NDIA Accountability Project

Provision of Non-Electronic Communication Aids, Assistive Technology and the NDIS

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  • Communication

September

130072673 www.scopeaust

                   aust
    circ@scopeaust.org.au                              disability
  • Access to communication Electronic Service is a human right.

An estimated 1 in 500 people in Australia have severe communication disabilities or Complex Communication Needs, with approximately 25% being children (Perry, Reilly, Bloomberg, Johnson, 2002).

Scope’s Non-Electronic Communication Aid Scheme (NECAS) is funded until June 2019 by Department of Health and Human Services (DHHS) Victoria to provide customised non-electronic communication aids to adults with Complex Communication Needs (CCN). Additionally, Scope delivers Kids Chat 2 You – a program currently limited to three years, manufacturing non-electronic communication aids for children, with generous funding from philanthropic donors. The service also provides consultations and workshops in multiple locations across Victoria to support people with Complex Communication Needs to participate in life.

The following submission outlines changes NECAS and Kids Chat have experienced since the commencement of the National Disability Insurance Scheme (NDIS).

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We have experienced an increase in the wait time for communication aids since the NDIS rolled out. Under the previous block funded model, NECAS customers received their completed customised communication aids within four weeks. Under NDIS, participants are waiting an average of 15 weeks for their communication aids.

This is due to the NDIS model adding an additional layer of administration to the process. Under the previous funding model, NECAS applications were approved by Scope on average within two weeks of receiving an application. Under the NDIS, they are finally approved on average within 11 weeks.

Once a participant has the approval for Assistive Technology, the additional reports and justification further delay the process. For applications requiring approval, there should be a clear process for participants and providers and one approval point to streamline the process. This would reduce stress on participants.

Processing time of applications for communication aids

Processing time of applications for communication aids is significantly longer through Capital

Supports – Assistive Technology and in our experience planners more frequently use the Core

Supports budget. Going through the Core budget means that the communication aid budget in the

plan may then go under-funded. The Core budget includes $1500 for communications aids, which

can only be used in $520 increments. This means a participant may not have enough funding in their

plan to cover what is required and will need to access additional funding. This is a confusing process

that needs clarification and systems in place to ensure a person can get the reasonable and

necessary funding to meet their fundamental human rights to communication aids.

The speed of equipment provision is particularly concerning with regards to urgent applications. Prior to NDIS funding, NECAS could respond to urgent requests for communication aids promptly. This might be for people with degenerative conditions or those who have behaviours of concern. For example, we have provided a complex communication book within a day for a child entering hospital who would otherwise not have been able to communicate with unfamiliar communication partners.

There have been instances of planners attempting to influence what is recommended to the participant. Planners are not qualified to determine whether Assistive Technology is reasonable and necessary. As health professionals, we operate under a code of ethics and hold a duty of care to ensure the safety and welfare of our clients. Planners are a barrier between participants receiving what is reasonable and necessary to support people’s rights to communication.

For example, we have heard from our customers that NDIS planners have:

  • Challenged requests for non-electronic communication aids as reasonable and necessary This means that people who need one or multiple communication aids may not receive them. As an example, a person who uses an electronic communication aid may request to have a visual calendar that is physically accessible to him, but have this rejected by the planner given that he already has an electronic device.

  • Not included communication aids in plans as they think they should be funded through other means, such as the education system. Planners we have spoken with have refused non-electronic communication aids saying that this is the school’s responsibility.

  • Included complex non-electronic communication aids under core supports and requested quotes for items are split to under $500 each

It is important that customisation of aids is valued and included within NDIS plans. Customisation requires evidence-based practice and a speech pathologist to assist with selection and customisation, and can be overlooked if the NDIS plan uses Core Supports only. The participant may receive the wrong communication aid as they need therapist support in selection and implementation. This may mean that communication aids are not seen as beneficial and not valued in the future. With the right advice and support communication aids are effective and essential for people with Complex Communication Needs.

  • Requested quotes and assessment reports for level 1 equipment

This often occurs where requests will exceed the $1500 Core Supports category. Treating therapists are being asked to write reports outlining the alternatives trialed to justify basic items such as community request cards or My Day books. Basic communication aids such as these do not require trials and this is an inefficient and costly use of the therapist’s time.

  • Challenged the number of communication aids a person can have

This is an issue for participants who require multiple communication aids to sufficiently support their communication needs. A person who uses a communication aid for one purpose may require a different communication aid for another purpose, people with Complex Communication Needs often require multiple communication aids to communicate autonomously. Importantly also, support people must have access to resources, advice and raining to fully support the person’s Complex Communication Needs.

The Victorian Government was committed to supplying adults with Complex Communication Needs

to non-electronic communication aids.

Over the past 13 years through block funding we have provided

over 1800 communication aids in Victoria alone. It is clear that the current barriers and challenges

that exist to access the same supports through the NDIS is proving to result in many less participants

accessing communication aids to support their participation in daily life.

Last year, under the block funded NECAS scheme, 272 customised communication aids were completed, while under the NDIS system running concurrently, only 11 have been provided. Despite NDIS not being fully implemented, the projected output over this same time frame is still significantly lower.

Possible factors:

  • Quotes take a long time to convert under NDIS (an average of 6.5 weeks from quote being accepted to starting production on the communication aids)

  • Confusion regarding access to funding

  • Lack of consistency amongst planners with regard to knowledge of non-electronic communication aids and what is deemed reasonable and necessary.

NECAS has also received feedback that therapists are using therapy funding to make communication aids. This was common practice for therapists prior to NDIS, but given current limitations on therapy hours, it is no longer an efficient or cost-effective use of funding for participants.

According to customer feedback and our data, it appears that different regions of Victoria inconsistently interpret the various NDIA documents (the NDIA Assistive Technology & Consumables Code Guide and the Assistive Technology Complexity Level Classification and the price guidelines).

Also, the support/training/information received by planners appears to differ across Victoria.

There is no dialogue with the NDIA regarding Assistive Technology. Planners and support coordinators receive information from the NDIA, however Scope has not received information directly as a provider of Assistive Technology services. There is a generic Agency contact for enquiries, which means communication starts again with every contact to the Agency.

This leads to the NDIA planners not understanding Assistive Technology and how it affects people’s lives.

There is inconsistent understanding of the role of the NDIA in approving requests for communication

aids. Non-electronic communication aids are a form of Assistive Technology. They include aids for

expressive communication (comprehensive and targeted), receptive communication, and aids that

support communication partners. All of these items are a form of Assistive Technology.

The guidelines for the funding tiers (as per the NDIA Assistive Technology & Consumables Code

Guide and the Assistive Technology Complexity Level Classification) under NDIS are not clear.

Currently the position is that some communication aids can be purchased through Core Supports as

low risk equipment (complexity levels one and two). Others are funded through the Assistive

Technology line item, which requires a quote and an assessment report.

An example where the current classifications do not apply:

Pragmatically Organised Dynamic Display (PODD) Communication Books are listed as a low risk item

and can be funded under Core Supports. However, evidence-based practice shows that a PODD book

is a complex, high-value item and the role of speech pathologists and their expertise is not currently

recognised under NDIS.

A PODD book takes on average 12 hours to manufacture and costs between $1000 and $2000, not

including the time spent on design and customisation. These numbers are even higher if a speech

cathologist were to make the book using hours funded for therapy.

As well as this, many of the aids funded under Core Supports will cost more than the $520 allowed

per item, or the $1500 total amount, especially if more than one communication aid is required. For

example, someone may require a PODD book as well as another type of communication aid.

NECAS has heard of issues with planners and local area coordinators regarding:

  • Communication aids are considered “school’s responsibility”.

  • Communication aids considered to be of lower cost than they are with a reluctance to

         accept quotes or provide unnecessary quote breakdowns.

  • Consistency of planners, such as some requests for quotes to be split into parts so that

         these fit under $520 for Core Supports, or request for quotes to be broken down to

     allow for separate line items to cover one communication aid.
  • Consistent and clear information provided directly to providers by NDIA
  • More training and support for NDIA planners regarding Assistive Technology and non- -electronic communication aids
  • Increased consultation between NDIA and service providers such as Scope
  • Participants’ plans adequately funded for Assistive Technology and core support consumables for the production of communication aids

Non-Electronic Communication Aids

Aid Name Description

Comprehensive Expressive Communication Aid

A communication aid can be used to help an individual send a message. These aids can add to, enhance or substitute a person’s verbal communication. It is described as comprehensive as it is expected to create communication autonomy - that is; allowing the individual “to say whatever (they) want to say to whoever (they) want to say it to, whenever and wherever (they) want to say it.” - Gayle Porter & Linda Burkhart

  • Alphabet Board Suitable for people who have literacy/spelling skills. These display the letters of the alphabet so messages can be spelt out. It can be designed specially to suit the person’s needs e.g. using either an ABC or QWERTY format.

  • Communication Book (multi- multi-level or multiple pages) Multi-level communication books are for people who can use a visual display or photos, pictures and/or written words for communication. This communication aid allows access to a large vocabulary, and provides a method or communication for people who cannot talk or whose speech is difficult to understand. Can be individualised with symbols, photos or words to represent people, places and objects. They can be categorised in different sections and levels.

Pragmatically Organised Dynamic Display (PODD)

PODD is a multi-level communication book to support expression and understanding of language for people with complex Communication Book PODD stands for: Pragmatic – the ways that we use language socially Organisation – words and symbols arranged in a systematic way Dynamic Display – changing pages There are many different types of PODDs, so the one to use will depend on the communication needs of the individual. Everyone has different communication preferences and abilities. This is why PODDS can have different formats, depending on the individual physical, sensory and communication needs of the user.

  • Communication Board Communication boards are for people who can use a visual display of photos, pictures and/or written words for communication. The purpose of a communication display is to provide a method of communication for people who cannot talk or whose speech is difficult to understand. These aids are detailed and made specifically to suit the person’s individual needs and specific situations.

Targeted Expressive Communication Aid

A communication aid that can be used to help an individual send a message. These aids can add to, enhance or substitute a person’s verbal communication. Targeted aids allow an individual to communicate effectively within in given situation, routine or about a specific topic.

Community Request Cards Community request cards are used by a person who cannot speak

or who are difficult to understand. The cards are used to request items and services in the community. Instead of using speech to request an item or a service, the person gives or shows the card for the other person to read. The content on the card outlines what is wanted with all the details needed for their request to be met.

Object Symbols

Object symbols may be suitable for people who can understand that whole or parts of real objects can represent things, activities or events. The objects selected need to look, feel or have something to do with the item or activity they represent e.g. a piece of towel that smells like chlorine for swimming. Object symbols can be used for making choices. Instead of using real objects, object symbols representing items or activities are offered for the person to choose between, e.g., hairbrush = please brush my hair, hand lotion = please give me a hand massage. Object symbols can also be used to help the person understand what is going to happen in their day. Daily or weekly events and routines may be identified by the object symbol associated with the event or activity, e.g., purse = shopping; seat belt buckle = go in the car.

Shopping Lists

A shopping book or list allows a person to pre-plan what he or she wants to buy, or indicate if he or she wants something extra or different. Shopping lists need to be individualised to contain grocery and personal items for each individual.

Chores Chart

It may be useful for a person to have visual support or cue to remind him or her what jobs need to be done at home or work. A chores chart has been designed with photos or pictures to show the daily or weekly tasks within the home or work environment.

Who’s here today?

A ‘who’s here today’ chart displays the whereabouts of different people. It prepares a person for who they should expect to see, any changes that occur unexpectedly, and reasons why staff or others are away.

Picture stories/Social stories

Picture stories or social stories are tools to help individuals better understand a specific social situation and how to they can interact in an effective and appropriate manner. It supports an individual to participate in their world and undertake safe and meaningful exchanges.

Communication Aids for Communication Partners

A communication aid that can be used to provide information about an individual. These aids support communication partners in understanding, interacting and communicating effectively with people with complex communication needs.

Personal Communication Dictionary (PCD)

A PCD is a sheet that records what a person does (person’s individual gestures, body language, facial expressions, vocalisations and/or signs); what this means; and what the role the communication partner can play (it may also record when and where the behaviours may be seen). A gesture dictionary is similar and outlines all the manual signs and gestures that the person understands or uses to communicate.

####### Book About Me A ‘book about me’ is useful for communication partners or support people. It contains current information about a person’s needs and abilities and interests. Provides information about the person’s daily routine, what he or she can do independently and where her or she might need assistance.

######## Personal History Provides communication partners with information and photos about a person’s life and family history. Can be used as a conversation starter or to get to know a person.