Submission
Joint Standing Committee on the National Disability Insurance Scheme
Parliamentary Inquiry NDIS Assistive Technology
Independent Living Centre Western Australia
Submission context
The Independent Living Centre WA (ILC WA) has a 40-year history of providing information and advice to people with disabilities, older people, carers, families, health professionals, assistive technology (AT) suppliers and the Community Care sector. We are a middle-sized organisation employing 127 staff, two thirds being health professionals - Occupational Therapists, Speech Pathologists and Physiotherapists who deliver services across the state.
In Western Australia, the ILC WA is recognised, and held in exceptionally high regard, within the community for the provision of its specialty services including:
- allied health services with expertise in AT, reablement, home modifications and capacity building; and
- assessment to determine access and provision of support, technology requirements, equipment and services.
It is very timely, given the current roll out of the National Disability Insurance Scheme (NDIS), that the Joint Standing Committee is examining the provision of AT within its particular terms of reference. The ILC WA’s response below clearly highlights a number of valid concerns which ultimately will be detrimental to participants in the scheme.
The response has been framed around the recognised best practice AT service delivery stages. These being: information; assessment; selection; trial; prescription; purchase (funding); supply and delivery (fit and set up); training; repairs and maintenance (including emergency response plan); short and long term evaluation; and future planning (replacement, disposal). Within each term of reference the stages have been utilised to illustrate the issues and gaps in AT provision under the NDIS.
Transition to the NDIS and how this has impacted on speed of equipment provision?
Overall since the introduction of the NDIS there has been a significant decline in the speed of procuring AT.
Prescription
Paperwork and liaison for Health Professionals is now double to triple the amount of time that was previously spent. Therapists are having to spend significant time completing AT applications (previously if therapist had the required level of experience and knowledge of the piece of AT, then no further justification required - unless over budget ceiling price). Example: A lot of additional time is spent by therapists getting multiple quotes and conducting multiple and prolonged trials (as requested by the NDIS) to ensure value for money even when the therapist knows where to go to for the cheapest supplier or the best service for the situation/location.
Repairs and Maintenance
Within the NDIS funding system there is no scope to action a rapid response to urgent clinical needs.
Example: A client with pressure issues. Previously a therapist would be able to respond with an item within hours or days to initially sort the situation until a longer-term item is trialled and sourced.
This is the same issue if an AT item has been broken or become unusable. If a participant is unable to access funding for a Therapist’s time they can wait weeks or months for funding approval and then longer for the assessment and AT approval process.
Short and long term evaluation and future planning
ILC WA Therapists are skilled, experienced clinicians who understand the short and long term impacts of AT and how to mitigate potential issues. This important stage is not clearly funded for, or often perceived as valuable, by the NDIS or the participants.
Example: The participant receives a new wheelchair and finds it is working well so they choose to not spend their budget on additional time with the Occupational Therapist learning all the skills and knowledge related to maintaining the new wheelchair and putting together a review plan. The lack of skills and training for both participants and planners means they are not able to easily weigh the impact of short funding tradeoffs and their potential long term impact. Ultimately, it may cost participants additional funding to secure a more appropriate chair that properly fulfills all their requirements.
b. Whether the estimated demand for equipment to be sourced through the assistive technology process in each roll out area was accurate
No comments on this reference.
c. Whether market based issues impact the accessibility, timeliness, diversity and availability of assistive technology
Information
Level 1 and 2 AT – NDIA clients regularly come to the ILC WA for information and advice to assist them with their decision making as directed by the NDIS website[1]. Often the Level 1 AT solution, within the context of the person and environment, can make the solution complex therefore with the correct expert advice, a more suitable solution is recommended versus what the participant would had chosen on their own.
Example: A NDIS Participant calls the ILC WA to get advice on a selected Level 1 AT Alerting system that they wanted to purchase using their $1500 budget. Their personal requirements and the environment in which it is being used are established. The cost comes to $1900 and
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it is identified that it will require some additional therapist support to ensure suitability and fit.
- Assessment
There is a lack of choice for NDIS Participants in Rural and Regional WA. They are having their assessments completed by Health Department (WACHS) therapy services as there are no private providers in the region. It is unclear what will happen in the future if this does not continue.
- Selection
There are over 8000 AT suppliers across Australia but only 1100 in WA. For some complex AT there is only one supplier in Australia and the costs of shipping some products seem prohibitive even if they are deemed the best outcome post assessment. Example: A NDIS Participant who is not self-managing was declined a gate opening mechanism recommended by a therapist because there is no registered suppliers or fitters in WA.
- Trial
The ability to trial AT in regional areas is limited and often adds significant costs to the plan.
- Prescription
Currently a Clinical Advisor reviews an application to ensure that it was a suitable trial and purchase. The information to be reviewed is limited by the level of information and knowledge held by the prescribing therapist as they often do not know the full depth and breadth of complex AT. Additional time and costs can be added to the approval process when the AT solution does not work for the participant due to the prescribing therapist’s constricted knowledge base.
- Training/Repair and Maintenance/Short and long term evaluation/Future planning
With complex AT, it takes an experienced and skilled AT clinician to see, mitigate, and plan for future issues. This ensures the future viability of expensive and complex AT items. Under the NDIS this decision and planning is left to the responsibility of the participant who often don’t hold or value this knowledge and may solely rely on suppliers or their own social networks.
d. The role of the NDIA in approving equipment requests
- Information
In WA, participants have previously had regular access and relied upon (often well known) local area coordinators to help navigate the process and were given timely and accurate information and advice that was directly relevant to their situation.
Under the NDIS if support coordination is not funded within a plan there is no clear point/person of contact. To date , this has often resulted in participants coming to the ILCWA for support and advice about the NDIS process.
Purchase
Once the NDIS has sent out a letter to participants it becomes their responsibility to order the AT themselves.
Delivery (fit and set up)
Relies on the participant phoning the prescribing therapist to inform of delivery and to sign off/agree to using their budget for fitting and set up costs. Participants may not see or understand the value in spending some of their budget on fitting to mitigate future issues and ensure viability, which is evidence based, best practice AT provision.
Transparency
The process is often unclear for both the Assessor, and participant. The time frames are long and confusing and the pathways fragmented and disjointed especially if a NDIS participant does not have AT within their plan.
The ILCWA staff spend considerable time educating people on the process and advise on the potential timeframes and possible delays they may experience.
For the ILCWA, the amount of information being systematically circulated by the NDIS has been sparse and with no clear processes it has been essentially a ‘learn as you go’ process.
Choice and Control
Plans are often developed without full participation from the support team that know a participant. For example, NDIS plans often do not have accurate AT funding plans that result in delays in the speed of provision. All of this is not controlled by the participant but by the administered processes within the NDIA.
The only choice and control a participant has under the NDIS is which supplier or therapist they choose. The strict criteria of “reasonable and necessary” eliminates true choice around the type and range of AT they can request and for what it can be used.
e. The role of current state and territory programs in the assistive technology process
The ILCWA administers the Disability Equipment Grants (DEG) and Equipment for Living Grants (ELF) in WA. We are now witnessing a huge gap in AT funding for people over 65 and in specific circumstances for under 65s.
Example: A person with Motor neuron disease (a new, significant disability) is meant to receive a Home Care Package but will often wait up to 18 months. These people have huge and urgent AT needs, but are not eligible for the same AT that they would get if they were under 65.
Example: A person under 65 with obesity and co-morbid diagnoses is not eligible for NDIS and is now not eligible for CAEP (changed to over 65). These clients now do not have access to AT under any scheme.
Note – CAEP have indicated that one-off case like this will be considered but this appears minimal and it is unclear what will happen post 2020.
f. Whether the regulatory frameworks governing assistive technology are fit-for-purpose
- Information
The ILCs are currently funded to provide AT information and advice and are perceived as an important step in the AT procurement process due to the staff’s’ expert AT knowledge and experience. Both participants and other service providers value having an expert resource at the end of the phone or online (NED).
Examples: 20% of all ILC WA enquires and NED (National Equipment Database) searches are from Health Professionals needing information, advice and clinical support to select the right (often complex) AT for their clients. 30% of ILC WA enquires are from participants wanting to find, see and trial AT often as part of their planning.
Once the funding for Information and Advice services ends. Who will pay for these services in the future??
- Assessment
NDIS Participants in Rural and regional WA are having their assessments completed by Health Department (WACHS) therapy services as there are no private providers in the region.
- Selection
ILC WA deals with health professionals daily who require clinical support and advice to select, or in many cases find and source, the right AT solutions and suppliers for the NDIS AT process. Example: Our staff can often spend up to an hour to just short list AT for one Health Professional, related to one client’s issue.
- Trial
The ability to trial AT in regional and remote areas is limited. The assessing professional has limited access or exposure to more low demand, high complex solutions that may meet an NDIS participant’s needs and therefore result in recommendations based on limited knowledge and not expert advice.
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with AT by creating an inclusive, peer lead AT user community. AT Chat uses accessible formats familiar to AT users like Facebook, to create peer to peer conversations, an online forum, called Chatterbox that links with Independent Living Centre Therapists and AT + Me stories to share experiences and knowledge about AT, by AT Users across Australia. This project has recently been funded through NDIA Information, Linkages and Capacity Building funding to build on its achievements.