The Child and Family Disability Alliance
Submission to draft lists of NDIS supports
August 2024
The Child and Family Disability Alliance (CAFDA) is a national partnership between three long-standing, independent not-for-profit organisations. Our shared vision is to build the capacity and wellbeing of parents and carers of children with disability through our well-established, robust and proven peer support model.
We provide advocacy, practical guidance, information and support, and help families to connect with one another, to the health system, the NDIS, the education system, to service providers and to services available within the community.
Our aim is to empower parents and caregivers with the knowledge and connections they need to manage the complexities of parenting a child with disability or developmental concerns so families and children thrive.
For more information contact
Karen Dimmock CEO, ACD e: karend@acd.org.au
Carrie Clark CEO, Kiind e: carrie.clark@kiind.com.au
Stacey Touma CEO, Kindred e: stacey@kindred.org.au
Summary
The Child and Family Disability Alliance welcomes the opportunity to provide feedback on the draft lists of NDIS supports. These lists are an opportunity to boost system connection and collaboration to improve the interface between the NDIS and other services, and to embed a child and family lens to ensure the needs of children with disability and their families are included.
Families have raised ongoing concerns about the way the NDIS interacts with other key service systems including education and child protection. These are long-standing challenges that have not been resolved by The Applied Principles and Tables of Support to Determine the Responsibilities of the NDIS and other Service Systems (APTOS). Without careful consideration, the proposed draft lists as they stand will replicate or exacerbate existing challenges.
To ensure NDIS supports result in the best outcomes for children with disability and their families, they need to be principles based, and reflect:
- Age-appropriate autonomy for children and their growing independence throughout childhood.
- The additional care provided by families raising children with disability and the importance of short breaks/respite to support them in their caring role.
- The central role of education in the lives of children.
- The need to support families to implement NDIS plans.
The Child and Family Disability Alliance encourages the Australian Government to ensure these principles are reflected in the lists of NDIS supports to boost outcomes for children with disability and their families.
Examples of specific feedback have been detailed below.
Supports that are ‘NDIS supports’
Assistance to Access and Maintain Employment or higher education
Explicitly cover volunteer opportunities that are not facilitated by education settings. Volunteering and work experience can build skills and confidence and can be important pathways to paid employment and can occur outside of formal work experience in education settings.
Assistance With Travel/Transport Arrangements
Additional clarity should be provided for travel/transport arrangements to remove any confusion. Assistance with travel should include arrangements for children who can’t travel independently to and from mainstream secondary school.
Specialist Positive Behaviour Support
This should include skill building for the child and young person.
Communication And Information Equipment
This should include repair and updates for products and equipment, and training to use (including for parents/carers and support workers as needed).
Customised Prosthetics (includes Orthotics)
To avoid any confusion, this should include maintenance and adjustments.
Daily Personal Activities
This should include ‘age-appropriate’ assistance and/or supervision to ensure it captures the needs of children who need assistance to with daily personal activities.
Development Of Daily Care Skills And Life Skills
This should have flexibility to include age-appropriate skills to live as autonomously as possible.
Early Intervention Supports For Early Childhood
Specifically state ‘evidence-based’ therapies.
Clarification is need on what constitutes a key worker.
Management of Funding for Supports
Clarify whether plan managers will be able to reimburse participants who purchase agreed products directly.
Specialised Driver Training
Include driver training for those with other impairments requiring specialist instruction but who do not used adapted or modified vehicles.
Therapeutic Supports
Amend to include retaining as well as improving participation and independence in daily, practical activities.
Supports that are not ‘NDIS supports’
Day-to-day living costs
Clarify what is included in the carve-outs. Specifically, that additional living costs that are incurrent by a participant solely and directly as a result of their disability support needs should be funded by the NDIS. This includes:
- Home maintenance and repairs for damage or wear and tear – for example, damage to walls or windows.
- Security gates and alarms – for example, internal systems to prevent children from absconding from the home onto busy roads.
Mainstream – Mental Health
Mental health services and supports working in partnership with disability services and supports should be included in the carve outs. For example, in circumstances where mental health and disability related needs are connected and require cross-sector collaboration.
Mainstream – Child Protection and Family Support
This should be separated into two lists to keep Child Protection and Family Support separate.
Out of school hours care and vacation care, excluding respite – make it clear that while NDIS funds can’t be used to pay for an outside school hours care provider, families can use Support Worker funding during school holidays and before and after school. Additional clarity is needed for disability specific camps and school holiday activities delivered by services that do not receive the Child Care Subsidy.
Mainstream – Early Childhood Development
Explicitly state that NDIS funded therapists can meet with educators and teachers to discuss the child’s disability support needs in the education setting.
Mainstream – School Education
Explicitly state that NDIS funded therapists can meet with educators and teachers to discuss the child’s disability support needs in the education setting.
What’s missing
Respite or short breaks
Respite should be included under ‘Supports that are “NDIS supports”’. It should give particular consideration to respite needs of families raising children, including carers of children with disability in out-of-home care.
Support Coordination
Support Coordination is critical for helping families implement their NDIS plan. It is needed for families who fall below the threshold of specialist support coordination. This includes families with low literacy, who have multiple children who are participants, and families involved with child and family services. Support Coordination should be included for these families.