Individual submission to the Inquiry into the implementation, performance and governance of the National Disability Insurance Scheme in the ACT
As a client of NDIS our experiences have been less than satisfactory. For us, NDIS has been and continues to be characterised by a considerable bureaucratic burden involving unnecessary and repetitious processes, excessive delays, conflicting advice, high staff turnover and an inadequate approach to either case management or translating case experiences into policy. NDIS operational policy can also appear arbitrary and in some cases not only conflicts with the expressed provisions within an NDIS plan but is sometimes impractical and constructed without concern to industry practice.
While the examples are numerous, these may serve to illustrate the issues we have experienced with NDIS:
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The first NDIS plan bore little relationship to the extensive evidence we provided at some
cost to us. Professional assessments indicating the extent of disability and the need for equipment and remedial therapy were not addressed. Despite having to make specific equipment arrangements to enable an assessment meeting, NDIS were still unable to address the specific disabilities apparent to them and noted at the assessment meeting;
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Having identified the issues with the first plan we sought review of the particular clauses
within the plan that were at issue. It took in excess of a month for NDIS to direct us in this matter so that we could attain a review. However, after complying with the direction, NDIS took no apparent action and eventually we rolled the issues we had with the plan into the annual review at the expiration of the first plan. In effect, this had meant that we were unfunded in the areas that were identified to NDIS for at more than one year. We understand from other NDIS clients that these delays or lack of response are common place and to be expected when dealing with NDIS;
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In the initial plan NDIS had made provision for equipment of only $10 in total, however, the
specific clause covering this noted that NDIS would consider further amounts under the clause on the production of professional assessments. These assessments had already been provided for the production of the plan, but there was no evidence that NDIS had taken these into account. Again, at cost to ourselves, the professional assessments were redone and submitted under the provisions of the plan. However, NDIS then advised after some delay that as a matter of policy, any request of this type needed to be made as a submission to review the total plan. In effect the provisions of the specific clause did not apply as worded. On a legal forensic reading of the terms, the relevant clause specifically enabled NDIS to consider claims in relation to the clause in isolation as the clause provided its own mechanism for review. The consequence for the client in this apparently arbitrary policy is delays and a more complicated lengthy and therefore costly process for the client and the tax payer;
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After more than a year a second plan was produced through the newly appointed area
coordinator with far more satisfactory results in terms of the plan’s provisions. Under the new plan
approval was given for specific equipment on production of a quote. Quotes had been provided to NDIS in preparation for the second plan and the “fresh” quotes were in fact no different to the first quotes on which the plan was based. Approving the quote should have been a formality and could have been turned around immediately by NDIS. It has been more than a month with no apparent action on NDIS’s part. The assessment meeting with NDIS for the first plan dates back to December 2016, it is now late March 2018 with no material result;
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With personal equipment that needs to be fitted for the individual and assessed in use it is
common industry practice to provide a fitting that is fixed and then to apply equipment to the fitting until the most appropriate equipment is identified. This process can take some weeks and in some cases there can be in excess of 3 or 4 different equipment models and makes to trial. NDIS, however, will only consider making funds available where the specific equipment has been identified and quoted with the obvious problem that the client cannot trial and identify with their professional the most suitable equipment for them. NDIS’s approach takes no account of industry practice in this matter or the specific issues involved in attaining the best result for the client. In this I would note that the best result does not mean the most expensive, simply the most suitable. Applying the NDIS requirements in this, professionals will likely be motivated to provide the most advanced and therefore the most expensive option to minimise client disappointed in the absence of a trial;
Internally, it is clear that many of NDIS staff are committed to delivering a good service. Looking from outside they appear frustrated in this endeavour by their own organisation. Understandably, staff turnover has appeared to be considerable and the ability to carry information over from one staff member to the next is poor. It is not surprising that NDIS decisions did not appear to be made with cognisance of the material they had in fact requested and been provided.
The one positive experience we have had was with the outsourced area coordination business. While they were initially difficult to establish suitable lines of communication with, they were far more professional and efficient in assessing the material provided for the production of a plan. To their credit, it was clear from the plan content that not only had we been heard, but the material we had paid for and presented had actually been read. Instead of taking months, the elapse time between the planning meeting and an approved plan was a little over two weeks. As can be seen from example 4 above, the only difficulty with the plan produced through this process has been as yet unresolved delays within NDIS.
In summary, our dealings with NDIS at a personal level can be described as uncertain, time consuming, frustrating and stressful. NDIS has presented itself as inefficient and in the examples above, ineffective in delivering its service. We can only assume that this is at an unnecessarily high administrative cost to the tax payer. If our experiences are not isolated, NDIS needs to establish a stronger client focus, greater policy consistency and a more effective case management approach.
NOTE: Specifics to our dealings with NDIS have not been included for reasons of privacy. These specifics can be provided on a confidential/not for publication basis if required.
David Roberts
29 March 2018