Parliament of Australia
Joint Standing Committee on the National Disability Insurance Scheme
Submission to Inquiry - provision of assistive technology
This submission summarises some of the disadvantages experienced and being experienced by my adult son due to the NDIS system lacking resources, having poorly trained planners, lacking a system to track progress of claims, and subcontracting the Victorian State-Wide Equipment Program (SWEP) without putting correct processes and procedures in place.
It summarises previous submissions to the NDIS Feedback system.
DELAY IN BEING ACCEPTED BY NDIS
Lost in the Roll-out
My son receives disability services from the Victorian DHHS and they advised that it was expected that NDIA would be in contact with him in 2016. When this did not occur by 2017 we visited a NDIS office and found that his recorded telephone number was incorrect (missing a digit) although his address was correct but had not been used to contact him.
After family intervention he was subsequently accepted as a NDIS recipient in 2017 with Plan funds allocated for assistive technology – power wheelchair replacement and associated special wheelchair attachment.
The telephone number given by the Victorian DHHS was missing a digit. Since Melbourne telephone numbers have 8 digits it should have been possible for NDIA staff to realise this and either get confirmation from DHHS of the number, or write using the postal address which was correct.
This lack of checking on the telephone number added six or seven months delay for a planning meeting. This delay had unforeseen consequences in that he was caught with a power wheelchair that the Victorian SWEP would not maintain as it was already 16 years old and which he could not replace until NDIA contacted him for the process of planning future support; and as it turned out, considerable time after this. Fortunately in this period of more than a year the existing wheelchair did not require major repairs which he would have had to personally pay for.
Suggested solution
More staff and adequate training
DELAY IN GETTING APPROVAL TO USE FUNDS
description
Attempts to get approval to replace the existing power wheelchair began immediately notification of NDIS acceptance was received in 2017. It was then another 7 months before the wheelchair was delivered. We had obtained a current supply quotation the month before
NDIS Plan acceptance,
SWEP were aware of my son’s need, the prescribing physiotherapist was immediately available to follow whatever system NDIS wanted, and the supplier considerably reduced the normal 8 – 10 weeks build time. Thus this 7-month delay was completely out of our control.
Written complaint to NDIA about the delay in getting approval to expend Plan funds and find out progress of the claim elicited the following emailed response:-
- NDIA had limited processes to deal with recipient requests to use their allocated funds,
- NDIA had insufficient staff to cope with the workload.
Suggested solution More staff and processes, and adequate training
NDIA POOR INFORMATION
Lack of information about assistive technology items. We have been unable to find any practical information on the NDIS web site regarding the process to initiate purchasing assistive technology items even when funds have been allocated in a plan. The Planner admitted that she did not know and the NDIS help line advised simply uploading a quotation. A follow-up telephone call from NDIA fortunately provided correct information.
Suggested solution Some practical advice either with the printed plan or in a referenced web site would be of help.
NDIS lack of traceability Inquiries with phone calls and visits to NDIA elicits the same answer – “don’t know where the approval request is in the system”, and it will be ‘escalated’. When pressed NDIA advised ringing SWEP – who then advised checking with NDIA!
Suggested solution It does not seem unreasonable for NDIA to have a logging/tracking system to enable recipients to see the status of their application. Given the poor experience with communication previously mentioned it is of concern that no information is available and this can trigger a concern that the system has ‘lost’ the application leading to an increase in checking with NDIA and concomitant increased staff workload.
SWEP LACK OF PROCESS
SWEP incorrect information At the time of them issuing a purchase order for the replacement power wheelchair, SWEP provided to my son both a letter headed ‘Notification of Customised Equipment Purchase’ and an attachment entitled ‘Equipment Information Sheet for Consumers’. These documents contain statements that are wrong and include:-
Ownership
The item is issued on a loan basis for as long as you need it.
Repairs:
For all repairs please phone 1300 747 937. SWEP will organise and pay for any necessary repairs to equipment purchased under the Program.
Emergency Repairs:
SWEP provide an after-hours emergency service 24 hours a day, every day of the year including public holidays. Please phone 1300 747 937 and you will be directed to the after-hours emergency service which is manned by SWEP staff.
Insurance
SWEP recommends that you consider insurance cover for your equipment. These statements are discussed below.
Ownership
Our understanding is that funds allocated under NDIS are provided to Participants personally for them to use, with NDIA approval, to purchase necessary items for their use and that the funds therefore have the status of a grant and equipment purchased with these funds are the property of the Recipient and are not provided on a loan basis. There may not in many cases be any practical difference between loan or grant but the status should be determined specifically as there may be legal implications such as insurance (see below).
Repairs & Emergency Repairs
At my son’s planning meeting the question of repair to his assistive technology items was raised (including his existing electric wheelchair) but the Planner could not provide any information about how this would be handled and the subsequent Plan has no recognition of these potential costs Consequently we were surprised to read from the SWEP issued documentation that they would ‘organise and pay for’ all repairs to the subject new electric wheelchair. In speaking directly with SWEP they advise this is not the case and they will not pay for repairs. NDIS in its pilot and rollout stages had been operating in Victoria then for about four and a half years; why was SWEP still issuing, as an agent of NDIS, patently wrong information about equipment repairs?
Insurance
Generally one requires an insurable interest in an item to be able to insure it – this is generally ownership. If an item is only ‘on loan’ the question of being able to insure it may be problematic.
Suggested solution
A complete review of the arrangement of SWEP subcontract and the processes to be used is warranted
Copy of Purchase Order
SWEP advise they are not authorized to provide a copy of the Supplier purchase order to either the therapist or the NDIS Participant.
For the NDIS system with policies of Consumerism, Choice, Control and Transparency this attitude seems to be a total disregard for these policies and a regression to the pre-NDIS days of paternalism.
Apart from the insult to the Participant, there may be commercial issues in keeping purchase orders secret – the Participant and Therapist are supposed to sign off on the product as delivered, but in the event of a discrepancy in what was requested and what was ordered this could result in a delay in delivery. Conversely if a copy of the purchase order was provided to the Therapist and the Participant when it was issued, any anomalies could be dealt with early in the process.
There simply seems to be no reason to keep the purchase order secret and this would not be contemplated in normal commercial transactions.
SWEP advise that any changes to the Therapist submission would be advised by NDIA to the Therapist and Participant when the submission is approved thus allowing consideration to be had of changes. However this is not a positive system since communication can get forgotten or misunderstood. The only positive way is for all involved to view the purchase order to ensure it is as requested.
We ask why is the purchase order for vital equipment to a Participant kept as a secret from them?
This situation is similar to the often complained about NDIA practice of refusing Participants access to draft Plans before they are submitted for approval. It was announced by NDIA Senior Management that this practice was to be changed – but has not been.
Suggested solution
It would be appropriate to change the policy of secrecy of Assistive Technology purchase orders and provide both the therapist and the participant a copy.
Behaving like no NDIS exists – questionnaire
A couple of months after obtaining the new wheelchair SWEP sent a questionnaire asking to rate the service provided by SWEP. This was written in a manner which clearly did not relate to the NDIS system but was a carry-over from SWEP’s previous role of deciding and approving funding for the Victorian Government. It included questions such as referring to SWEP providing funds, the timeframe for them to make decisions, etc
Suggested solution
A complete review of the arrangement of SWEP subcontract and the processes to be used is warranted
INADEQUATE TRAINING OF PLANNERS
Special Attachment
My son’s initial NDIS Plan had provision for purchasing the design and production of a special attachment for his electric wheelchair. Estimated at about $10,000.
At the first annual review meeting it was explained to the Planner that because of the long delay (7 months) by SWEP and NDIS to authorise a new electric wheelchair, the project to obtain the attachment for it has necessarily also been delayed. After finally receiving the replacement wheelchair and finalizing its customization for my needs, negotiating with potential suppliers for design and manufacture of the attachment was in progress.
Since the goals for this equipment had not changed and delay was due to the NDIS it was expected that the provision for this item in the Plan would be carried over to the new Plan. Instead it has been deleted with no explanation.
Purchase of vehicle
At the first annual review meeting it was explained to the Planner that because of transport difficulties accommodating a power wheelchair my son wanted to purchase a vehicle converted to be accessible for an electric wheelchair with the goal of being more independent with transport. The planner said she did not know anything about whether NDIS would assist with this purchase. We explained that NDIS policy was that the cost of conversion to wheelchair accessibility could be funded by NDIS if reasonable and necessary and subject to conditions about the vehicle.
The planner said she would have to find out from NDIA about this.
It was expected that this would be included in the Plan once the planner had obtained confirmation of NDIS policy. Instead the request has been ignored.
On querying this with the Planner her response was “I asked somebody in the office and they said it would probably not be funded, so I left it out”.
Conclusion
Since both of these items are within the NDIS policy to fund, subject to ‘reasonable and necessary’ and other tests, there is no valid reason to ignore the requests by the recipient.
There is no system except for requesting a Review of a Reviewable Decision, or AAT, to remedy this complete disregard by the Planner of NDIA policy. Since Reviews take months/years this amounts to a complete failure of the NDIS system to provide reasonable (and therefore timely) and necessary supports.
Suggested solution
Better training of NDIA planners and provide the participant a copy of the draft Plan for review before presenting for formal approval.
Adoption of Ombudsman’s suggestion of prioritizing requests for Review and reducing the (then) 14,000 backlog.
More staff to address in a reasonable time, recipient requests for Review.
NO UNDERSTANDING OF NEED FOR ACCESS TO MAINTENANCE FUNDS
At my son’s planning meeting the question of repair to his assistive technology items was raised (including his existing electric wheelchair) but the Planner could not provide any information about how this would be handled and the subsequent Plan has no recognition of these potential costs except to note ‘AT repairs – Quote Required’
Various answers are given by NDIA about this need, such as “submit a changed circumstances request” or “get a quote” or “request a review”. Such processes could take weeks/months and having obtained a quote what is one to do with it?
Severely physically disabled people may rely on their assistive technology almost as a life or death option. Such items include suction machines, personal hoists, bathing equipment, respirators, and pressure reduction mattresses. In the case of powered wheelchairs it is often the person’s life - without it working they may be unable to get out of bed. This can have adverse effects on their physical and mental health, especially if increased support staff hours are not provided for in-bed support.
Thus emergency repair of these items is vital but NDIA cannot provide any answer of how they can provide this. This is an immediate (same day) need, not the NDIA cumbersome weeks and months attitude.
This is an area that the Victorian SWEP system did handle well - having subcontractors to promptly attend to any equipment they had provided.
Suggested solution
In Victoria if a nominal value of funds was included in Plans for emergency repair of identified vital AT equipment, SWEP could be tasked to give same-day telephone or email approval to carry out immediate repairs of NDIS funded AT equipment.