraction strategies with existing government programs that provide support and work-related training for job seekers in Canberra and the surrounding regions. Participants in ACT Government programs or networks and employers in the disability sector would be assisted to access a range of existing funded ACT and Australian Government workforce and training initiatives.

The initiative would be innovative because:

• the project team would partner directly with the ACT Government and build on existing relationships with clients seeking employment opportunities
• the attraction campaign would build on existing funding relationships and networks between the ACT Government, Australian Government, community organisations and disability service providers to facilitate the involvement of support and training providers
• the initiative would integrate foundation skills development, training and work with the provision of support services for individuals who may be experiencing barriers to employment or may be disengaged from the labour market
• the campaign would be supported by the production and distribution of tailored promotional materials that:

  showcase support work, disability services, community service and Canberra as an occupation, a career, a vocation and a community of choice acknowledge and value diversity link readers to CareCareers.com.au and additional information and support services, training and employment opportunities.

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SOME ACT GOVERNMENT SUPPORT PROGRAMS, NETWORKS & PARTNERSHIPS THROUGH WHICH EMPLOYMENT OPPORTUNITIES IN THE DISABILITY SERVICES SECTOR MIGHT BE DIRECTLY MARKETED

Aboriginal & Torres Strait Islander people

• Aboriginal and Torres Strait Islander Grants Program
• ACT Indigenous Community Email Network
• VET support funding

Culturally & linguistically diverse people

• Work Experience Support Program (WESP)
• Adult & Community Education (ACE) Programs (e.g. English for Living & Home Tutoring programs)

Women returning to work

• ACT Women’s Return to Work Grants
• Women’s Return to Work Information Sessions
• VET qualification completion bonuses

Young people

• Youth Coalition (advocacy, information & referral service)
• School-based traineeships
• Youth housing services
• VET-in-Schools

People with a disability

• Additional support funding for gaining nationally recognised VET qualifications
• Network of Employment and Training Agencies (NETA)

Older Canberrans

• ACT Older Persons Assembly
• Subsidised training opportunities for older persons
• ACE programs

Rural & regional job seekers

• ACT Australian Traineeships program
• CHC Affordable Housing

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GROUP TRAINING ARRANGEMENTS ARE ONE WAY EMPLOYERS MAY ACHIEVE A DEGREE OF FLEXIBILITY EQUIVALENT TO A CASUAL WORKFORCE, WHILE OFFERING A MORE ATTRACTIVE EMPLOYMENT PACKAGE

The attraction and employment of trainees through group training arrangements is underused in the ACT disability sector despite the potential benefits to employers and workers.

For example:

• the opportunity for the trainee to gain a nationally recognised qualification while engaged in paid work in the same industry
• host employer incentives of up to $4,000 that can contribute to covering the cost of releasing workers to attend training
• additional financial incentives for employers hosting an Aboriginal and Torres Strait Islander trainee, a mature age worker, or a person with a disability
• recruitment is managed by the group training organisation (GTO) in consultation with the potential host employer
• flexible training arrangements that include choice of RTO and choice of at-work, off-site, and/or online training delivery and/or assessment
• support in liaising with the RTO to ensure that the training content and methods are tailored to meet the needs of the host employer and the trainees
• highly flexible employment arrangements, including part-time, school-based, and full-time trainees, and shared employment arrangements (e.g. 2 host employers sharing one trainee)
• support in managing a change of RTO at any time during the traineeship
• probation periods during which the host employment arrangement can be terminated without notice, and after which only two-weeks notice is required.
• mentoring for the trainee, which has been demonstrated in national studies to correlate positively with improved traineeship completion rates and retention after training is completed
• workers’ compensation, superannuation, annual leave, sick leave, public holidays and payroll are managed by the GTO
• some GTOs operate across the ACT/NSW border and can source potential employees from rural and regional areas
• some GTOs have relationships with Aboriginal and Torres Strait Islander communities and employment service providers.

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USE OF GROUP TRAINING ARRANGEMENTS TO HOST TRAINEES IN DISABILITY SERVICES RELATED QUALIFICATIONS IN 2014-15

Table 1 below indicates that employers (including schools) in the disability sector employed five new trainees through group training arrangements in the period 1 July 2014 to 30 June 2015.

This compares to 11 trainees employed though group training arrangements in the children’s services sector, five in the aged care sector, 82 in the public services sector and over 186 in the building and construction sector during the same period.

Table 1: Total number of ACT trainees commencing in disability services-related qualifications and employed through group training arrangements in 2014-15

Qualification	Commencement date	Type of traineeship	Age of trainee at commencement	Gender of trainee
Certificate IV in Disability	28/01/2015	New Worker	18	F
Certificate IV in Community Services Work	25/08/2014	New Worker	18	F
Certificate III in Disability	13/08/2014	New Worker	18	F
Certificate III in Disability	11/08/2014	ASBA	17	F
Certificate III in Disability	12/12/2014	ASBA	17	F

Source: ACT Education and Training Directorate. (August, 2015). ACT Vocational Education and Training Administration Records System.

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AN EXAMPLE OF A MARKETING STRATEGY FOCUSING ON BOTH ATTRACTION AND RETENTION BY CRAFTING A SHARED SENSE OF ‘WHO WE ARE’ AND SHOWCASING ‘WHAT WE STAND FOR’: FROM ACCOR HOTELS

Relevance to the disability services sector

Accor Hotels is an example of low-cost business model. Accor sought an effective way to attract and retain a wide variety of non-professional and professional staff. Their particular workforce challenge was attracting and retaining staff in lower-paid, lower-status, lower-skilled positions that are often casual and/or shift-work and do not require qualifications for entry nor have obvious or established career pathways. Examples include housekeeping staff, kitchen-hands, food and beverage attendants, porters, administration staff and telephonists, without whom the hotel business could not operate.

Strategy:

An internal and external marketing campaign that represents, advances, creates, and embeds a collective vocational narrative that is shared by low- and high-skilled workers alike.

• Interactive website jobsataccor.com.au: “Day in the Life…” videos; “Read our stories”; “Are you a people person?” quiz.
• Existing staff acting as ambassador: exemplifying the values and ideals of their occupations, the organisation and the industry.
• Glossy information pamphlets - tailored to specific target groups - that develop an understanding of what it means to work for Accor (e.g. “What we can offer”; “Why we want you”).
• Appealing equally to people’s unique personal identities and their group identities e.g. “Each and every one of our hotels is as unique as you are”; “Meet the team”; “We’re a caring bunch”.
• Acknowledging and valuing diverse group identities: promotion is not restricted to job role but also a range of social identities (gender, age, cultural diversity) that may be meaningful for potential and existing staff e.g. “Our Indigenous Story”; “Experienced Workers” (aimed at workers 55+).
• Making ‘us’ matter: “Jobs within the Family”; “The Perks: We like to reward our people for being so awesome”.
• Showcasing activities that are useful to staff: training and careers tailored for specific groups.

Accor developed a successful marketing strategy that built on an understanding of why people join groups and why workers sustain commitment to roles and groups despite low status and persistently low pay. The Accor campaign focused on what gives workers meaning and purpose to their job, provided a vehicle to acknowledge the value of their work, and promote fun, self-development and career progression.

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PROJECT 1: ADDITIONAL OPPORTUNITIES

Role models

There is an opportunity for the attraction and retention campaign to cultivate people within the sector to influence the community.

redacted

Heightened community interest in the NDIS

Leverage the current community interest in the NDIS to gain access to ‘free’ promotional opportunities generated through the ACT Government’s activities. These opportunities would be coordinated by the contractor who would also provide support, advice and background research.

Assistance from other industries

Provide work-experience for multimedia students in the campaign (e.g. CIT; UC: film and sound production and editing; graphic arts; photography). This approach was used successfully by ScreenACT for the Centenary of Canberra website. Involving local students has the added benefit of raising awareness of the disability sector in the wider community and among young people in particular.

A specialist to target schools

Embed a disability occupations specialist liaison officer in the Education and Training Directorate to work alongside VET field officers to promote training opportunities and support completions in disability to school students and employers. The liaison officer would benefit from the field officers’ general knowledge of how to navigate the VET sector and existing networks and relationships. The Directorate is also the key source of data and intelligence about existing uptake of school-based traineeships.

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PROVIDING ATTRACTIVE OPTIONS TO ATTRACT EMPLOYEES: MAKING BETTER USE OF AVAILABLE SERVICES TO HELP EMPLOYERS ATTRACT MORE OF THE RIGHT PEOPLE

Aim:

To quickly (within 6-12 months) increase the number of suitable workers available to the disability sector and, at the same time, increase the diversity of the disability services workforce.

Objectives:

• maintain flexibility of employment arrangements for disability service providers facing uncertain times, without relying solely on casual employment arrangements
• make employment in the sector more attractive to job seekers
• provide extra support for preparing and training new workers - to more quickly deliver the skills and abilities employers are looking for
• improve disability service providers’ access to host employer financial incentives that assist them to cover costs related to employee training (e.g. covering wages for employees while they attend training).

Strategy:

Improve coordination, marketing and utilisation of existing government and community services, such as:

• government-subsidised traineeship programs and additional support funding and services for trainees
• government-subsided pre-traineeship and work-experience programs
• government-subsided foundation skills (i.e. language, literacy, numeracy, computer skills and other employability skills) development programs
• mentoring and support for trainees provided through group training arrangements (GTAs)
• support and flexible employment and training arrangements for host employers provided through GTAs
• government financial incentives for employers commencing and completing a trainee in a priority occupation
• government financial incentives for employers hosting trainees from a disadvantaged cohort through GTAs
• government administered workforce development programs (e.g. Work Experience Support Program (WESP) and Women’s Return to Work Program).

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HYPOTHETICAL EXAMPLE: ATTRACTING NEW WORKERS FROM CULTURALLY AND LINGUISTICALLY DIVERSE (CALD) BACKGROUNDS

Rationale

• Lack of diversity in the disability services workforce has been identified as an issue for the sector by the NDS.
• To increase the number of workers available to the sector, attraction strategies need to target a range of cohorts, including cohorts experiencing underemployment or barriers to employment.
• In the ACT people from CALD backgrounds often experience underemployment and barriers to full participation in the workforce. Examples include having post-school education and qualifications that are not recognised in Australia, cultural barriers, difficulties with reading, speaking and/or writing in the English-language, and/or difficulties gaining access to opportunities to demonstrate their employability skills and abilities.

Example strategy:

The proposed project could:

• Step 1: set up a procedure for contacting potential workers in the WESP program (i.e. a cohort of approximately 240 applicants per year)
• Step 2: provide information to WESP applicants on work-experience, training and employment opportunities available to in disability services occupations.
• Step 3: set up systems to coordinate the pathways for WESP participants to navigate through the various stages from pre-employment to employment in the disability sector.
• Step 4: set up monitoring systems to ensure GTOs are providing the services promised in ways that meet the needs of disability providers and trainees.

An important aim of the proposed project is to address the burden on disability providers associated with employing workers who may have English language difficulties. One way to do this is to help potential employees and their employers make better use of existing support services and pathways to employment.

Evidence reveals that these support services and pathways are currently underused by the disability services sector.

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STEP 3 IN MORE DETAIL - USING A HYPOTHETICAL EXAMPLE TO SHOW WAYS IN WHICH ENGLISH LANGUAGE PROFICIENCY ISSUES MAY BE ADDRESSED BY THE PROPOSED PROJECT (RATHER THAN BY THE EMPLOYER)

Stage 1:

WESP participant enrols in an existing government-funded program designed specifically to develop employment-related English language skills.

E.g. MARSS English for Living Program subsidised by the ACT Adult and Community Education Grants Program. The English for Living Program is designed to assist people to participate in work and training.

Stage 2:

WESP participant enrols in a government subsidised pre-traineeship program.

E.g. an ACT Skilled Capital course in Certificate II in Community Services:

• delivered by a registered training organisation (RTO)
• providing a work experience component that is integral to the course
• providing additional foundation skills development that is fully integrated into the course
• providing a $500 completion bonus to the student on completion of the course.

Stage 3:

The WESP participant gains employment with a GTO under a traineeship contract to complete a Certificate III in Individual Support within 18 months.

The training is provided by an RTO whose fees are subsidised by the ACT Australian Apprenticeship Program. Additional program funding is available for language and literacy development, cultural support, tutoring and mentoring for the trainee.

Stage 4:

The GTO liaises with potential host employers to:

• assess their training and employment needs to:
  • tailor the hosting arrangement to the host employer’s needs
  • identify suitable candidates to put forward for interview with the host employer
  • Identify a suitable RTO to provide training that meets the host employer’s needs
• arrange a recruitment interview between potential candidates and host employer.

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SERVICE PROVIDERS NEED TO MEET THE CHALLENGE OF INCREASING WORKFORCE PRODUCTIVITY WHILE MANAGING CHOICE AND LABOUR COSTS WITHIN PRICING LIMITATIONS.

Under the NDIS:

• competition between service providers will increase, rewarding those who deliver good value, high quality and responsive services. Existing ACT service providers will experience increasing competition from interstate, national and, possibly, multinational providers that could deliver the services at a lower cost.
• service delivery will shift to be more individualised and person-centred.

New delivery models:

providers will need to design their services in a manner that enables the desired innovation, competitiveness and efficiency to be achieved.

Managing diversity:

of roles, expectations and interests within teams. E.g. managing issues arising from the use of volunteer workers to supplement service delivery by paid employees; qualified and unqualified workers doing the same role; or generalist support workers and specialist support workers both dealing with clients with complex needs. In addition, teams will not only exist within organisations, but also around individual clients. Such teams around clients are likely to consist of workers from different organisations.

Fostering high performing work practices:

to enhance worker adaptability, capability, engagement and wellbeing. More will be required of coordinators, facilitators and managers to identify evidence-based frameworks and processes that support and maintain good communication, trust and cooperation.

Business transformation expertise:

existing ACT providers have limited first-hand experience implementing innovative service delivery models.

Lack of standardisation:

widely differing views in the sector about the role, boundaries and skills required of support workers.

Increasing isolation of support workers:

as a result of a shift to more individualised services and increased casualisation.

Volunteers:

uncertainty as to how volunteers appropriately fit into an individually-planned, fee-for-service model.

Training:

the low-cost funding model may limit workers’ access to nationally recognised training, increased demand for on-the-job training and increase the need to engage unqualified/less qualified workers.

According to the Australian Industry Group (AIG), high performing workplaces are more productive, innovative, financially more profitable, more fair, have more committed employees, and provide a better customer experience. AIG. (2012). High performing organisations: Maximizing workforce potential. Retrieved from http://www.aigroup.com.au

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PROPOSED STRATEGY: COLLECTIVE IMPACT: THE WORKFORCE ISSUES IN THE DISABILITY SECTOR ARE COMPLEX. NO SINGLE ORGANISATION, HOWEVER INNOVATIVE OR LARGE, COULD TACKLE THESE ISSUES ALONE.

From the challenges of the introduction of the NDIS a small group of leaders have emerged in Canberra, who are interested in working collectively to prepare their sector for the immediate challenges around:

• workforce shortages
• learning and development
• marketing the sector
• improving team performance
• exploring new delivery models.

This is very positive as there is scant evidence that isolated initiatives are effective in solving many sector workforce development problems. Isolated impact approaches tend to be oriented toward finding and funding a solution embodied within a single organisation, combined with the hope that the most effective organisations will grow or replicate to extend their impact more widely.

That is not to imply that all sector development problems require collective action. Some technical problems can be solved by individual organisations. Technical problems tend to be well defined, the answer is known in advance, and individual or a few organisations partnering together have the ability to implement the solution.

Adaptive problems are complex, the answer is not known, and even if it were, no single entity has the resources to bring about the necessary change. Reforming public perceptions of disability service occupations, increasing workforce productivity, and managing choice and labour costs within pricing limitations are all adaptive problems.

In these cases, reaching an effective solution requires learning by the stakeholders involved in the problem, who must then change their own behavior in order to create a solution.

Shifting from isolated impact to collective impact is not merely a matter of encouraging more collaboration. It requires a systemic approach that focuses on the relationships between providers and the progress toward shared objectives. And it requires ensuring participating providers can assemble and coordinate the specific elements necessary for collective action to succeed.

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RESEARCH SHOWS THAT SUCCESSFUL COLLECTIVE IMPACT INITIATIVES TYPICALLY HAVE FIVE CONDITIONS THAT TOGETHER PRODUCE TRUE ALIGNMENT AND LEAD TO POWERFUL RESULTS:

The Five Conditions of Collective Impact

Condition	Description
A common agenda	All participants have the same vision for change including a common understanding of the problem and a joint approach to solving it through agreed actions
Shared measurement systems	Collecting data and measuring results consistently across all participants ensures efforts remain aligned and participants hold each other accountable. Partnering with research institutions will assist here.
Mutually reinforcing activities	Participant activities must be differentiated while still being coordinated through a mutually reinforcing plan of action.
Continuous communication	Consistent and open communication is needed across the many players to build trust, assure mutual objectives and create common motivation.
A backbone support organisation	Creating and managing collective impact requires a separate organisation with staff and a specific set of skills to serve as the backbone for the entire initiative and coordinate participating organisations and agencies.

Creating a successful collective impact initiative requires a significant financial investment: the staff of the backbone organisation are needed to lead and support the initiative’s work. Coordination takes time, and the participating organisations are unlikely to have any to spare. The expectation that collaboration can occur without a supporting infrastructure is one of the most frequent reasons why it fails. Skillful implementation of more intangible dimensions will be essential to successfully achieving collective impact. Funding for interventions that build relationship and trust among diverse stakeholders, develop identity leadership and create a culture of learning will be necessary.

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THE INITIATIVES RECOMMENDED BY THIS PROPOSAL ARE INTENDED TO TAKE A GUIDED EMERGENT APPROACH RATHER THAN A TOP-DOWN, IMPOSED APPROACH.

The intended approach is that actions will involve individual providers and be informed their needs and experiences while providing expert commercial and academic advice, evidence and training.

Emergence is a term from ‘Complexity Science’ used to describe events that are unpredictable, which seem to result from the interactions between elements, and which no one organisation or individual can control. To say that a solution is emergent, however, is not to abandon all plans and structures. Rather than deriving outcomes by rigid adherence to preconceived strategies, a key tenet of addressing complex problems is to focus on creating effective rules for interaction. These rules ensure alignment among participants that increases the likelihood of emergent solutions leading to the intended goal.

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PROJECT 2: A HEALTHY COMMUNITY OF PROVIDERS: WORKING EFFICIENTLY AND WORKING TOGETHER TO ACCELERATE CHANGE

Priorities

• Fund an organisation with a specific set of skills to serve as the backbone for the entire initiative and to coordinate participating organisations and agencies
• Support providers to explore the potential for transforming their service delivery models
• Provide actionable, expert advice on building effective teams and high performing work practices
• Develop organisations’ change capital to enable them to accelerate progress

Vision

• Motivated organisations will be supported and assisted to create their own bespoke, best-practice workforce capacity solutions
• Each organisation will engage in activities to different degrees and in different ways, depending on the context, their needs and their capacity

Principles

• Encourage collaboration across overlapping initiatives
• Guide vision and strategy
• Support aligned activities
• Build public will
• Advance policy
• Use evaluation to inform strategy and help organisations learn
• Include solutions from outside the disability sector

Products

• A community of practice through which organisations can learn from each other
• Good-practice models, evidence, resources and advice assembled for organisations to access as desired
• Learnings shared with the sector via publications, social media, seminars
• Shared measurement practices established
• Established relationships with research institutions (e.g. ANU) to facilitate ongoing research into workforce capacity development in the community care industry

“The most powerful role for funders to play in addressing adaptive problems is to focus attention on the issue and help to create a process that mobilises the organisations involved to find a solution themselves… Communities and organisations around the world have embraced a collective impact approach to accelerating change across systems.” Stanford Social Innovation Review. Retrieved from: http://ssir.org/articles/entry/collective_impact

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PROJECT 2: CHANGE ACCELERATION PROGRAM FROM A DIFFERENT PERSPECTIVE

Sector level interventions

• Backbone change management consultancy which can bring together and make accessible commercial and academic expertise
• Promotion and advice on implementing and managing high performing work practices, including self-managing teams
• Cultivating people in the sector to influence the sector i.e. development of Key Opinion Leaders (KOLs): trusted people in the sector who will implement the ideas
• Timely and relevant discussions short seminars
• Advice and support on implementing a capability framework tailored for the needs of the organisation

Sustainability

• Publishing of case studies and success stories
• New findings incorporated into an internet-based knowledge portal
• Dissemination of ideas through advocacy by KOLs
• Link to centres of excellence and ongoing research in related areas (e.g. Centre of Excellence for Building Sustainable Societies; research in identity management and leadership in Allied Health industry)
• Establishment: setting up processes and systems so providers can manage ongoing change themselves

Evaluation

• Define and measure success metrics and monitor change progress
• Analyse and report results from data collected by participating research institutions (e.g. ANU; UQ)

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BUILDING HIGH PERFORMANCE SKILLS UTILISATION AND WORK ORGANISATION PRACTICES.

Characteristics of high performing organisations (HPOs)

• effective induction processes
• creation or design of jobs that will provide challenge, responsibility and control
• flatter management structures
• open channels of communication and the sharing of strategic business information with employees
• HPO’s empower workers by involving them in quality improvement processes and giving a voice in company decision-making
• work is organised around principles of teamwork, lean production and quality management and processes are supported by relevant and current technologies

Leadership characteristics of high performing organisations

• helping not directing
• more emphasis on following
• more time and effort in managing people
• clear values and practice what they preach
• encourage employee development
• welcome feedback as learning
• increased recognition and acknowledgement
• foster involvement and cooperation among employees

Client experience of high performing organisations

• more effort in understanding client needs
• act on suggestions
• create value
• client satisfaction goals

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BUILDING TEAMS AROUND THE CLIENT: RESEARCH SHOWS THAT THE DIRECT SUPPORT WORKER IDENTIFIES MOST CLOSELY WITH THEIR CLIENT AND THE CLIENT’S FAMILY/VOLUNTEER CARERS.

The shift to more individualised services, delivered in the client’s home, and increased use of casual workers may exacerbate the isolation of direct support workers.

Direct support workers’ close relationship with the client and their carers is a key factor in a client-centred approach and the retention of workers. In addition, the direct support worker can possess detailed and holistic understanding of the needs and capabilities of the client. However, direct support workers often work alone with irregular contact with their ‘head office’. This can lead to direct support workers identifying more with their client and less with their employer. It can also mean valuable information is not shared with the client’s wider care team e.g. allied health professionals, nurses, coordinators.

Research suggests that direct support workers receive low levels of respect and comprise some of the lowest paid workers in health and social care (cf: Noelker & Ejaz, 2005). Studies have shown that they are rarely approached for information when care planning decisions are made (Caspar & O’Rourke, 2008; Cott, 1998) and that healthcare organisations lack systems to support knowledge transfer between support workers and other professionals (Dellefield, 2006; Kontos et al., 2009). In response to this lack of recognition, support workers have been shown to form a distinct occupational identity which offers a useful framework for analysis when examining barriers to multiprofessional teamwork.

An objective for clients and their families is reconnection with the community and greater independence. The support worker-client-carer relationship is an important factor in achieving this objective. However strategies to reduce the social isolation of the support worker need to be developed. Fostering identification with a team and the organisation can motivate people to behave in ways that align with the best interests of the group, leading to good communication, trust, cooperation and support between group members. Active harnessing of these positive group processes provides a basis for supporting and maintaining employee wellbeing and engagement (Haslam et al., 2014; Jetten et al., 2012; Peters et al., 2014; Pittinsky & Simon, 2007).

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GOOD PRACTICE EXAMPLE: SELF-MANAGED TEAMS

The Buurtzorg (Netherlands) experience has demonstrated the potential of self-managed or semi-autonomous teams.

• Each team dedicated to a group of clients. Each member of the team is multi-professional, i.e., they perform many care tasks for each client.
• Each team regularly meets to discuss issues, goals and barriers. Each team elects a representative who meets with representatives of other clusters. Cluster meetings facilitated by coordinator. Meeting agenda is to discuss distinct and shared issues, goals and barriers.
• Coordinator communicates organisational objectives and reports cluster meeting discussions to head office. Coordinators also share information with other coordinators.
• Disability service providers meet on a quarterly or semi annual basis to share and discuss sector issues and strategy.

Social psychologists (cf: Haslam et al, 2013) have identified elements of leadership approaches and organisational processes that are essential for such teams to be effective and sustainable over time.

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PROJECT 2: CONSIDERATIONS

What might the successful tenderer look like?

The successful backbone support organisation requires dedicated staff separate from the participating organisations who can plan, manage, and support the initiative through ongoing facilitation, technology and communications support, data collection and reporting, and handling the myriad logistical and administrative details needed for the initiative to function smoothly. The consultant would have a lean staffing model and mobilise many partners to help further the work. Because of the number and diversity of participants, the consultant and its partners must be able to quickly determine what processes are universal and which require adaptation to a local context.

It is ideal if three conditions are in place before launching a collective impact initiative: an influential champion, adequate financial resources, and a sense of urgency for change. Together, these preconditions create the opportunity and motivation necessary to bring people who may have never before worked together into a collective impact initiative and hold them in place until the initiative’s own momentum takes over. The most critical factor is an influential champion (or small group of champions) who commands the respect necessary to bring CEO-level cross-sector leaders together and keep their active engagement over time. Therefore, a consultancy with knowledge and expertise in collectivistic leadership approaches and harnessing social identity resources would be an ideal candidate.

Example KPIs

• Measureable shift in the degrees of trust and collaboration across CEOs.
• Measurable progress on the dimensions of transformation - decision making/planning processes in place, agreement on future structure; operational implications indentified and addressed.
• Feedback from all CEOs as to approach, effectiveness and impact.

Additional opportunities:

Academics from the following research institutions have indicated interested in the ACT’s disability services workforce challenges and the collective impact approach: organisational and social psychologists from the Research School of Psychology, ANU; the National Institute for Mental Health Research, ANU; and Professor Alex Haslam (and team), Australian Research Council Laureate Fellow, School of Psychology, University of Queensland (formerly from ANU).

Collectivistic leadership approaches require broadening leadership development beyond an exclusive focus on individuals. Such approaches view leadership as an accomplishment of collectives rather than as the actions of individuals identified as leaders.

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PROJECT 2: PRACTICAL APPLICATION 1: MANAGING THE WORKFORCE THROUGH SELF-MANAGED TEAMS: NEW LEADERSHIP APPROACH.

Change context

After being exposed to information about the Buurtzorg model, from the Netherlands, some NDS-registered ACT service providers indicated an interest in exploring the potential for implementing self-managed teams. Providers where also interested in exploring other relevant good-practice examples of flatter management structures. In addition, in the NDIS environment teams will not only exist within organisations, but also around individual clients. Teams around clients are likely to consist of workers from different organisations.

Issues

There is a body of research that indicates positive client, community and workforce outcomes for a self-managed teams strategy (cf: Haslam et al., 2013; Huybers, 2012). However, this research also suggests that this strategy may require a radical structural and managerial transformation for some providers. Social psychologists have demonstrated that leadership focusing on group identity management and harnessing positive group processes is essential if self-managed teams are to be productive and sustainable over time. This strategy works best if leaders and followers alike are aware of underlying group processes that can have both negative and positive impacts and what to do to manage these. An important principle is that group processes will influence group members’ behaviour whether or not they are acknowledged.

Opportunities:

Stakeholders have indicated interest in learning more about effective ways of harnessing positive group processes and supporting teams to be effective and harmonious. Stakeholders can see potential for effective self-managed teams to create positive and satisfying workplaces which, in turn, may assist attraction and retention in a competitive labour market. In addition they see the benefit of team-based management for providing on-the-job training. Further, they anticipate that sector-wide education about team dynamics may help teams with members from different organisations work better together.

There is a great deal of local expertise about harnessing positive group processes at ANU and its partner universities. There is the opportunity for the contracted change consultant to make available strategic human resources advice, training and support for providers to access. For example, advice on the efficacy and implementation of the following strategies:

1. Bottom up and top down planning: Strategy and planning is a collaborative process involving frontline workers and executive in discussion of distinct and shared goals and barriers to achievement. The aim is, through the planning process, to create identity-based bonds between leaders and followers, and new knowledge from which the whole organisation may benefit.
2. New leadership: Self managed teams require leaders who have the skills to create and maintain team and organisational identity, who can work collaboratively to identify and realise goals and who can develop structure and processes that embed the various team identities.
3. Team based recruitment and training: Each team would be responsible for recruiting and inducting their own team members. This has a number of advantages in terms of team cohesion and support. Team based training means that each team decides what training its members require based on the particular requirements of their work and team member capabilities.

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PROJECT 2: PRACTICAL APPLICATION 2: ENCOURAGING COLLABORATION ACROSS OVERLAPPING INITIATIVES: THE VOLUNTEER WORKFORCE

Change context

The sector has identified opportunity related to the engagement of volunteer.

Issues

How can/should volunteers be engaged when clients or service users are paying for a service, but where volunteers (by definition) are not financially compensated? How can organisations/clients/self-managed teams best incorporate volunteers into an individually-planned fee-for-service model?

Existing initiatives, advice and best-practice

• Volunteering and Contact ACT (VCA) is both the peak body for volunteering and the volunteering support service for the ACT and the key source for the Canberra community to access accurate information on, and referral to, Canberra’s community services and programs.
• Volunteering Australia has recently published a new, updated definition of volunteering reflecting changes in how people volunteer in Australia.
• Volunteering Australia has also recently published updated National Standards for Volunteer Involvement to provide useful guidance in the NDIS context.
• VCA’s publication Designing Volunteer Roles: A practical guide.
• Policy directives from the Fair Work Ombudsman.
• Industrial relations system

Opportunities:

Larger-scale system change comes from better cross-sector coordination rather than from the isolated intervention of individual organisations. In practical terms, the contracted change consultant would work in partnership with the peak body (VCA) to raise awareness and discussion of existing advice and resources. This partnership would then work with interested service providers to provide practical support to implement best-practice. In this way the resources of the peak body can be augmented, accelerating change in policy and practice.

Each service provider may have a slightly different definition of the problem and the ultimate goal. These differences are easily ignored when organisations work independently on isolated initiatives, yet these differences splinter the efforts and undermine the impact on the sector as a whole. Collective impact requires that these differences be discussed and resolved. Every participant need not agree with every other participant on all dimensions of the problem. In fact, disagreements continue to divide participants in most examples of collective impact. All participants must agree, however, on the primary goals for the collective impact initiative as a whole. The change consultant would coordinate a process to find common ground among the different objectives of service providers, community groups and clients in order to establish workable cross-sector change.

“Collective action doesn’t happen often, not because it is impossible, but because it is so rarely attempted. Funders and nonprofits alike overlook the potential for collective impact because they are used to focusing on independent action as the primary vehicle for change.” Stanford Social Innovation Review. Retrieved from: ssir.org/articles/entry/collective_impact

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PROJECT 2: PRACTICAL APPLICATION 3: ENCOURAGING COLLABORATION ACROSS OVERLAPPING INITIATIVES: BEST PRACTICE PEER WORK IN THE NDIS ENVIRONMENT

Change context

The sector advises that a significant increase in demand for psychosocial disability support is expected as a result of the introduction of the NDIS. Psychosocial disability support providers report a longer term inability to maintain the current highly skilled workforce under the new conditions.

To respond to these pressures requires diversification of the workforce and of recruitment strategies and sources. To grow the workforce under challenging circumstances we need to look outside traditional audiences for new recruits and build a workforce with diverse skills and qualification levels.

In this context one of the target populations for recruitment will be people with lived experience of mental health issues. This population can be a source of highly skilled specialist peer support workers as well as entry-level support workers in the NDIS environment. Research supports positive recovery impacts of employment for people with lived experience, as well as positive recovery impacts of peer work for service participants.

Issues

The value of employing peer workers in ACT and indeed throughout Australia is still not well understood. There appears to be a lack of consistency in role definition, tasks undertaken by peer workers and other critical aspects of the employment relationship with peers.

Existing initiatives, advice and best-practice

Mental Health Community Coalition (MHCC) ACT, peak body for community-managed mental health service providers in the ACT, has facilitated the establishment of Peers ACT as part of its ongoing commitment to the development of a strong and professional peer workforce in the community mental health sector. MHCC has proposed a project to improve access for all stakeholders to comprehensive and up-to-date information on world-wide best practice on the integration of peer workers into the workforce.

Opportunities:

Access for providers to expertise and assistance in the development of an innovative, sustainable service delivery model that incorporates specialist peer support workers and entry-level support workers.

Facilitate collaboration between the National Institute for Mental Health Research, ANU, MHCC ACT, service providers and Volunteering and Contact ACT leading to ongoing research into best practice for integrating the role of peer workers and peer support services for people with psychosocial disability.

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PROJECT 2: PRACTICAL APPLICATION 4: NATIONAL DISABILITY SERVICE’S (NDS) CAPABILITY FRAMEWORK

Change context

The introduction of the NDIS will require the designing and redesigning of jobs to meet the future needs of the people supported and the organisation.

Issue

There is lack of consistency in role definition for a range of disability workers. In particular, there are widely differing views in the sector about the role, boundaries and skills required of support workers including paid, volunteer and peer support workers.

Existing initiatives, advice and best-practice

The NDS Capability Framework was developed by NDS in partnership with People Advantage (organisational renewal consultants) and funded by NSW Govt. The Framework provides practical support, tools, and advice for businesses in designing job roles. It has the flexibility to cater for a range of worker-types, including paid and unpaid, qualified and unqualified workers performing similar roles. This assists with a number of operational and strategic workforce issues including advertising, supervision, pay rates, training and performance management. NDS/People Advantage provide fee-for-service introductory and advanced workshops to interested service providers to learn how to use the resources to design job roles. Thirteen ACT service providers have attended half-day introductory workshop on the Framework. The feedback from participants was positive and there appears to be interest in this product.

Opportunities:

Applying an emergent framework to sector interventions, the contracted consultant would first gauge the extent of provider interest prior to purchasing this product. It could be anticipated that each provider would engage with the workshops and additional implementation support services to different degrees and in different ways, depending on the context, and their needs and capacity.

The consultant could negotiate with and sub contract NDS/People Advantage around the delivery of the workshops and follow-up advice to meet providers needs.

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