Parliamentary Inquiry NDIS Assistive Technology

e): the transition to the NDIS and how this has impacted on speed of equipment provision;

The transition to the NDIS has significantly impacted on the speed and efficacy of equipment provision, and in several cases caused risk to participants awaiting essential services. In NSW there is only one provider of equipment – Enable NSW which is a state government health operated organisation. Participants are required, in this region, to have their AT equipment NDIA agency managed. This means that participants are not permitted to self-manage or plan manage to enable ‘choice’ of suppliers to provide their equipment. As the sole supplier in NSW, Enable is in the unique position of being able to add a substantial surcharge of 15 % for the supply of equipment, which increases the cost of the item supplied, and this is paid for by the NDIS. This effectively results in federal funds supporting a state-based organisation. I believe the agreement between the NDIA and Enable NSW, as the sole supplier of equipment, negates choice and control for participants and is contra to the principles of the Act 2013-Ch 3 P 2 Section 43.

f): whether the estimated demand for equipment to be sourced through the assistive technology process in each roll out area was accurate;

Regarding this point of discussion, I am unsure of what the estimated demand for equipment was in this region so am unable to determine the accuracy of the estimate. I am certain that the current waiting period for replacement equipment, such as wheelchairs for high support need participants, should not be, as is current practice, exceeding 15 months. There is a participant whose pressure care injuries are a direct result of delays in providing replacement equipment and has been hospitalised several times this year because of it. He has now progressed into a high risk of injury participant.

c) whether market-based issues impact the accessibility, timeliness, diversity and availability of assistive technology;

Yes, as mentioned above, the contractual agreement between the NDIA and Enable NSW, and the restriction by the agency to allow participants choice of providers, is impacting on other assistive technology service providers. The objects and principles of the Act Section 3 (g) to promote the provision of high quality and innovative supports that enable people with disability to maximise independent lifestyles and full inclusion in the community is not being realised.

There is a participant who is visually impaired and works 5 days per week at an Australian Disability Enterprise (ADE). He has a range of vision assistive equipment he uses. The equipment he uses at home is dissimilar to equipment required in his work environment, however, this young man is unable to independently access the community. His request and subsequent assessment submission from a qualified occupational therapist for visual equipment to assist him to access the community has been declined. The NDIA would prefer to fund him with a support person for community access rather than grant him permission to purchase innovative technology such as the OrCam MyEye, which would provide independent community access, facilitate independent travel and create the potential for employment in the open job market. The OrCam MyEye is not supplied by Enable but is supplied and fitted by Vision Australia and, according to agency delegates from the NDIA, does not meet the criteria for reasonable and necessary. This does not appear to be in line with the principles of the Act 2013 Section 3: (g).

d) the role of the NDIA in approving equipment requests;

Significant improvements in the delivery of basic Level 1 and standard Level 2 AT has recently been implemented by the NDIA. Funding for these items is now added to the core support budget under consumables which permits participants to purchase AT that doesn’t require a therapist assessment. However, participants must be able to project and identify exactly what they may need over the course of a 12 or 24 month period before it is approved. This is difficult to realise as auxiliary parts or equipment only require replacement when the need arises. The substantial delays in approving AT requests are with Level 3 and Level 4 AT.

Role Of Ndia

The role of the NDIA is to determine whether an AT equipment request meets the criteria of Reasonable and Necessary as outlined in the Act 2013 – Ch 3 Section 34.

Participants are required to engage a specialist therapist, such as occupational or speech therapist, to assess and subsequently submit a General Assistive Technology assessment template to agency for approval. Once the request is received LAC’s and agency planners are required to scrutinise the therapist’s report to determine whether information submitted meets all parts of the Act Section 34 criteria.

Furthermore, assessments by therapists must provide evidence of trials, age of current equipment, alternative (yet similar) equipment trials and if the requested item is over a specific benchmark price, mandatory or a Level 3 & 4 request, a written request must be lodged with the NDIA specialist team for approval. This process takes up to 6 weeks.

Once a request for advice is returned to the NDIA delegate considers it but is not bound by its findings. Even if the advice agrees with the AT request and therapist report the local NDIA delegate can reject the request. In our region the majority of all AT requests are rejected on the grounds the therapist report does not meet Section 34 criteria.

I am aware of a participant who waited for 15 months for his wheelchair to be approved, hhowever, he is unable to enter and exit his home safely due to the NDIS declining his home modification request for an access lift or ramp. In regional Australia there are insufficient providers of services to enable participants to gather multiple quotes for home modifications. It is not uncommon for there to be only one registered provider in a regional area who can do a home modification assessment and limited registered providers for quotes. This impacts on the ability of participants to provide multiple quotes. If a participant who has not had previous AT, makes a request to add AT into a plan, it requires the submission of a plan review and the review process is currently taking upward of 6 months.

The NDIA delegates in this region who make decisions whether to accept or decline a request for AT equipment are not qualified in either therapeutic or disability disciplines. There are immense delays and numerous review requests to include AT backlogged, wating for approval in the system and most requests are declined. The lengthy delays result in quotes expiring and the participant being requested to resubmit documents.

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This also impacts on the qualified therapists in the scheme. A large number of requests

are being declined. Many therapists are becoming despondent in supporting their

clients as it gives the impression they are not doing their jobs effectively when

participants are required to provide further assessments, reports and evidence to

resubmit their application and return to the queue. I am aware of occupational therapists

exiting the scheme, due to low success rates of their AT assessments.

I believe that an analysis of how AT assessments are processed and approved is |required and that the responsibility should be removed from an individual hub or |regional platform to a centralised specialist team across the entire footprint of the |NDIS. This would create additional staff working on the back log of review requests, |rather than AT requests. Considering the dearth of qualified therapists registered to |provide support and assessments to participants (particularly in regional areas) a |greater respect for their qualifications is required by NDIA delegates.

f): whether the regulatory frameworks governing assistive technology are fit-for-purpose, and

When deciding whether a request for AT meets the criteria of Act Section 34 NDIA delegates are required to apply the reasonable and necessary criteria. Section 34 is ambiguous in wording and does not consider risk as a prioritised factor. Risk of harm from ill fitting AT results in individuals being hospitalised. LAC’s and NDIA delegates do not hold the qualifications to review reports of qualified therapists and should not be placed in a position to do so.

a. any other related matters.

There are several concerning factors to consider. There is not a Nationally consistent application of processes, each regional ‘hub’ has a dissimilar process. A Nationally consistent approach to processes must be implemented to ensure scheme integrity. A good example of this is the inability of participants in this region to self- mange their AT and Home modifications.

The process of adding or editing a participant plan to add or change supports requires a review. The review process is very lengthy (over 6 months). This is being addressed by the agency but there is still insufficient staff employed to manage the demand within a timely manner.

In regional NSW participants are having their subsequent plan’s support funding

reduced if they were unable to connect to service providers in their first plan and this

is causing distress to participants who are limited by suppliers in the area. For

example, in this region it is a minimum waiting time of 6 months to procure speech,

occupational and behavioural therapy services. The volume of underutilised supports

returned to the agency is momentous, the NDIS scheme cannot be operating over

budget.

In summation, choice and control is being denied to many participants due to NDIA

staff making decisions on what they perceive is best suited for a participant, but is

not necessarily in line with the integrity of the Act 2013 and the operational

guidelines.