Received 2/11/18 022

Life Without Barriers

Mental Health

Services and the

NDIS

Submission to the Parliament of South Australia Social Development Committee

Opening Remarks

Thank you for the opportunity to provide a submission to the Social Development Committee on our experience – and those of our clients – of the impact on mental health services by the transition to the NDIS.

In our view, the transition has for the most part led to greater choice and control for people with a disability, and provided greater opportunities for people to maximise their capabilities, participation in the community and to live the lives they choose. However, some unintended gaps in service provision have been experienced, particularly for those receiving mental health support services.

Who We Are

LWB is a leading social purpose organisation working in more than 440 communities across urban, rural and remote Australia. Our services currently support over 14,000 people living in their own homes or in residential houses that we manage. We support children, young people and families, people with disability, older people and people with mental illness. We work with people who are homeless and refugees and asylum seekers.

LWB has been active in South Australia since 2002 years and we offer mental health services to over 800 individuals and families throughout the state. These include psychosocial rehabilitation services delivered to people in their own home, alcohol and other drug counselling and the Partners in Recovery program which connects support programs and services to provide the best fit for the needs of individual clients. LWB offers services across the state including in Adelaide, Victor Harbor, Mount Gambier, Berri, and Whyalla.

Our Submission

In this submission we will address each of the items identified by the Committee as relevant to the discussion around Mental Health Services and the NDIS. As the Committee is likely to receive many submissions to this inquiry, we have elected to keep ours succinct and with a clear focus on the experiences of our clients and opportunities for improvement in the sector.

We are, however, more than happy to discuss this submission further, and look forward to additional opportunities to partner with the Parliament of South Australia and the broader sector to help improve outcomes for South Australians living with a mental illness, regardless of whether they are eligible to join the NDIS.

1. The gap between the Federal Government’s predicted and realised percentages of mental health clients receiving NDIS support

In South Australia, LWB supports around 800 mental health clients – of the 124 who have received a decision in relation to an NDIS access request. Of these:

61 have been deemed ineligible (14 of whom are currently appealing or re-submitting)
56 have been deemed eligible and are waiting for a plan, and
10 have been deemed eligible and have received a plan.

While a small sample size, this hints at a discrepancy between the Federal Government’s predicted percentage of mental health clients receiving access to the NDIS and what the people we support have experienced to date. This discrepancy is twofold:

About 8% of our overall mental health clients in SA have been deemed eligible for the NDIS, lower than the figure of 13.9% predicted by the NDIA, and
At the time of writing, less than 2% of our clients accessing mental health services and less than 20% who have been deemed eligible for the NDIS have received a plan, despite the anticipated NDIS roll-out schedule.

The remainder of our submission will explore in detail the implications of these figures for our clients, and their possible impact on people accessing mental health services in South Australia.

2. The reduction in funding to the Personal Helpers and Mentors program and Mental Health Respite Carer Support program and the impact this will have on people with mental illness

In our experience, the reduction in funding to these programs has not corresponded with the actual roll-out timeframes of the NDIS in South Australia. In particular, 90% of LWB’s Personal Helpers and Mentors (PHaMS) and Mental Health Respite Carer Support (MHRCS) clients are yet to transition to the NDIS. The reduction in funding to PHaMS in particular has required a pause on intake of new clients, which has resulted in a vulnerable group of people being caught in a service gap as the NDIS has not yet counterbalanced the reduction in availability of these services as was initially anticipated.

An example of the impact of this on people accessing mental health services can be found in LWB’s Partners in Recovery (PIR) program, which supports people living with a mental illness by finding and connecting support programs and services. Due to the pause on accepting new clients, PIR is no longer able to refer clients to local PHaMS services, which have historically been an important component of the support offered as part of the program.

As there remains uncertainty around the continued support for PHaMS and MHRCS services, LWB’s has by necessity shifted towards working with clients who are more likely to be eligible for NDIS funding. This leaves a gap for clients who are ineligible for the NDIS but still require ongoing psychosocial support due to their mental illness. Unsurprisingly, people unable to access a service are more likely to experience a number of concerning outcomes, including increased psychological distress and hospital presentations.

It is clear from our experience that many people will still require psychosocial supports even if they are unlikely to be eligible for NDIS funding. In our view this is something that should be addressed urgently by the South Australian Government.

3. The ongoing requirements for block funded mental health services provided by the State Government after the NDIS transition

Of LWB’s existing PHaMS and Mental Health Carer Support clients who have applied for an NDIS plan, very few whose primary disability is a psychosocial disability have been approved. In our experience, there is a clear need for these services to continue to provide support for people with a mental illness regardless of their eligibility for the NDIS. The method of procurement of these services is ultimately a matter for the SA government. LWB has experience delivering services in both block funded and consumer directed packages.

Additionally, some clients face barriers due to the rigorous process required to access services under the NDIS, which includes the need for a diagnosis and evidence that other treatment options have been tested. The process can be particularly challenging for people with complex needs in addition to their psychosocial disability – such as those who are homeless, have alcohol or other drug dependencies or present with challenging behaviours – as their circumstances can make it difficult or impossible to attend the appointments necessary to obtain meet these requirements.

There have also been occasions where the NDIA has rejected an access request on the grounds that an individual has not pursued all treatment options. In some instances, these can include more intensive procedures such as electroconvulsive therapy, which may only be effective in certain cases and is not always desirable to people with a mental illness.

In our view, this speaks to an opportunity for the sector to assist in the improvement of knowledge and understanding of the complex factors often associated with psychosocial disability among NDIA assessors and planners. We will continue to seek opportunities to partner with the NDIA and would welcome any South Australian initiatives to facilitate this process.

More broadly, the nature of individualised funding can itself provide challenges for people with complex needs, as they often require a level of flexibility in service provision that is not possible under the NDIS pricing guide.

For example, LWB is working with a client with an acquired brain injury and a mental illness who exhibits some challenging behaviours. They had been approved for an NDIS plan and were receiving support coordination from a government agency, however, this service was stopped on

the grounds that the client was abusive toward agency staff. Unfortunately, as they were unable to manage it themselves and no alternative support coordination funding was available, the lack of this service led to the client’s package not being used. This further led to them being unable to meet the conditions of their tenancy, which has resulted in the client becoming homeless.

In our view, such situations need to be taken into account when considering the ongoing requirement for services after the NDIS transition. In particular, individuals with mental health issues severe enough to qualify for NDIS funding are perhaps more likely to require access to more flexible and responsive coordination and support, especially where one or more additional complex needs are present. This represents another opportunity for the South Australian Government to facilitate discussions with or advocate to the NDIA on behalf of such clients.

4. The effects on South Australians with mental health issues who are deemed ineligible to receive NDIS funding

LWB understands that the NDIS is not intended to cover all people with a mental illness, and that some people who are functionally impaired by their mental illness are not so significantly impaired that they are eligible for the NDIS. While this ensures the future sustainability of the NDIS, people in such circumstances may still require psychosocial support services of some variety, and there remains a need for services so as to ensure vulnerable people are able to access the help and support they need.

To this end, Continuity of Support (CoS) funding is intended for individuals who are currently receiving support for their mental illness but will not be eligible for access to the NDIS. However, at this stage, to receive CoS funding it is expected that people first submit an NDIS access request to confirm their ineligibility. This requires a significant amount of paperwork and other activities despite the limited prospect of success. Additionally, whether expected or not, rejection of an access request can be distressing for a person with a mental illness.

Compounding this, there remains a lack of clarity around what support will be provided to those deemed eligible for CoS funding after the current period expires in June 2019, creating instability and uncertainty for individuals and their families.

These effects are not, in our understanding, an intended consequence of the transition to the NDIS. It is our view that a review of the process for obtaining CoS funding be reviewed, and that certainty around continuity of CoS funding beyond June 2019 be provided as soon as possible.

5. The sufficiency of services provided to people with mental illness who are accepted into the NDIS

Once accepted into the NDIS, we have found that the majority of LWB clients have received access to the services they require. However, individuals can face barriers to utilising some items in their plan if they live in regional or remote areas where service providers may not be nearby.

It is also important to note that there is a fundamental conceptual difference between the kinds of services funded by the NDIS and the recovery-focussed approach which forms the basis of most psychosocial mental health services. While the underpinning philosophy of the NDIS is to maximise individual capacity, this is in the context of a lifelong disability – there is no expectation that individuals will ‘recover’ from physical, intellectual or developmental disabilities. This is in contrast to prevailing mental health service models that work with individuals toward the achievement of recovery goals.

An increased focus on the provision of recovery-focussed mental health models may be beneficial for some South Australians with a mental illness who are accepted into the NDIS.

6. The effects on South Australians with mental health issues undertaking the application process for the NDIS

In our experience, in addition to the CoS issues mentioned in Section 4 of our submission, there are several unintended effects on South Australians with mental health issues applying for access to the NDIS.

For example, many people with a mental illness may not have capacity to find the evidence – and particularly up-to-date evidence – required to submit an access request without the assistance of a provider. While the intention is that this assistance is provided by a Local Area Coordinator, in our experience this has not been the case due to the level of demand on these services which have only recently commenced in South Australia and are still establishing themselves. This often leads applicants to General Practitioners, who for the most part are not familiar with the specific requirements of the NDIS, which can hinder or delay completion of the diagnosis and functional assessments required to request access.

For people in regional areas, it can be very difficult to access the kinds of assessments undertaken by general practitioners and psychiatrists that are required to be submitted with an NDIS access request. In some cases, medical practitioners are also unwilling to complete the forms that are required as evidence to accompany an NDIS access request.

Additionally, where assessments are required from non-Medicare billing practitioners such as private occupational therapists, significant out-of-pocket costs – often in the thousands of dollars – are incurred. These costs are prohibitive or financially onerous for many requiring access to the NDIS.

If a person has not received a diagnosis or undertaken the functional assessments required for their access request, the application process can take a provider months to complete, often equating to a week of full-time effort from a single staff member. Even when an individual has already received a diagnosis and undertaken the required assessments it can still take providers several weeks to complete the process, or roughly to 2-3 days of full-time work. This is largely due to the onerous nature of the application process with the NDIA.

The time taken by the NDIA to assess an access request is also longer than the 21 days stipulated in the Act – in our experience, assessment in the majority of cases takes 2-3 months. Further, if the request is successful, it regularly takes 6-8 months from submission to the receipt of a plan.

While we are unable to comment on the specifics of NDIA resourcing and capacity, it is our view that more could be done to increase the skillset of application assessors, particularly when it comes to access requests for people with a psychosocial disability. Attention should also be directed to streamlining application processes so as to reduce the time and resource commitments involved in access requests and plan delivery, and LWB would be pleased to partner with the NDIA and the sector to help achieve this.

7. Any other relevant matters

Conclusion

In conclusion, we would like to thank the Committee for the opportunity to contribute to this important conversation around the impact of the transition to the NDIS on people accessing mental health services in South Australia. As our submission suggests, we believe the NDIS to be a largely positive development for all living with a disability Australia, however, our experience is that some unintended service gaps and other issues have arisen for people requiring mental health support.

In particular, the circumstances of people with psychosocial disabilities and additional complex needs – such as those who are homeless, have alcohol or other drug dependencies or present with challenging behaviours – require further consideration. People in such situations are more likely to find the rigorous application process and obtaining the levels of evidence required distressing or prohibitive. They may also require additional support to ensure that they are able to access and use the services that form part of their package if they are eligible for the NDIS

Consideration should also be given to continued support for non-NDIS mental health services. As mentioned in this submission, there is a distinct conceptual difference between recovery-based mental health models and the philosophy behind the NDIS – there will also remain a need in the community for mental health services for people whose psychosocial disability is not so severe that they become eligible for the NDIS. Related to this is a need to reconsider the requirements for receiving Continuity of Service funding, and to make clear the provisions for this funding beyond the current end period of June 2019.

There is an opportunity to increase the skills, knowledge and capacity of NDIA assessment and planning staff in working with people with a psychosocial disability and other complex needs. This activity should in turn attempt to streamline the various application processes so as to reduce the current gap between submission of an access request and the delivery of a plan. The South Australian Government may have a facilitation or advocacy role to play in this, and LWB would welcome any such initiative.

LWB would be pleased to contribute in any appropriate fashion to the above activities and to any other initiatives that help achieve the vision shared with the SA Government for people living with a mental illness to receive the support required to overcome barriers to participation and live the lives they choose.

Kind Regards,

Sue Thomas

State Director South Australia