Submission to Consultation on draft lists of NDIS supports Via email NDISConsultations@dss.gov.au
24 August 2024
Dear consultation team,
The Australian Music Therapy Association (AMTA) welcomes the opportunity to provide our response to the consultation on draft lists of NDIS supports. Music therapy has been included as an evidence-based therapeutic support since the start of the NDIS. Like our allied health colleagues, registered music therapists (RMTs) provide capacity-building supports that improve participants’ function, independence and participation. We look forward to continuing this work.
Music therapy as a specialist support
In Australia, music therapy is delivered by registered music therapists (RMTs). More than listening to or learning music, registered music therapists design and deliver individualised music-based interventions that support physical, social, communicative, sensory, emotional, cognitive and behavioural skills. For NDIS participants, music therapy can significantly impact function and wellbeing and increase independence, socialisation and community participation.
Do you think the draft list of NDIS Supports covers the kinds of disability supports you think should be included?
AMTA is pleased to see that the draft list of NDIS supports describes Early Intervention Supports for Early Childhood as including a mix of therapies and Therapeutic Supports as evidence-based therapy supports to assist a participant to apply their functional skills to improve participation and independence in daily, practical activities in areas such as language and communication, personal care, mobility and movement, interpersonal interactions and community living. We trust that these descriptions ensure music therapy remains a recognised therapeutic support when NDIA delegates are making decisions about funded supports in participants’ plans. Music therapy must be delivered by or under the supervision of a registered music therapist.
An important aim of the NDIS is to maximise participants’ independence and reduce the need for supports over time. As part of music therapy, participants may therefore be prescribed musical instruments or technologies (e.g. music apps) to support their use of music therapy interventions outside of the funded therapy hours. When prescribed by a RMT, musical instruments and music technology are not day-to-day living or lifestyle related expenses. They are therapeutic tools carefully considered reasonable and necessary to address the NDIS goals of the participant, and they are essential for building participants’ capacity to generalise the skills learned in therapy to their homes, schools, workplaces and in the community.
For this reason, AMTA recommends the inclusion of musical instruments and music technology on the funded NDIS supports list. These should be funded only when prescribed by a registered music therapist as part of a participant’s funded therapeutic supports.
Draft lists of NDIS supports – Consultation response Australian Music Therapy Association 1
Are there goods or services on the exclusion list that you think shouldn’t be there?
AMTA is concerned that musical instruments and music production/music technology are listed on the exclusion list and will not be considered NDIS supports. When prescribed by a RMT, musical instruments and music technology are reasonable and necessary therapeutic tools that support participants to achieve their NDIS goals. They are not day-to-day living or lifestyle-related expenses.
AMTA notes that in the exclusion list under Carve outs that may be considered NDIS supports for certain participants that play equipment where it is specialist sensory equipment may be funded if it relates to reasonable and necessary support. We recommend the addition of Musical instruments and musical technology when prescribed by a registered music therapist as therapeutic supports in this category.
Examples:
- For someone with limited upper limb movement, working on fine motor skills to increase independent living (e.g. using knife/fork, driving), the mobile app ‘Thumb Jam’ has been found to be an effective way of building functional upper limb movements[1]
- The neurologic music therapy method ‘Therapeutical Instrument Music Performance’ (TIMP), which can include therapeutic training in piano/electronic keyboard, has been found to improve functional movement in grip strength, finger independence and fine/gross motor for adolescents with Cerebral Palsy[2]
AMTA would also like to highlight the use of musical instruments and technology in music therapy as methods for alternate communication and as assistive equipment with capacity building benefits. These capacity building benefits include increased social connections, communication and self-expression through music, motor skill development, and building skills which can lead to social and community engagement or employment as a musician or in music production.
We note that the Communication and Information Equipment category describes products to assist with alternate communication. The Assistive Equipment for Recreation category describes specialist products used in competitive and non-competitive sports and other recreational pursuits. In each of these categories, there are no specific products or items listed as carve outs that are not NDIS supports. We query why musical instruments and music technologies have been carved out for exclusion when there are clear therapeutic benefits that can be linked to funded supports when these are prescribed by a registered music therapist.
For participants, music therapy does not feel overtly clinical or impairment-focussed, but rather is often experienced as enjoyable, strengths-based, informed by preference and productivity focussed. The specialist musical and creative skills of registered music therapists mean the participant’s functional, independence and participation goals are being achieved while the participant may also be developing greater confidence and feelings of self-efficacy.
___[1] Silveira, T., Tamplin, J., Dorsch, S. & Barlow, A. (2018). Let’s Improvise! iPad-based music therapy with functional electrical stimulation for upper limb stroke rehabilitation. Australian Journal of Music Therapy, 29, pp.1-16
[2] Dogruoz Karatekin B, Icagasioglu A. The effect of therapeutic instrumental music performance method on upper extremity functions in adolescent cerebral palsy. Acta Neurol Belg. 2021 Oct;121(5):1179-1189. doi: 10.1007/s13760-021-01618-0. Epub 2021 Feb 15. PMID: 33590470; PMCID: PMC7883946._
Draft lists of NDIS supports – Consultation response Australian Music Therapy Association 2
Do you have any further feedback or concerns with the draft NDIS support lists?
AMTA acknowledges and welcomes this consultation. We are concerned by the short timeframe given for submissions and suggest that this will impede the consultation team’s ability to gather meaningful feedback from participants and providers on this important issue.
AMTA again reminds the consultation team that music therapy is not a complementary or alternative therapy. Registered music therapists are evidence-based university-qualified NASRHP-regulated allied health professionals. AMTA urges NDIA to ensure staff understand the difference between music therapy and sound therapy, to ensure participants are supported in their choice to access music therapy as a reasonable and necessary support. AMTA continues to hear reports from participants and providers that NDIS staff are providing incorrect information about music therapy’s exclusion from the NDIS.
AMTA notes that in the past, many responses to consultations have remained unheard and unresolved. We have raised our priorities and concerns with Minister Shorten and the NDIA in person and via numerous prior submissions. We trust that this consultation is genuine and hope that any further recommendations for change will be proposed and consulted on before they are presented as final for implementation.
Learn more
Music therapy is an evidence-based allied health profession. AMTA welcomes enquiries about how registered music therapists are uniquely qualified to use music as a therapeutic tool and deliver positive outcomes with NDIS participants. We welcome the team to review our recent publication, Music therapy: disability evidence summary 2024.
We would welcome a discussion to provide more information about how our RMT members support NDIS participants across Australia.
Yours faithfully,
Bridgit Hogan RMT (she/her) Chief Executive Officer Australian Music Therapy Association Inc. E: ceo@austmta.org.au Ph: +61 438 444 439
Draft lists of NDIS supports – Consultation response Australian Music Therapy Association 3