Received 29/10/18 009
Government of South Australia
SA Mental Health Commission
Ground Floor Unit 6
60 Hindmarsh Square
ADELAIDE SA 5000
PO Box 189
Rundle Mall
The Secretary ADELAIDE SA 5000
Social Development Committee
GPO Box 572 Tel: 1300 293 220
www.samentalhealthcommission.com.au
Email: sdc@parliament.sa.gov.au ABN 55 213 814 044
South Australian Mental Health Commission submission into the provision of services for people with mental illness under the transition to the National Disability Insurance Scheme (NDIS)
Dear Committee Secretary
Thank you for your invitation published in The Advertiser asking for submissions to the Social Development Committee inquiry into the provision of services for people with mental illness under the transition to the National Disability Insurance Scheme (NDIS).
Please find attached a submission from the South Australian Mental Health Commission. There is no confidential material presented.
Should you require clarification, or would like to discuss this submission in further detail, please contact Ms Amelia Traino, Executive Director, SAMHC at amelia.traino3@sa.gov.au or on 8463 6148.
Yours sincerely
CHRIS BURNS CSC
Commissioner
SA Mental Health Commission
25/10/2018
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Executive Summary
- The gap between the Federal Government’s predicted and realised percentages of mental health clients receiving NDIS support;
- 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;
- The ongoing requirements for block funded mental health services provided by the State Government after the NDIS transition;
- The effects on South Australians with mental health issues who are deemed ineligible to receive NDIS funding;
- The sufficiency of services provided to people with mental illness who are accepted into the NDIS;
- The effects on South Australians with mental health issues undertaking the application process for the NDIS;
- Any other relevant matters.
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The South Australian Mental Health Commission (the Commission) welcomes the opportunity to make a submission to the inquiry into Mental Health Services and the NDIS by the Social Development Committee, Parliament of South Australia.
The Commission was established in October 2015 with the key task of leading the development of a mental health strategic plan for the state. The role of the Commission is to engage with the mental health sector and the community to strengthen the mental health and wellbeing of South Australians. The Commission promotes and facilitates the sharing of knowledge about mental health and wellbeing and provides leadership in developing or co-developing proposals and projects related to the State’s mental health and wellbeing.
The Commission considers the NDIS to be an important national initiative and supports the key premises of individualised support and choice for people with a disability.
In 2017 the Commission consulted widely with the South Australian community in developing the South Australian Mental Health Strategic Plan 2017 — 2022 (the Plan). The Commission listened to a broad and diverse range of individuals, organisations and groups from across South Australia. Over 2200 South Australians engaged in conversations with the Commission in the development of the Plan. Many people spoke to us of their lived experience and what has and is helping them to engage in their recovery journey and we heard from many family members and people working in the mental health system. A significant concern of many people was the advent of the NDIS and the fear that the services currently helping people to become and remain well would not be available to them in the future.
The Productivity Commission (PC) estimated the number of participants in the NDIS at full Scheme (2019-20) with a significant and enduring primary psychosocial disability will be 64,000 (13.9%). This projection focuses on people with a primary psychosocial disability. The total population of people with a severe mental illness is estimated to be much larger — up to 600,000 people (2 — 3% of the population in Australia). This may result in more than 64,000 being eligible for the NDIS. The PC NDIS Cost Report¹ notes the uncertainty around the number of participants with psychosocial disability at full scheme.
The National Mental Health Services Planning Framework has been used to model the number of people with severe and complex psychosocial disorders aged between 18 — 64 years who would closely align with the NDIS criteria with that estimate being 92,000 people. Mental Health Australia also commissioned work around modelling for how many people in Australia would need individualised intensive NDIS-like community support in a 12 month period and their estimate was approximately 289,000 in a 12 month period. The Commission is concerned that people requiring the support of the NDIS will not be able to access it and will experience their mental health and wellbeing will be adversely impacted.
¹ Productivity Commission, NDIS Costs Study Report, October 2017, https://www.pc.gov.au/inquiries/completed/ndis-costs/report/ndis-costs.pdf
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There is no direct provision of respite support for carers through the NDIS. Programs which currently support carers such as the Carer Respite Program (Commonwealth funded) and state-based funding currently supporting carers are likely to not exist after the full implementation of NDIS. Carers from across SA spoke to us about their concerns about how they will access the support they need in order to continue to support their family members and loved ones once the NDIS is fully implemented and these programs no longer exist.
Partners in Recovery (PIR) and the Personal Helpers and Mentors Program (PHAMs) was mentioned to the Commission many times during our community conversations as it was known at that time that the funding for these programs would be rolled into the NDIS funding. The criteria for these programs are vastly different to the criteria for the NDIS and there was widespread concern from the community that people currently receiving a service from PIR or PHAMs would not have support after the funding transitioned to the NDIS.
People currently receiving services through the Individual Psychosocial Rehabilitation and Support Service (IPRSS) and the Housing and Accommodation Support Partnership (HASP) Program do not all meet the criteria for the NDIS. These programs which have been evaluated and determined to be extremely effective in assisting people to learn or relearn skills, engage in the community, maintain their tenancy and reduce hospital admissions are essential parts of the mental health service landscape in SA. HASP and IPRSS are part of the stepped system of care in SA and the NDIS is not able to replicate these programs.
The Commission would like to express concern about the funding of HASP going to the NDIS. The business models used to build the funding for HASP are predicated on a provider having a significant number of HASP places to support, in order to build capacity within the provider. This is never more true than with Burnside HASP. This community managed provider contracted to this subprogram provides 20 people who live in their own houses forming a square facing onto four streets with 24/7 rehabilitation and support. Should this funding be rolled into the NDIS it is possible that the people living in HASP accommodation will choose different providers — those providers will be unable to provide the same level of onsite rehabilitation and support provided by the current provider. This difficulty has been recognised by the Ministry for Health in NSW who is keeping the funding to the Housing and Accommodation Support Initiative (HASI) program (built using similar concepts and business models as HASP) separate to the NDIS. The Commission is concerned that the significant levels of rehabilitation and support built into the business models of HASP to enable people to move out of hospital into the community will dissipate should this funding be moved to the NDIS.
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The Commission is very concerned that people will fall through the gaps if they are not accepted to the NDIS or are accepted but have minimal support and there are no or limited state funded programs to assist them. People with a lived experience of mental illness, their families and carers, clinical and non clinical staff have all expressed their concern about how people who currently receive support will be supported into the future if they don’t receive NDIS support.
The Commission is concerned about the potential negative effect it will have on individuals, their families and the mental health and wider health system.
The Commission has concerns about the expertise of the staff providing services to people with a psychosocial disability under the NDIS given the pricing structure. The community managed sector in SA has spent over 15 years in developing and building the capacity of their workforce. SA is fortunate to have a robust and skilled mental health vocationally qualified workforce. Currently the community managed sector in South Australia are required through their contracting arrangements to use the Certificate 4 in Mental Health or Peer Work as the standard qualification for vocationally qualified staff working with people with mental illness.
The NDIS designates the lesser and more generic qualification of a Certificate 2 or 3 as the minimum qualification for vocationally qualified workers. NDIS services are unlikely to pay Certificate 4 qualified staff what they are currently paid. Given the differences in the staffing between what is currently available and what is likely to be available under the NDIS, the Commission is concerned that the expertise will not be retained in the sector after the advent of the NDIS.
The Commission is aware of many skilled workers who have moved out of the mental health arena altogether due to the advent of the NDIS and its lower pricing structures.
As at 31 March 2018 (COAG Disability Reform Council NDIS Quarterly Report, 31 March 2019) there were 151,970 participants with an approved plan. Of the total number of active participants across Australia with an approved plan, 7% were for participants with a psychosocial disability and only 1% of plans in SA were for people with a psychosocial disability. At full scheme implementation it is expected that 13.9% of NDIS participants will be people with a significant and enduring primary psychosocial disability. Consequently in SA it is relatively unknown how the application process affects South Australians with mental health issues undertaking the application process for the NDIS.
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Based on reports of people in other states undertaking the application process and progress in SA over the last 7 months, the Commission has the following concerns about participants undertaking the application process:
- Having to establish “likely permanence” of their disability being at odds with a recovery approach
- The amount of time it takes to gather all the information required and who is available to assist potential participants through the application process.
- Concerns about participants having to re-tell their story multiple times
- Concerns about lengthy telephone interviews being used for planning meetings
- Concerns about planner understanding and knowledge of the needs of people with psychosocial disability
- Waiting times and delays for receiving access to funding
Approach
There is a significant difference in the approach of the NDIS and current psychosocial rehabilitation services in SA. The NDIS necessarily takes a disability approach which is reflected in the criteria for the NDIS which states:
“they have a disability that is likely to be permanent (psychosocial disability) and without support they have a substantially reduced capacity to take part in the activities of daily living and effectively participate in society and they are likely to require support from the NDIS over their lifetime”.
This is quite different from the recovery approach used by mental health services which advocates for people to be recognised as having unique capabilities to heal, learn, develop and grow with regard to their own experience of building, sustaining and maintaining mental health and wellbeing.
People have expressed concern to the Commission about not wanting to label themselves or their family member with a permanent or likely to be permanent disability given the episodic nature of mental illness. This leads to the Commission being concerned that some people who need help to become and stay mentally well may not engage with the NDIS and receive the support they need.
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South Australian service planning
South Australia provides a difficult proposition for service planning due to its 980,000 square km area being sparsely populated outside of the greater Adelaide region. Its biggest town after Adelaide is Mount Gambier with approximately 26,000 people and there are few towns located close enough to “hub and spoke” services out from.
SA Health has found it difficult to build sufficient capacity for community managed organisations to be able to “set up shop” to provide non clinical mental health services in rural areas, but has managed to do so through using multiple programs overlaying each other. Should community managed organisations not be able to maintain a ‘critical mass’ as achieved through block funding in rural and regional locations they may be forced to withdraw their services.
With the NDIS not providing block funding the Commission believes there is a risk of services not being available in rural and remote South Australia, thus disadvantaging those South Australians living in the country.
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