Submission to:
NDIS Review: What we have heard
August 2023
Submission to:
NDIS Review: What we have heard
August 2023
Introduction
Music therapy is an evidence-based practice and allied health profession and in Australia is delivered by registered music therapists (RMTs). Allied health professions all require a minimum AQF7 university-level education. Current RMT graduates have achieved an AQF9 level qualification and are accredited nationally by the Australian Music Therapy Association (AMTA). There are currently nearly 800 music therapists registered with the AMTA.
RMTs are allied health professionals with expertise in using music engagement to activate complex neurological structures. RMTs design and deliver individualised music-based interventions that support social, communicative, sensory, emotional, cognitive and behavioural skills.
For NDIS participants, music therapy can significantly impact mood, cognition, behaviour, communication and mobility, and increase independence, socialisation and community participation. RMTs are recognised therapy service providers for the NDIS and provide crucial and life-changing supports for people with disabilities and their carers.
AMTA is the national peak body for music therapy in Australia, and is responsible for registering RMTs, accrediting music therapy courses and maintaining professional standards and ethics. AMTA is a member organisation of Allied Health Professions Australia (AHPA) and the National Alliance for Self-Regulating Health Professions (NASRHP). Membership of NASRHP requires all RMTs across Australia to meet 11 regulatory standards to ensure consumers receive quality and safe services from qualified and certified RMTs.
AMTA acknowledges and welcomes this consultation. We have raised our priorities with Minister Shorten in person and 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, who in the NDIS often act as advocates for participants. We hope the Review will propose and consult on their recommendations before they are presented as final for implementation. This process will allow participant, carer, support people and provider voices to be heard.
1. Applying and getting a plan
The processes and procedures within the NDIS are protracted, complex and often lack transparency, consistency and predictability for participants and their support people. RMTs, their allied health colleagues, and other providers are adopting the role of advocate to support participants to navigate complex and inconsistent planning processes.
Experiences of engaging with the Scheme
The initial planning process continues to be the aspect of the NDIS causing the most distress to participants and the most concern to providers. Planning and coordination requires a high-level understanding of complex disability and a detailed understanding of the disability sector and the value of available supports. Choice and control for participants is best facilitated by coordinators and planners who understand the breadth of supports available to participants and the benefits and outcomes these deliver. NDIS participants and our members continue to express concerns that decision-makers, often coordinators and planners, may not have sufficient knowledge, training or skills to enable participants’ active role in decision-making, make valid decisions about participant goals and plans or identify the most suitable providers for support.
AMTA members continue to witness participants’ being disempowered to make their own choices and decisions due to administratively-driven and economically-motivated processes within the NDIA. We have heard from participants who have had plans drawn up on their behalf without their or their family’s consent or engagement and denied the opportunity to have input. Participant supports have been removed or drastically reduced without consultation with participants. We hear that decisions are made without having read reports by allied health professionals (reports paid for by the NDIS). Such experiences are in direct conflict with the intent of the NDIS. Any further objections or appeals are extraordinarily difficult and cause significant distress for participants and their support people.
The complexity of funding guidelines also impacts the ability of applicants and participants to make informed choices and decisions about their support needs, priorities and goals. The participant perspective is often lost when conversations take place with NDIA. LACs and Planners must have the requisite skills to manage conversations about finite resourcing and personal support needs meaningfully and sensitively. These skills and interactions significantly impact the relationships of planners and coordinators with participants, often placing them as an adversary rather than a facilitator. Participants and providers refer to their, at times, combative relationships with the NDIA. Participants and providers tell us that those with ‘bureaucratic literacy’ and the available mental and emotional resources can ‘fight’ for NDIS access and supports. Those without specific bureaucratic skills are unable to challenge the NDIA, creating additional disadvantage. Funding and procedural complexities push the participant experience further from an ‘ordinary life’ with protracted, complex, distressing and exhausting processes.
Inconsistent decision-making is experienced over time by participants. Participants report to AMTA that music therapy may have been a primary support one year yet is not approved for the following year, despite ongoing needs and a clinical recommendation for continued funding. AMTA is concerned by decisions to remove primary supports despite participant choice and clinical recommendations. These decisions have serious consequences for a participant’s health and wellbeing. AMTA also questions the need for frequent planning reviews for those participants with stable and ongoing needs. Less frequent
reviews for participants could promote continuity and minimise the stress associated with the NDIS funding and planning process. For providers, less frequent reviews could enable longer-term planning for participant supports, reduce proportionate funds expended on non-contact activities, and reduce the workload for the NDIS. NDIA could review a plan when there was a change in circumstance, as needed, or at a 2-3 yearly period.
| Impact | People with disability and their support people are actively disempowered by protracted planning processes and procedures with limited transparency, consistency and predictability. People with disability and their support people are experiencing harm from NDIA processes and practices. People with less ‘bureaucratic literacy’ experience compounded disadvantage as they are unable to ‘fight’ for resources and supports. Providers are investing valuable time and resources in providing guidance, education and support to navigate the complexities of the NDIS or challenging planner and LAC assumptions. |
| Solution(s) | Ensure planning processes place people with disability at the centre, in accordance with the intent of the NDIS. Ensure planning processes are transparent, easily understood, and consistent – for participants and providers. Actively enable choice and control for people with disability. Ensure review processes are timely, transparent and truly accessible for the participant. Consider longer timeframes for plan reviews for those whose needs are less likely to change quickly. Ensure NDIS staff have the skills, expert knowledge and resources to engage with people with disability and their support people in a way that actively promotes choice and control. |
2. A complete and joined-up ecosystem of support
Experiences of intersection and interaction of services inside and outside the NDIS are fraught. The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability exposed the many issues people with disability experience in the health sector¹. Many of these issues extended from poor coordination and communication, governance issues, and unclear responsibility for different aspects of care. Poor communication between NDIS providers and non-NDIS services can result in delayed or inappropriate care and directly impact short and long-term health and wellbeing. The perceived focus on service and economic rationing by the NDIA can negatively impact timely access to support. Different languages, models and frameworks across the various sectors (e.g. treatment, maintenance, rehabilitation, capacity building, recovery) increase complexity for professionals and disempower NDIS participants.
Complex interfaces require planned and coordinated approaches to improve communication, integration, and participants’ outcomes. Instead, issues at these interfaces are often managed by the participant, their carer or support person, often at significant personal burden and expense.
The Linkages and Capacity Building Program grants do not provide providers with enough confidence long-term to design, develop, plan and implement innovative service models.
¹ https://disability.royalcommission.gov.au/public-hearings/public-hearing-4
The issue of ‘duplication’ is a recurring one and one we have raised previously with the NDIA. Our members report that engagement with non-NDIS services can result in exclusions of goals or supports from participant plans (with NDIS citing duplication) or extended delays as different segments of government debate responsibility for funding or delivering care. For example, engagement in an early intervention program in the community may determined to address an NDIS goal and result in the removal of a specialist NDIS support in that area. The AMTA regularly reminds the NDIA that allied health professions offer unique, specific value to participants. Music therapy provides unique and distinct value to participants that is different from other allied health professionals. Participants may benefit from and actively select collaborative and multidisciplinary approaches involving more than one profession or more than one service to address their NDIS goals.
Multidisciplinary and interdisciplinary care, where participants, carers, support people and professionals work together to address shared goals, is not duplication; it is best practice.
| Impact | People with disability and their support people experience poor coordination and communication, governance issues, and unclear responsibility for different aspects of care across funding providers and services. The notion of ‘duplication’ within the NDIS actively precludes participants from accessing relevant supports from other parts of the service system. Poor communication and/or conflict between NDIS providers and non-NDIS services can result in delayed or inappropriate care and directly impact short and long-term health and wellbeing. Different languages, models and frameworks across the various sectors (e.g. treatment, maintenance, rehabilitation, capacity building, recovery) increase complexity for professionals and disempower NDIS participants. Providers invest valuable time and resources in providing guidance, education and support to navigate the complexities of the NDIS or challenging planner and LAC assumptions. |
| Solution(s) | The NDIA must reconsider the notion of ‘duplication’ within the NDIS. Participants can more efficiently and effectively achieve their goals when providers work together. This is not duplication; it is best practice. NDIA must recognise and value the specialist contributions of music therapy and allied health professions in the Scheme. NDIS must be open to participants accessing relevant supports from other parts of the service system whilst simultaneously accessing ‘reasonable and necessary supports’ from the NDIS. NDIS should consider how to encourage, enable and provide links to community-based service models. |
3. Defining reasonable and necessary
The criteria for Reasonable and necessary supports as defined in the National Disability Insurance Scheme Act 2013 - Sect 34 seem clear and meaningful. However, the interpretation and application of these criteria causes difficulties for participants and providers, resulting in unclear criteria, inconsistent decision making and distress for participants.
AMTA was heartened to see the recent publication of the NDIS Commission’s Evidence-Informed Practice Guide, which highlights the various types of evidence, importance of respecting the experiences, perspectives and rights of people with disability and the expertise of professionals and providers. AMTA
is supportive of an approach to planning and the determination of what is ‘reasonable and necessary’) that takes into account these four components:
Figure 1: NDIS Commission's model of evidence-informed practice
(Adapted from Sackett, et al. 1996 and Hoffman et al. 2016).
AMTA and our members continue to provide the NDIS with evidence about the value of music therapy from a research and evaluation evidence perspective, information from implementation contexts and clinical expertise. However, we continue to hear from some planners and coordinators that there is insufficient evidence to include music therapy in participants’ plans. This occurs even when music therapy is the primary support selected by a participant, their carers and support people.
Additionally, for participants, the language used within the NDIS is still largely complex and bureaucratic. This public-facing webpage is an example of how communications with participants continue to be overly complicated and unclear.
Participants and our members perceive the term ‘reasonable and necessary’ as rationing language. It can cause distress to participants when plans are declined or they are not empowered or enabled to select their most appropriate supports. Participants, their carers and support people can perceive they are being ‘unreasonable’ by identifying or selecting their preferred supports.
| Impact | People with disability and their support people are actively disempowered by unnecessarily unclear and complex language and processes. Language used by the NDIA continues to be overly complex and inaccessible for many participants, their carers and support people. The interpretation of criteria by planners and coordinators leads to inconsistencies, unpredicatability and potential conflict and distress. People with less ‘bureacratic literacy’ experience compounded disadvantage as they are unable to ‘fight’ for resources and supports. Providers invest valuable time and resources providing guidance, education and support to navigate the complexities of the NDIS or challenging planner and LAC assumptions. |
| Solution(s) | Simplify language and processes to meet the needs of people with disability, their carers, and support people. |
Ensure planning and communications place people with disability at the centre, in accordance with the intent of the NDIS. Ensure planning processes are transparent, easily understood, and consistent. Actively enable choice and control for people with disability. Embed principles from the new NDIS Commission’s Evidence-Informed Practice Guide into the implementation of reasonable and necessary criteria. NDIA should work with therapy speak bodies, support providers and NDIS participants to develop information and guidelines about best practice therapy supports that help participants achieve their goals. Ensure NDIS staff have the skills, expert knowledge and resources to engage with people with disability and their support people in a way that removes jargon and bureaucratic-speak and actively promotes choice and control.
4. Early childhood supports
A well-planned multidisciplinary team approach is considered best practice in early intervention, where a child’s developing behavioural, cognitive, social and communication systems are inextricably intertwined⁴. Family-centred team approaches to early intervention are central to achieving positive outcomes for children. Multidisciplinary teams may span funding programs, services and sectors – one child’s team may span education, NDIS providers and health and medical specialists – including teachers and teaching support staff, school-based learning support, allied health providers, assistive technologies, paid carers and specialist physicians. Multidisciplinary care, where professionals and families work together to address shared goals, is not duplication; it is best practice.
AMTA member experiences are that the NDIA undermines best practice and collaboration between providers. Planning is perceived to be based on a ‘tick-box’ system where participants have priorities addressed via separate and distinct goals rather than understanding the complexity of interactions between and across skills, function, goals and therapies. Planners tell participants and providers that if one provider is allocated to a goal, the NDIS has addressed that goal. Participants’ carers and support people are then having to choose which support they believe will best meet their child’s needs, to the exclusion of others. This places unnecessary burdens on families, carers and support people.
AMTA supports the value of delivering interventions in naturalistic settings. Some children with disability and autistic children may have difficulty generalising skills⁵; working in partnership with families and carers (a child’s primary ‘environment’) is invaluable and impactful. Providing for generalisation of skills across contexts represents high-quality, individualised planning and interprofessional collaboration, with providers working together to achieve critical goals identified by the child, their family or carer. Working together toward shared goals across professional boundaries has significant potential benefits for children and families. AMTA firmly rejects the NDIA’s current perception of this work as ‘duplication of supports’ - an approach that actively undermines, lessens or eradicates positive interprofessional, family-centred team approaches to care.
Allied health interventions designed for early childhood participants are developmentally informed and age-appropriate, with play often used as the natural setting. These play-based interventions may be delivered across environments, including the home, early childhood settings and clinical environments. Delivery in early childhood environments and partnership with early education providers must consider the actual costs associated with program development and delivery.
| Impact | NDIA’s concerns about ‘duplication of supports’ actively undermines the delivery of best practice, multidisciplinary approaches in early intervention. Language used by the NDIA continues to be overly complex and inaccessible for many participants, their carers and support people. The interpretation of criteria by planners and coordinators leads to inconsistencies, unpredictability and potential conflict and distress. People with less ‘bureaucratic literacy’ experience compounded disadvantage as they are unable to ‘fight’ for resources and supports. Providers invest valuable time and resources providing guidance, education and support to navigate the complexities of the NDIS or challenging planner and LAC assumptions. |
| Solution(s) | Simplify language and processes to meet the needs of people with disability, their carers, and support people. Ensure planning and communications place people with disability at the centre, in accordance with the intent of the NDIS. Ensure planning processes are transparent, easily understood, and consistent. Actively enable choice and control for people with disability. Embed principles from the new NDIS Commission’s Evidence-Informed Practice Guide into the implementation of reasonable and necessary criteria. Ensure NDIS staff have the skills, expert knowledge and resources to engage with people with disability and support people in a way that removes jargon and bureaucratic-speak and actively promotes choice and control. Reconsider the notion of ‘duplication of supports’. |
5. The support and service marketplace
Ongoing challenges with planning, planning decisions and annual review of pricing arrangements create obstacles to full provider market engagement with the NDIS.
Effectiveness and sustainability of the NDIS
Financial and actuarial modelling and forecasting are essential for the NDIS’ longevity - AMTA acknowledges that NDIS costs continue to rise. However, financial modelling provides only one lens to inspect the inputs, outputs, outcomes and impacts of the Scheme. AMTA would urge the NDIA to review measures used to identify the social, individual and economic impacts of the NDIS, to obtain further insights into the critical outcomes the Scheme is achieving with people with disabilities and communities more broadly. To exclude these measures is to misunderstand the purpose of the Scheme.
AMTA draws attention to the complexity of the existing funding model, the NDIS Pricing Arrangements and Price Limits for 2022-23. This complexity results in significant administrative burden (time and costs) for providers – to ensure they understand the scheme and meet requirements to deliver supports. This complexity negatively impacts the ability of providers to think, plan, and provide supports differently.
The NDIA may improve its sustainability by identifying and addressing waste, such as burdensome administrative processes and increasing rates of AAT reviews. Participants and their support people must not bear the consequences of recent modelling, forecasting and sustainability concerns. AMTA
reasserts the importance of a stable and informed NDIA workforce that is suitably prepared and supported to effectively collaborate with participants and their support people to make high-quality and meaningful decisions.
Statements in the media about ‘price-gouging’ and ‘greedy providers’ undermine participants’ confidence in providers. These statements also dishearten and disengage providers and practitioners from their critical, life-changing work with participants.
Stable rural, remote, and very remote services rely on consistent funding arrangements to attract and retain rural and remote practitioners and enable design (and co-design) and delivery of flexible and innovative service delivery models. We would welcome a detailed study of rural and remote service costs to ensure funding models do not drive further inequities in access, health and outcomes for people living in rural and remote areas. We would also encourage the NDIA to examine alternative funding arrangements, which might support access in regional, rural and remote areas. For example, funding full-time (or higher EFT) allied health positions in rural areas by pooling available funds from NDIS, state-based health organisations, PHN funds and other service providers.
AMTA recommends that the NDIA commit to a 3-year pricing model (with CPI increases) to give providers the stability to undertake future-focussed business modelling, build momentum and systems in the field, and enable more significant innovation and program model development.
| Impact | Annual review of pricing arrangements creates instability in the market. Providers are dedicating significant resources to understanding and responding to frequent changes to administrative requirements associated with the NDIS. NDIA should increase its focus on the value of NDIS outside of purely financial accounting. Complex funding and pricing arrangements create complexity in the system, leading to inconsistency. Some health professionals are GST-inclusive, while others are GST-exempt. |
| Solution(s) | Commit to longer-term pricing arrangements to give providers the stability to undertake planning and develop innovative programs and approaches. Provide rural and remote markets with greater ability to plan and establish much-needed services through longer-term pricing arrangements (e.g. 3 years). Consider joint-funded positions, commissioned services and other specific funding arrangements for rural and remote areas. Actively reinforce the use of telehealth in rural areas. Recognise, value and celebrate the contributions of allied health in the NDIS, to reinforce the disability sector as desirable and sustainable employment. Ensure planning processes place people with disability at the centre, in accordance with the intent of the NDIS, to minimise issues and reduce administrative processes. Ensure planning processes (and finding providers) is a simplified and transparent process to enable choice and self-determination. Ensure staff are equipped to have complex and sensitive discussions about prioritisation of supports. |
Music therapy – an available, self-regulated and evidence-based market resource
Music therapy is a specialist, evidence-based allied health profession, equivalent in terms of qualifications, accreditation and registration status to professions such as speech pathology or dietitians. RMTs are Masters- and Bachelor-level qualified and accredited by AMTA. However, approvals for music therapy are inconsistent, both across different regions and over time for individual participants. We often hear of participants going to AAT to resolve issues with the processes within the NDIS.
AMTA often hears of misrepresentations of music therapy by LACs and planners who have told participants that music therapy is not an approved funded support. AMTA continues to receive complaints from its members regarding some NDIS planners’ misinformation about music therapy and ultimately, their refusal to fund music therapy in NDIS plans - irrespective of participants’ requests and comprehensive reports describing strong outcomes across all domains of daily functioning. Some participants report that the NDIA denies participants access to music therapy supports without reading clinical reports (which incidentally have been paid for with their NDIS funds). AMTA has communicated regularly with the NDIA about these ongoing issues and provided information, evidence reviews and case studies. We have offered training. We urge the NDIA to collaborate with AMTA to address these ongoing issues.
| Impact | NDIA repeatedly poses the use of lower-quality, less-safe services for people with disability by substituting allied health professions with unsupervised assistants or workers. This erodes confidence, safety and quality in the Scheme. People with disability and their support people have inconsistent access to music therapy. |
| Solution(s) | Recognise, value and celebrate the contributions of allied health in the NDIS, to reinforce the disability sector as desirable and sustainable employment. Ensure people with disability and their support people have ready access to information about available supports so they can make informed choices about their plans. Ensure NDIS staff have the skills, expert knowledge and resources to understand the range of available evidence-based supports, including music therapy. Ensure NDIS staff have access to appropriate, high-quality and current information about music therapy and associated outcomes for participants. AMTA would be pleased to work with the NDIA to increase understanding of music therapy for people with disability and their support people, planners, and coordinators. Ensure planning processes place people with disability at the centre, in accordance with the intent of the NDIS, to minimise issues and reduce administrative processes. Ensure planning processes (and finding providers) are simplified and transparent to enable choice and self-determination. Ensure staff are equipped to have complex and sensitive discussions about prioritisation of supports. |
6. Measuring outcomes and performance
AMTA stresses the importance of safety and strong clinical governance as accepted foundations of the Scheme. RMTs are a self-regulated allied health profession recognised by AHPA and NASRHP. RMTs have specific qualifications, accreditation and expertise in evidence-based approaches to the use of music to improve health and wellbeing. Allied health professional practice is evidence-based and includes
outcome measurement and continuous service measurement, evaluation and review as part of everyday practice. Any work to further embed outcome measurement in the NDIS must be developed and/or selected with participants and allied health professionals providing therapy supports.
The NDIA’s perceptions around the costs of allied health therapy supports, and suggestions that less qualified health workers could do the same work, undermine conversations about outcomes for participants. Substitution of allied health professionals with assistants, unqualified or unregulated workers reduces the quality of supports, risks participants’ outcomes, and is potentially unsafe.
AMTA would welcome greater focus on Scheme outcomes and evaluation. AMTA is strongly opposed to a system that ties outcome measurement to payment. AMTA does not agree that providers should compete to deliver the ‘cheapest’ service, but instead focus on high-quality supports and outcome achievement. Our members note that outcomes measurement is often ableist/normative and focused on function rather than participation. This would need to be considered in developing or selecting outcome measures for the Scheme.
Our members caution the NDIA not to oversimplify outcome measurement and goal achievement. Generalised outcome measures often do not adequately capture outcomes for people with complex needs. A simplistic approach to outcomes-based funding may act as a disincentive for practitioners to support more complex clients with profound disabilities, or promote selection of ‘micro-goals’ to increase goal achievement that may not reflect ‘real’ change for the participant. AMTA cautions against use of outcome measures that would disadvantage those participants with more profound needs. Any proposed funding model should consider the potential impact on participants, and equitable access to supports.
Blended payments may disadvantage smaller and solo providers, who may have less capacity to embed a new and additional quality system into their practice or organisation. This could in turn impact market availability or skew the market to larger providers (potentially with less geographical spread).
AMTA was frustrated to read the question posed in the What we have heard report (p.17): How can we build a system where the NDIS keeps improving based on evidence? For years, AMTA has responded to NDIA consultations, highlighted the evidence base for music therapy and allied health, and advocated for a better system. We have provided research papers, case studies, and commentary from participants and providers. We often feel that we oppose the NDIA when advocating for participants when we would prefer to work as allies (we share the outcomes and experiences of participants as drivers for the work we do). While we have had some successes with greater understanding and acceptance of the evidence and reflecting this in practice (particularly at a regional level), changes have not been experienced at a systems level. There is still work to improve the experiences of participants and support for music therapy by planners and coordinators.
NDIA and the NDIS Review should collaborate with participants, their support people and providers about what constitutes positive outcomes from the Scheme and codesign a framework for appropriate outcome indicators and measures.
| Impact | Outcome measurements are routinely used by allied health, often reported in NDIS participants’ reports. Outcome measures shape allied health practice with participants to maximise goal achievement and outcomes from the Scheme. |
| Impact | Pairing outcome measurement with payment can have unanticipated consequences, such as reduced service availability for people with more complex needs, or adjustments to goal setting to enable goal achievement. |
| Solution(s) | Collaborate with participants, their support people and providers about what constitutes positive outcomes from the Scheme and codesign a framework for appropriate outcome indicators and measures. Ensure NDIS staff have the skills, expert knowledge and resources to understand the range of available evidence-based supports, including music therapy. Genuinely codesign with participants and providers to improve understanding of outcome measures and work toward developing or selecting appropriate measures in the NDIS. Improve communication between providers and participants about outcomes and appropriate outcome measures as a useful tool to describe goal attainment and progress. Ensure NDIS staff have access to appropriate, high-quality and current information about music therapy and associated outcomes for participants. Partner with peak bodies and providers over time to ensure the NDIS reflects best practice and the available evidence base and continues to improve. |
10. Participant safeguards
AMTA strongly supports the NDIA’s focus on providing high-quality and safe services to NDIS participants. AMTA stresses the importance of safety and strong clinical governance as accepted foundations of the Scheme. AMTA is the national peak body for music therapy in Australia, and is responsible for registering RMTs, accrediting music therapy courses and maintaining professional standards and ethics. AMTA is a member organisation of Allied Health Professions Australia (AHPA) and the National Alliance for Self-Regulating Health Professions (NASRHP). Membership of NASRHP requires all RMTs across Australia to meet 11 regulatory standards to ensure consumers receive quality and safe services from qualified and certified RMTs.
AMTA values the focus on quality and safety evidenced by NDIS registration processes, however notes the significantly lower focus on quality and safety when unregistered NDIS providers deliver supports. We advocate for a system that ensures the qualifications and accreditation of allied health professionals, regardless of provider registration status.
Allied health professions are a highly regulated, safe and high-quality resource in the NDIS ‘market’ but the NDIA often undervalues our advice, skills and professionalism. In discussions with NDIA about the importance of allied health therapy supports, we have repeatedly been met with concerns about costs, and suggestions that less qualified/regulated health workers could do the same work. Substitution of allied health professionals with assistants unqualified or unregulated workers reduces the quality of supports, risks participants’ outcomes, and is potentially unsafe.
AMTA’s professional self-regulation processes provide safeguards for NDIS participants in terms of registration and ethical and safe practice by RMTs. We recommend NDIA works together with the existing professional bodies to minimise duplication and reduce the unpaid (and costly) workload of allied health professionals relating to NDIS registration.
| Impact | Allied health regulation and self-regulation provide confidence, safety and quality assurance for participants and the NDIA. Music therapy is a self-regulated allied health profession. Cost-driven arguments to replace allied health with ‘lower cost providers’ risk reducing the quality of supports, participant outcomes and safety. Unregistered NDIS providers - particularly otherwise unregulated providers - pose a specific risk to participants. Unregistered NDIS allied health providers (qualified and accredited by their professional bodies) provide some safeguards for participants due to their professional regulation. At significant costs, allied health NDIS registered providers experience duplication in NDIS registration and professional regulation processes. |
| Solution(s) | Collaborate with allied health to understand regulation, self-regulation, and the safeguards this provides. Collaborate with allied health peak bodies and providers to minimise duplication within the NDIS registration process and reduce administrative cost to the NDIA, and costs to allied health professionals. Ensure NDIA staff understand the quality and safety risks of recommending lower cost, lower quality supports. Collaborate with providers and participants to develop appropriate quality safeguards for all providers in the NDIS, across various professional groups and provider types. This is unlikely to be a one-size-fits-all approach, and safety should be the highest priority. |
AMTA welcomes the opportunity to continue conversations with the NDIS Review and the NDIA about how we can further improve the NDIS for participants, their families, carers and support people.
Contact: Bridgit Hogan Chief Executive Officer Australian Music Therapy Association Inc. E. ceo@austmta.org.au www.austmta.org.au