Joint Standing Committee on NDIS: Assistive Technology

14th September 2018

Cerebral Palsy Alliance is a large not for profit service provider in NSW and ACT delivering services to people with cerebral palsy and other neurological disabilities. Assessment, prescription of assistive technology and intervention using assistive technology is a core part of Cerebral Palsy Alliance’s business. People with complex disabilities require essential assistive technology (AT) to support their independence, participation and quality of life. Essential AT equipment includes items such as wheelchairs and other mobility devices, standing frames, communication devices, personal care equipment such as commodes and shower chairs, and specialist orthotics. Please see responses below according to a number of the terms of reference outlined.

The transition to the NDIS and how this has impacted on speed of equipment provision:

• The NDIA has demonstrated a lack of understanding of issues around AT prescription for complex clients which has resulted in a greater amount of time and cost to the participant to address questions and requests of the NDIA to provide further evidence of an AT prescription when it has been thoroughly clinically justified according to the participants goals in their plan on the original AT application. An example of this is the requirement to procure multiple quotes for items where there is only 1 supplier of the item in question or where the participant has specifically chosen the supplier of their choice such as in custom moulded seating.
• The NDIA is allocating limited funding for complex clients who have high cost equipment recommendations e.g. Alternative or Augmentative Communication (AAC) and complex seating and mobility requirements, this is significantly delaying intervention using this equipment such as communication development.
• There is a significant delay experienced in the approval of AT applications lodged with the NDIA-equipment approval timeframes are varied but can be more than 6 months even for clients with degenerative conditions.
• Due to the time delay in funding AT, often a client needs the equipment reviewed prior to ordering due to growth or changes in posture or function. There is not a clear process to alter the piece of AT required. When a piece of equipment does need to be altered due to the above changes, there is another time delay in approving and funding the equipment.
• There have been many instances where an NDIA planner has declined an application for AT on the basis of a restrictive practice, despite evidence provided by the therapists that they have gone through the appropriate RP process and the AT in question has been deemed to NOT be a restrictive practice. This is causing significant delays and stress to participants and their families
• Full AT applications are required to be written for a straight replacement of assistive technology such as Ankle Foot Orthoses (AFOs). This costs the participant money and the therapist time completing a full report, when it is not clinically justified. It also results in delayed equipment provision for the child requiring these orthoses.

The role of the NDIA in approving equipment requests:

• The NDIAs Assistive technology application form is difficult to use with regards to formatting and sections repeat themselves and are not clear on the information the section is seeking
• There is not a clear process across all NDIS regions in regards to submitting an AT application: ie: via email or portal and who should be submitting the AT application: therapists or participants
• There is a lack of communication once an AT application has been submitted in regards to the receipt of that application, its progress and outcome.
• For our more complex clients where seating has been declined because NDIA are wanting providers to provide two quotes – apart from being time consuming and inefficient with the costs being paid for by the participant out of another section of their NDIS plan, it is also not always possible to do this as different suppliers often don’t stock similar chairs.

• NDIA planners are often requesting for certain piece of AT to have extended trials, such as standing frames to ensure the participant gains benefit from this piece of equipment. The piece of AT is clinically justified and its benefits evidence based, thoroughly trialled and the results clearly stated in the AT funding application. Extended trials are often not possible due to equipment shortage and suppliers not offering this service.
• AT applications are being declined when a piece of AT will directly benefit a client’s caregiver from a manual handling perspective. Eg: Powered and power assist wheelchairs. This has direct impacts on the client as they may be denied access to lifestyles programs due to manual handling concerns
• Lack of consistent messaging in regards to AT approval and reasons for AT not being approved. AT approval/rejections vary between NDIS office and NDIS planner.
• Benchmark pricing is applied to a number of pieces of AT, however participants often need pieces of AT that are highly specialised and have custom features that extends beyond the benchmark. The AT is often declined for the sole reason that it is above the benchmark pricing, even though the increase is clinically justified.

Any other related matters

• There is not a clear process for when a client requires a piece of AT urgently due to safety concerns
• Benchmark pricing is generally lower than many standard and accepted pieces of AT on the market
• The expectation that a participant has all required pieces of AT already quoted for and submitted at the time of a new plan so the AT request does not trigger a plan review is not a realistic assessment of the participants needs and priorities. This requirement also does not acknowledge or plan for a participants needs changing over the period of their plan.
• For participants who do have AT funding nominated in their plan, the ‘cost as outlined in the AT price guide’ is included which is often ‘basic equipment’ so even if the item has been flagged the budget is often insufficient which triggers a plan review

Impact on Participants

• Unacceptable delays for essential equipment therefore impacting on independence and participation
• Frustration and distress when they do not have access to daily personal equipment they need
• Increased potential for their function to deteriorate and increased caring responsibilities on parents or carers that is beyond ‘reasonable and necessary informal supports’
• Potential health and safety concerns due to them not having the equipment they require
• Potential delays in children’s development due to them not having the AT they require. Eg: AAC, Powered mobility, walking aids
• Greater cost to the participant needing to spend more of their therapy money for AT prescription to gain multiple quotes for the same piece of AT, therefore decreasing their potential for functional gains in their goal areas

Impact on Service Provider

• Administrative cost burden due to inadequate processes and decision making – increasing the time, administration and coordination efforts to resolve these issues of behalf of participants
• Greater amount of time and therefore cost to service provider of therapists required to answer questions from NDIA planners or further explore AT options that have already been clinically discounted and/or further justify a piece of AT that has already been clinically justified and all reasoning outlined in the AT report
• Intermediary between NDIA, suppliers and client – typically participants will seek out support from their provider to expedite the matters especially if it is hindering their ability to leave their

Proposed Solutions

• Develop more robust and sensitive planning tools to ensure that the NDIA includes essential and necessary items in the participants plan - whilst is it important for participants to self-direct their goals and aspirations, there needs to be adequate safeguards within the planning process to ensure that essential support items are not missed and inadequately funded - there appears to be a heavy reliance on clients and/or their immediate informal supports to be across all of these needs
• Develop reference packages for AT - work with agencies like Enable to profile people with specific disabilities to support NDIA and clients understand and anticipate the likely equipment needs and average funding packages they will require across their lifetime
• Improve communication with participants and providers
• Improve decision making methodologies and eligibility criteria to speed up processing time