ACT Legislative Assembly Inquiry into the implementation, performance and governance of the National Disability Insurance Scheme in the ACT LACommitteeHACS@parliament.act.gov.au
CatholicCare CANBERRA & GOULBURN
Thank you for the opportunity to make a submission to the ACT Legislative Assembly in regards to the implementation, performance and governance of the NDIS in the ACT. CatholicCare Canberra & Goulburn has operated in the NDIS since the launch of the trial in the ACT and continues to support the principles of the scheme. CatholicCare has however experienced significant pressure as a result of issues related to the implementation, performance and governance of the NDIS and as such wishes to highlight some issues for the Assembly to consider. In summary they include:
- Inefficient systems which impact on performance of both the NDIA and providers.
- The interface between the Health system and the NDIS.
- Issues around workforce capacity and development
- Inadequate pricing leading to the risk of market failure
- Issues in regards to quality and safeguards
Inefficient systems which impact on performance of both the NDIA and providers
The ongoing implementation of the scheme which continues to place the administrative burden on service providers is a huge issue given the requirement for providers to become leaner as a result of the NDIA’s pricing. The Portal is slow and cumbersome, and does not provide service providers with the information or authority required to efficiently and effectively support individuals to administer their plans. We recognise the work being done in regards to the portal, however there continues to be huge onus placed on providers to follow up on requests and emails to the NDIA rather than having effective systems which allow both the Agency and the Provider to perform effectively.
This administrative burden is in no way covered by the NDIA’s pricing, therefore CatholicCare would suggest a levy paid to registered providers which would assist in subsiding the man hours required to operate within the current NDIA systems.
The interface between the Health system and the NDIS
As the NDIS progressed through roll out and now as we operate in full scheme, it is clear that there is significant work to be done on the interface between the NDIS and the Health System. With limited, and often only short term, funding available to people who are deemed ineligible for the NDIS and the siloing of the Health system, there is great potential for individuals and families with complex needs to be inadequately supported or to slip through the cracks completely. Many of the block funded programs which did not transition into the NDIS are based on the premise that those not eligible for the NDIS don’t need regular ongoing support. This however is not the case for many individuals and families dealing with complex and challenging situations.
Issues around workforce capacity and development
A major concern for CatholicCare is workforce, in terms of the availability of a suitably qualified workforce to meet the demand of the NDIS, but also in regards to the ability to meet their ongoing training needs due to funding constraints. There has been a shortage of staff in the sector for more than 15 years and with the growing demand in both the disability and aged care sectors the challenge to recruit and maintain staffing levels has increased. In addition the NDIA pricing does not encourage people into the sector, with limited to no funds to offer training and professional development opportunities, which in turn limits career progression, it is not an attractive sector to get into or to stay in.
The other issue around the workforce is particularly in regards to specialist workers to support people with psycho-social disabilities. The transition into the NDIS saw the movement of a large portion of skilled and experienced mental health workers away from NDIS funded services. With providers having to significantly reduce wages to come in line with the NDIA pricing, many workers left the sector or changed roles which left people with psycho-social disabilities without familiar and skilled workers to support them. The long term impact of the NDIA pricing is the deskilling of a critical specialist workforce. Support workers are operating even more independently in the field, with less training, support and experience.
There needs to be funds allocated to professional development and training for both disability workers and specialist training around working with people with psycho-social disabilities. These funds need to not only provide training, but assist by subsidising wages for workers to attend, to allow back fill of support shifts which otherwise organisations have to fund or cancel.
Inadequate pricing leading to the risk of market failure
CatholicCare has major concern that the inadequate pricing, particularly in relation to one on one services under the NDIS will lead to market failure. With ongoing costs relating to awards, allowances and the support and supervision requirements for outreach workers, if pricing continues to remain at current levels, organisations like CatholicCare will be unable to provide these essential services to vulnerable people within our community. The expectation that organisations achieve the lean state required by the NDIA price guide has resulted organisations financially subsidising the scheme for the last 4 years. This has been and will continue to be at the expense of other services, clients and future viability, if not addressed. This is unsustainable and will lead to market failure as Boards make decisions to withdraw from NDIS service provision in areas due to the incorrect pricing of services. We have already seen this is the ACT with a number of providers withdrawing from the delivery of one on one services and remaining registered for service lines such as Supported Independent Living. This will result in the inability of people in need to access flexible services and will limit the choice and control participants have to execute their plans. The worst case scenario of market failure is of course the risk of vulnerable people being without essential services.
Issues in regards to quality and safeguards
In a similar vein to those issued mentioned above, the NDIA pricing has had a significant impact on quality and safeguarding practices. Again the NDIA has a requirement for organisations to reduce overheads while at the same time expects that quality assurance systems and safeguarding processes are maintained. In fact the inadequate pricing of one on one supports, in particular, has forced providers to reduce personnel in positons responsible for supervision and oversight of direct support staff, as well as quality assurance duties.
In addition, the requirement for providers to respond to the transition to a national system while at the same time maintain substantial state and/or territory accreditations, places even further administrative costs on organisations which are unsustainable given the NDIA’s pricing.
The overall theme of this submission is that for organisations to maintain a level of quality, to recruit and retain staff, to manage the administrative requirements of the NDIS and to continue to meet the demand for service by participants, the NDIA needs to consider allocating block funds specifically to subsidise the costs associated with providing services under the NDIS.