Submission to: NDIS Provider and Worker Registration Taskforce Via webform
5 May 2024
How do you currently engage with the NDIS?
The Australian Music Therapy Association (AMTA) is the peak body for music therapy in Australia; representing registered music therapists (RMTs) and advocating for access to music therapy. Our mission is to enable, advance and advocate for excellence in music therapy. Music therapy is an evidence-based practice and allied health profession. In Australia music therapy is delivered by RMTs.
AMTA regulates the field of music therapy by registering music therapists, accrediting music therapy courses, and upholding professional standards and ethics. As a member of Allied Health Professions Australia (AHPA) and the National Alliance for Self-Regulating Health Professions (NASRHP), AMTA supports RMTs in using evidence-based practices to promote the health, wellbeing, and functioning of Australians and ensures that RMTs are appropriately qualified, skilled, and meet national regulatory requirements.
There are currently nearly 800 music therapists registered with the AMTA working across a variety of sectors including health, disability, aged care, education and mental health.
In the NDIS, registered music therapists design and deliver individualised music therapy programs that are evidenced to significantly impact mood/emotional regulation, cognition, behaviour, communication, sensory regulation and mobility, and increase independence, socialisation, community and economic participation.
What do you think about the proposed levels of registration and enrolment in the report?
AMTA welcomes a change to the current registration requirements and supports improved safeguarding for NDIS participants.
AMTA firmly believes businesses providing supports to NDIS participants should be registered as a provider in some way to enable the NDIA to extract more data on service use, including to see the volume of supports available for people with disability, to track
AMTA SUBMISSION: NDIS Provider and Worker Registration Taskforce
participant use of services, and to ensure a safe, equitable and fair system of practice. We support the requirement for all persons providing support to NDIS participants to hold a NDIS Worker Screening Clearance.
AMTA strongly asserts that any changes need to uphold participants’ right to choice and control of their services and ensure an accessible registration process for providers.
Current registration processes place excessive burdens on providers
Current registration processes place excessive administrative burdens on providers. Many RMTs find the current registration requirements prohibitive; reporting the cost of compliance (i.e. external audit fees) to be too high, and the compliance with required practice standards to be administratively onerous for their small business size. Many RMTs are therefore working in the NDIS as unregistered providers supporting self and plan managed participants only.
Our members cite costs of registration starting from $1,000+ for verification, and certification costs ranging from $8,000-20,000+. Many of our members have decided to undertake verification audit only, due to these significant costs to what are often sole practitioner or small practices. These costs are in addition to our members’ professional registrations, and quality safeguards including supervision and continuing professional development, insurances and business running costs. Members also cite lengthy waits for audits to be processed, with repeating registrants citing delays of 5-7 months.
Data from AMTA’s 2024 Workforce Survey shows that 78% of RMTs who provide NDIS supports are sole practitioners. 25% of RMTs providing NDIS supports are registered providers; however, 77% of RMTs reported that they intend to abandon their NDIS registration in the future (i.e. 154 RMTs).
Our concerns with the proposed model
Registration Pathways:
The proposed levels of registration do not clarify how allied health professionals will be classified in terms of risk, or how this risk will be assessed.
Allied health professionals are not like other NDIS providers. To register with our professional associations, allied health professionals much meet a range of requirements. To register as music therapists, RMTs must complete accredited tertiary level qualifications (currently AQF9 level) and maintain strict compliance with AMTA’s code of ethics and professional standards (including continuous professional development), with existing structures for consumer complaints or concerns and professional investigation. AMTA argues that the current processes are duplicative and excessive for highly qualified and regulated professions.
In the current auditing process Early Childhood Supports and Behaviour Supports are considered ‘high-risk supports’ and require providers to complete the most intensive
AMTA SUBMISSION: NDIS Provider and Worker Registration Taskforce
and costly audit/registration process. Audit requirements in this context are excessive and limit the workforce available to provide Early Childhood Supports and Behaviour Supports. These requirements negatively and significantly impact the availability of highly qualified and regulated RMTs providing early intervention; when supports provided in critical stages of development can deliver lifechanging outcomes for children and their families.
The introduction of mandatory registration without changes to current processes and costs will result in loss of RMTs in the Scheme – a loss to those NDIS participants for whom music therapy is a critical and valued support. Market thinning via professional attrition will reduce access to music therapy and result in poorer health and wellbeing outcomes for participants.
What we recommend
AMTA strongly recommends reducing duplication for AHPRA and NASRHP-regulated professions. The NDIA must recognise existing structures for professional registration, with current professional registrations recognised as quality safeguards within the NDIS. AMTA strongly supports allied health being included in a lower risk category, either in Basic or Enrolment (or somewhere between).
Importantly, by recognising these regulatory structures and processes, the NDIA would reduce its administrative load and improve timely registration to get quality supports to participants sooner.
What key features of the proposed model are important to you?
Music therapy is a growing profession, and a high percentage of the workforce are women; many RMTs work part-time. To ensure an equitable and accessible process for RMTs and other allied health providers, any changes to registration requirements must consider:
Cost of Registration: Many RMTs report the current cost to undertake an external audit and register as an NDIS provider restrictive and not proportional to business size. NDIA has not applied indexation to therapy supports for four years. Additionally, music therapy is not a GST-exempt support, meaning RMTs receive hourly rates equivalent to 2018 and lower than other allied health providers. This is due to the outdated listing of health professions Other Health Services listed under s38-10 of Division 38 of the GST Act. This issue has arisen because music therapy was omitted from the table referred to in paragraph (a) of subsection 38-10(1) of the GST Act. Notably this is different from those NDIS participants receiving Early Childhood Supports or supports in residential services.
The stagnation of therapy supports pricing and increasing cost pressures to run a private practice/small business mean that many RMTs cannot justify expenditure on external audit fees when they can continue to provide supports as unregistered
AMTA SUBMISSION: NDIS Provider and Worker Registration Taskforce
providers. Any changes to the registration process which require an external audit to be undertaken need to ensure that the associated fees are affordable for providers, particularly sole traders and small businesses.
Mandatory registration without changes to the existing registration process will result in market losses across Australia, and particularly in rural and regional areas where allied health practices may be reliant on more than one funding stream or program.
Compliance with Practice Standards: Risk and business size should be registration factors. If registration is about ensuring a binding set of policy and procedures to safeguard participants then the NDIS should issue these as standardised and then all businesses subscribe and register to align with those. These could be built with participant voice included. Currently the required policies and procedures associated with the practice standards, and the administrative burden to comply with these, does not accurately reflect the quality of services provided to participants.
Recognition of existing regulatory requirements: AMTA encourages recognition of existing regulatory requirements for Allied Health professionals including Registered Music Therapists. Regulatory controls in accordance with AHPRA professions are already in place for self-regulated professions via NASRHP (National Alliance for Self-Regulating Health Professions). We recommend that these robust regulatory processes be accepted as meeting the requirements for registration for NDIS providers to reduce duplication.
What is the most important thing to you that you want the Taskforce to consider when developing their advice?
AMTA acknowledges and welcomes this consultation, and advocates for ongoing meaningful consultation on issues in the future. We have raised our priorities with the NDIA via numerous prior submissions. AMTA notes that in the past, our responses to consultations have remained unheard and unresolved. We trust this consultation will continue to hear and value the voices and skills of allied health professionals. We hope this Taskforce will continue to propose and consult on recommendations before they are presented as final for implementation. This process will allow participant, carer, and provider voices to be heard.
Regarding the NDIS provider workforce, top priorities for AMTA and its members are participant safety, participant choice and control, quality of supports, and accessible processes for registration and auditing.
Participant Safety and Quality of Supports: AMTA strongly supports the NDIA’s focus on providing high-quality and safe services to NDIS participants. AMTA often receives notification of non-qualified individuals claiming to be music therapists working with NDIS participants. Often, these are passionate musicians who are unfamiliar with the requirement for music therapists to be qualified and registered with AMTA. Without
AMTA SUBMISSION: NDIS Provider and Worker Registration Taskforce
formalised NDIS registration requirements, it is difficult for the AMTA and NDIA to identify and regulate unqualified providers.
Participant Choice and Control: AMTA strongly supports the right of NDIS participants to choose supports from providers that best meet their individual needs. We believe that registration should create more opportunity for services to join the NDIS and extend the volume of supports available to participants with funding through the NDIS. If registration restricts or reduces services available, it will have failed participants and created more long-term impacts for people with disability and a potential escalation of financial costs for the NDIS as people have to remain in the scheme for longer.
Accessible registration processes: AMTA encourages recognition of existing regulatory requirements for Allied Health professionals including RMTs. AMTA supports simplified compliance processes and a reduction to external audit costs for providers who are already regulated by a governing body with nationally recognised quality and safety standards.
In your view, how can the proposed model uphold the rights of people with disability, including the right to live independently and be included in the community, be free from violence, abuse, neglect and exploitation, have an adequate standard of living and economic and social participation?
AMTA supports compliance with quality and safety measures to ensure that NDIS participants receive safe, high quality, individualised supports from appropriately qualified providers. We hope that mandatory registration will reduce unregistered and unqualified providers falsely claiming therapeutic supports.
AMTA asserts that existing regulatory processes for allied health professionals such as RMTs should be recognised, and not duplicated. This will increase administrative burden on providers and the NDIA, allowing a greater focus on priorities for participants.
The introduction of mandatory registration without changes to current processes and costs has the potential to adversely impact which service providers NDIS participants are able to engage with, including restricting participants’ access to their current providers (if they are currently unregistered providers and do not choose to participate in mandatory registration). AMTA suggests that more information is needed regarding the impact of mandatory registration on participant choice and control.
Submission Lodged Sun 5 May 2024