5 July 2019
Ms Robyn Schutte
Secretary
Social Development Committee
Parliament of South Australia
sdc@parliament.sa.gov.au
Dear Ms Schutte,
Re. Mental Health Services and the NDIS
Thank you for the opportunity to make comment regarding the Social Development Committee’s considerations around Mental Health Services and the NDIS.
Skylight Mental Health provides community mental health services across South Australia, including metropolitan, rural and remote areas with a mix of state, federal and community funding.
Currently, we provide direct services and supports to approximately 1,500 people per annum, and to another approximately 500-1,000 through Carer Supports, community engagement, information sessions and workshops. At present, more than 250 of that cohort are people with NDIS plans.
Because of our service provision and delivery, we have significant experience in:
- Delivering NDIS information sessions to people considering an NDIS application or testing their eligibility.
- Assisting people to apply for the NDIS.
- Assisting people with the NDIS planning process.
- Assisting people with the NDIS appeal (review) and re-application processes.
- Assisting people to implement their plans.
- Providing a range of NDIS services, including Core Supports, Capacity Building, Therapies, Activities, Short Breaks, Plan Management and Support Coordination to a wide range of participants and families.
We deliver this suite of services with a 35-year background in the provision of a range of recovery-focused and person-centred services for people with a severe experience of mental illness.
- The gap between the Federal Government’s predicted and realised percentages of mental health clients receiving NDIS payments
There is a poor level of understanding currently around a number of issues, including:
a. A person may gain ‘Access’ to the NDIS but still might not be eligible for a plan. Furthermore, they may have to wait many months for a planning meeting. The NDIS
provides no services during this interim period. In its calculations, SA Health appears to have combined incorrectly the number of people with a plan with those granted access, and identified that all are receiving NDIS supports.
b. Of the people with NDIS plans, the majority of these plans do NOT appear to meet the needs (and often the choices) of people with a psychosocial disability. This appears to be the case Australia-wide.
c. While some people were found eligible and have received supports under the NDIS, a number of these still require other psychosocial supports because their NDIS plans are not appropriate to their needs, even when there is adequate funding in the plan. In essence, plans are frequently so narrow and rigid that provision of a person’s necessary, and preferred, psychosocial supports is not possible.
d. The model of the NDIS application process forces many people to apply and re-apply for Access multiple times. In addition, there is a need to seek reviews as well as appeal decisions regarding Plans. These processes are tortuous, time-consuming and demoralising – for consumers and workers alike. Further, consumers need high levels of support to negotiate these processes, even when plans are in place. The NDIS does not provide these supports, and there are no services or supports to meet this need other than existing funded mental health NGO’s.
e. Estimates suggest that 800,000 people in Australia have a severe mental illness with around 295,000 of those requiring significant, and frequent, mental health support in the community. Approximately 65,000 of that larger group are likely to gain access to the NDIS. Assuming that South Australia has 8% of the national population, these figures transfer to this state as (approximately) 64,000 in total, 23,600 requiring services, and 5,120 eligible for the NDIS. Therefore, it is no surprise that when people have moved into the NDIS from a State-funded service, new referrals have filled those vacancies immediately. The vast majority of those services can ONLY accept referrals from the SA Government’s own mental health services.
All of this suggests that the State’s view of the percentage is optimistic and not overly useful. It is important to ensure that the NDIS provides plans to those who are eligible, and that the plans provided are appropriate to the needs and choices of those who are eligible. However, it is not sensible to assume that resources can transfer directly. This is because people move from one service system to another when the service is not delivering on its promise. Even if it were, it would not meet the needs of most people with a mental illness.
- 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.
Skylight was previously the largest provider of the federally funded Personal Helpers and Mentors (PHaMs) and Day-to-Day Living (D2DL) services in SA. What funding remains for those two services is now channelled through the State’s two Primary Health Networks (PHN’s).
In many ways, the issues above have already occurred in the PHaMs/D2DL transition and it is clear that a significant number of consumers across Australia have been negatively impacted through the transition period. Despite this, federal funds for these programs are still focussed on transition rather than needed supports, such that services are forced into trying to engage with people to prepare paperwork, evidence, applications, appeals, etc. rather than providing services and supports around recovery, wellbeing and community engagement.
The new federal National Psychosocial Support Measure (NPSM) and Continuity of Support (CoS) are intended to deal with the group of people who may be new to the mental health system, still applying for the NDIS or ineligible for the NDIS. For people still in need, the funding provision appears to be woefully inadequate just for the group of people who are transitioning from PHaMs or D2DL but not eligible for the NDIS, let alone any new/re entries to the system.
The reality is that group of former PHaMs / D2DL consumers, or people who would have been eligible for those service types, will increasingly seek services from the SA Health system because the replacements to the previous federal programs appear to be less valuable on current evidence.
Separately, the Mental Health Respite Carer Support (MHR:CS) contracts have been extended until November 2019. The Integrated Carer Support Service (ICSS), which is designed to replace the MHR:CS will not be announced until at least July or August 2019, and will have significantly less funds than the current MHR:CS system. It would be sensible to suggest that the short transition timeframe from one service model and provider to a different service model and provider will be inadequate and likely to create chaos for carers especially when we acknowledge that the services will not be the same and the funding will be less.
- The ongoing requirements for block funded mental health services provided by the State Government after the NDIS transition.
The approximate SA figures suggested in Point 1, i.e. 64,000 people with severe mental illness in total, with 23,600 requiring services, and only 5,120 being eligible for the NDIS suggests that around 18,500 people will require services from somewhere other than the NDIS. At this stage, with recent cuts, the number of people being serviced may be as low as 1,500, or less than 10% of the identified need.
This is the similar in other states and apparently, NSW, Qld and NT have all sought to expand their State mental health funding contribution for community-based services to deal with the gaps exposed by the NDIS transition.
This is not to say that all of this group will require the same high level of services of many who receive (for example, Individual Psychosocial Rehabilitation Support Services (IPRSS) on a continuous basis) but some certainly will. Some will require it for substantial periods and others for shorter periods. More again will need community-based stepping-up/down services, short-term residential/training services, crisis response services, group/activity based therapeutic or skills building services, etc.
These numbers are uncertain, but given the manner in which recent vacancies have been filling we must assume the need is far greater than the current funds allow.
- The effects on South Australians with mental health issues who are deemed ineligible to receive NDIS funding.
As indicated in the points earlier in this submission, it is very clear that the larger number of people with a mental illness who require services in SA, that is around 78%, will not be eligible for the NDIS. This sits alongside a reduction in funding over the last several years in real terms, and a more drastic reduction of 25% in this current financial year.
The reality for many people is that they are only able to access mental health services when they are in absolute crisis and often only after family breakdown and several appearances in GP surgeries, Emergency Departments and general community services and when they have had contact with emergency services. There is no doubt that the shrinking resources will increase this likelihood for more people. It is hard to imagine a more destructive way to determine access to services, let alone a more costly one.
In mental health, like most areas of health, prevention is better than cure, and while we may not be able to prevent a mental illness, what we do know of NGO community mental health services is that they go a long way to maintaining wellness for people and preventing a need for higher level clinical or hospital services. This has been demonstrated in reviews of the IPRSS and PHaMs systems as well as on the Intensive Home Based Support Service (IHBSS) and GP Access service.
In addition, a separate issue is emerging of people who are essentially exhausted and traumatised by the application/ planning/review/appeal process when trying to access the NDIS. Certainly, Skylight is encountering a growing number of people who believe the NDIS model is inappropriate in its philosophy of disability rather than recovery and its Access and Planning approaches are so complex as to be traumatising for them.
- The sufficiency of services provided to people with mental illness who are accepted into the NDIS.
Mental Health services such as Skylight have consistently argued that while the NDIS funding model is appropriate for a number of people with a psychosocial disability the planning and service models are often not so.
Psychosocial disability NDIS plans can often be quite well funded, but:
- Are typically narrow in terms of what is allowed;
- Are typically focussed on core supports rather than ongoing capacity maintenance which maintains wellness rather than reducing needs;
- Usually limit, or deny, what are often the most useful tools to assist, that is case management and support coordination;
- Assume that support types are separate and best delivered by different people at different pay rates when the reality is quite the opposite;
- Assume that supports are best provided by quite lowly qualified and paid staff despite the acknowledgement of federal, state and territory funders that a Certificate 4 in Mental Health (or similar) is a minimum skill set, and requires an appropriate pay rate;
- Ignore the need to shift service focus toward a crisis response quickly depending on changing needs;
- Ignore the overlap between disability and health where the combination of the two is ignored as being the responsibility of the health system;
- Ignore the issues and costs around transport and travel which are frequently integral parts of a high level engagement with people and not just a quasi taxi service;
- Ignore the need for such things a medication depot assistance which is vital for many people’s wellness, but would rarely be a choice for people to use support hours for; and
- Ignore the need to spend significantly considerable amounts of time, frequently, in relationship building and rebuilding to create and maintain trust with a worker.
In essence, plans often seem to be lacking and are generally inconsistent, even when the best information has been provided. Unfortunately, the review and appeal processes are often so delayed and distressing that people choose to accept poor plans rather than challenge them.
- The effects on South Australians with mental health issues undertaking the application process for the NDIS.
Points 1, 2, 4 and 5 in this submission make clear that the NDIS process is difficult enough for workers to manage and feedback from carers and consumers indicates an enormous degree of anxiety, frustration, and distress from the interactions with the whole NDIS system.
Many may well be pleased with the outcome, especially if they were transitioned automatically from the general disability sector with no significant service changes.
However, this has not been the case for most people with a mental illness. That group have not transitioned automatically so have had to undertake the whole process with many refused
access or had inconsistent demands for additional evidence. Many people have had to make multiple applications with apparently no real clarity about why access had been denied. Numerous people that we would consider likely to be eligible have refused to apply or re-apply because of their or their peers’ previous experience with the process.
It is clear that only a relatively small number of people with a mental illness in SA will be eligible for the NDIS, so the process of forcing all of those in existing state or federally funded programs to apply, whilst also acknowledging that most of them are unlikely to be eligible is wasteful of resources and quite inhumane.
- Any other relevant matters.
The NDIS remains a positive option for some people with a mental illness, but it is unfortunate that it has been seen as the solution to all of the ills in the mental health sector. After some years of transition, it is still clear that there is a mismatch between the needs of people with a mental illness and the processes and service models available under the NDIS.
The consequences of this mismatch are generally listed earlier in the submission, but lead to:
- A high level of current unmet need in SA funded services;
- A perception that less state funding is needed if some people transition;
- A likely increase in crisis usage of Emergency Departments and Police and Ambulance services;
- Increased distress amongst consumers and carers in the sector;
- Increased financial distress in NGOs who provide high quality services in the sector;
- Decreased capacity of service providers to respond to changing needs for individuals and groups of people with a mental illness; and
- A loss of trained and skilled workers to the mental health system as the poorer funding and uncertainty in the sector becomes even more established.
None of this is to say that the NDIS should not engage with people with a mental illness. Clearly, the model can and does work for some people.
However, it is equally clear that the model is not intended to suit the majority of people with a mental illness and that the combined modelling of the NDIS with the current funded output from SA Health are well below the actual need in the community.
The argument then is that funding should be increased significantly in the sector, or at the very least, not reduced or ‘transferred’ at this stage.
Paul Creedon
CEO – Skylight Mental Health