AT Senate Inquiry – Submission Permobil Australia

First of all, thank you for the opportunity to provide feedback regards the implementation, performance and governance of the National Disability Insurance Scheme (NDIS). Within our organisation we have three NDIS participants and we know that the NDIS has been overall very positive for them.

Permobil Australia acts as a distributor, and as such has daily contact with end users, terapy, dealers and the NDIA. We hear a lot of feedback that is positive regards the NDIS from all stakeholders, but also hear a lot of frustration. The nature of this type of forum to provide feedback often results in the negatives being emphasised, so it can give the impression that there is nothing positive happening. This is certainly not what our intention

is, or what the feedback is saying.

We have also found the NDIA employees to be accessible, available, and helpful when we have had reason to contact the NDIA. We want to acknowledge that we appreciate their efforts and desire to have great results for participants.

We also recognise that the NDIS is a major and significant initiative requiring huge resources. We greatly appreciate the efforts and strides that have been made in making the NDIS the worldwide gold standard for provision of services, support and equipment for people impacted by disabilities.

We would like to focus on the areas of “particular reference” you list on the submission website, namely:

a. the transition to the NDIS and how this has impacted on speed of equipment provision; b. whether market-based issues impact the accessibility, timeliness, diversity and availability of assistive technology; c. the role of the NDIA in approving equipment requests; d. the role of current state and territory programs in the assistive technology process;

e. any other related matters.

It is worth noting here that we, Permobil Australia, deal predominantly in the complex Assistive Technology category, and our response reflects feedback from our own staff and

their experiences but also feedback from Therapists and Dealers and our own experiences as a Distributor/Manufacturer.

Areas of Particular Reference

a. The transition to the NDIS and how this has impacted on speed of equipment provision;

In the lead up to the implementation and roll out of the NDIS we held great hope that the speed of equipment provision would be greatly improved. Under the previous state-based systems we had seen periods where speed was quick, but for the majority of time the provision was not adequate.

Unfortunately, there has not been an improvement in the speed of provision of equipment.

In many cases we are finding that it is significantly worse under the NDIS.

From our perspective we see a number of contributing factors for this, including:

• A large number of NDIA planners/LAC do not have good knowledge of what Assistive Technology is available, how different conditions impact on participants, and how to facilitate a good plan to begin with.
• Participants are often not educated or given information in the lead up to their planning meeting on what will help expediate supply of equipment. For example, if participants are aware of an equipment requirement they have and are advised prior to the planning meeting to get some pricing then the submission of the plan for approval can include those estimates with the equipment listed and budgeted for. We also see that some of the plans do not cover off the requirement for repairs and maintenance. Expensive Assistive Technology, particularly wheel chairs, require regular repairs and maintenance. This needs to be factored into a plan.
• During the development of a plan, the planner/LAC meets with the participant to go through a set of questions to help develop the plan. At the end of the planning session the participant is not given a copy of the assessment to sign off on, so is not sure what is being submitted on their behalf. Feedback is that this can cause inaccurate submissions which cause delays as the participant then needs to lodge an appeal for adjustment, which results in a wait time up to 3 months.
• There appears to be a shortage of Occupational Therapists with the necessary skills to properly access and recommend complex Assistive Technology needs. This creates a back log of participants waiting for assessments.
• We have found that often the reports therapists put together do not link the Assistive Technology to the goals of the participant. Many therapists are still writing the reports with a focus on “clinical requirements” without linking the equipment to goals, which results in the applications being rejected by the NDIA. When the reports

are rewritten linking the equipment to the participants goals the review approves

equipment. However, this process can take months. 6. Added to the above, therapists are reporting frustration with the report templates they are required to fill out and submit. The format does not allow adequate scope for providing information resulting in therapists feeling they can answer all the questions but still feel like they have not been given adequate opportunity to highlight how essential the Assistive Technology is. The report needs to be redesigned with consultation from therapists. 7. The NDIA reviewers quite often do not have adequate knowledge of what the various conditions that cause disability are, the impact they have on a person’s life or what Assistive Technology is available to fulfil needs. This has resulted in rejection of applications which again require a request for review, which adds time to the provision of the equipment. 8. The time between a provision application and the assessment of that application can be up to 6 months, even if there is no review request. We are unsure of the exact reason for this, could be a shortage of NDIA reviewers, delays caused by the issues already raised, other reasons, or a combination of it all. 9. A long delay can result in another trial or measure and quote to be completed. Whilst necessary, it adds cost to the process and the only person remunerated for this is the therapist. The same situation applies when quotes are shopped around.

b. Whether market-based issues impact the accessibility, timeliness, diversity and availability of assistive technology;

Some of this is covered in our feedback regards point a of this submission. In addition to those points:

1. There is no doubt that there is fantastic assistive technology available in other parts of the world that are difficult to justify from a business perspective in the Australian market context. This is due to a relatively small population, which is spread over a huge area. In larger population countries the market for these products, while relatively small, are large enough to allow investment in their provision to be viable. With the low volume potential, and the cost of support/trial/maintenance/warranty they are just not viable here in Australia.
2. The cost of equipment trials, expert sales consultants, a shortage of skilled therapists in the complex rehab area and the hit and miss success of approval applications

c. The role of the NDIA in approving equipment requests;

1. We are finding our staff spending a significant amount of time with therapists/end users who have had equipment requests rejected. Some of this is caused by therapists not being skilled report writers, hence failing to link the equipment to the NDIS plan goals and/or failing to quantify how equipment can empower the participant and reduce costs in other areas such as the need to assistance.
2. Many times, it is the assessors within the NDIA that do not have enough knowledge about what the Assistive Technology is, what the challenges of specific conditions such as spinal cord injury or MND are, and how these two factors intertwine to provide a reasonable and necessary piece of equipment.
3. We are also finding that assessors, who appear to have very limited knowledge of Assistive Technology and conditions will over rule the expert advice of Occupational Therapists. This has been a cause of frustration and we know of several skilled Occupational Therapists who now refuse to do NDIS related work.
4. The time from application to approval can be significant. We don’t understand why this should be the case given the amount of work going into assessment and application report writing.

d. The role of current state and territory programs in the assistive technology process;

This has been a point of significant frustration, particularly in NSW, Victoria and now Queensland. When organisations such as Enable, SWEP and now MASS have been engaged to do NDIA work. They have maintained their old culture as “gate keepers” to funds, rather than embracing the principles of the NDIS…. In particular ‘Choice and control’, and ‘goals’ of the End Users, which are fundamental. It also potentially adds significant cost to the end offering for no real benefit.

e. Any other related matters.

From a business perspective, we were, and remain, excited about the NDIS. We have invested in having a business model that is very end user focused. We have also invested heavily into infrastructure that will ensure we:

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Have a large fleet of equipment available for trial and assessment

• Are prompt with the above equipment
• Can provide quotes for even the most complex equipment within 48 hours
• Have expert and well trained consultants to assist with assessments when required
• Have a large inventory of non-customised equipment and spare parts
• Permobil also manufactures many of the products we sell. At the manufacturing end the investment into quality control and speedy build times is significant as we know the equipment is critical for the wellbeing of the end user and is often needed before approval for funding is given.

Due to the delays in the current system many of these innovations and investments are negated. For example, we can get a quote out within 48 hours but often it takes weeks or months before the Therapist writes the report and lodges it. It can then take weeks or months for approval. In our view, the current slowness of the system does not provide an incentive to invest in innovation that streamlines the supply chain as it is negated by time delays with the NDIS/NDIA process. In a way the current system rewards poor service, while punishing good service.

Permobil has new ‘connected technology’ available to assist Dealers, Therapists and End Users in maximising their Permobil experience, particularly in Power Wheelchairs, but unless it is understood by all involved in the Planning and Provisioning process cannot and will not be leveraged. We see this sort of thing as essential in enhancing the Permobil value proposition to the NDIA.

Direct End user Feedback

The following is based on feedback from end users, and as the NDIS is an end user focussed scheme we believe it is worth including.

1. There remains confusion regards funding categories within the participant’s plan. How the funds can be spent is not always explained or clear.
2. The current NDIS portal is inadequate, and not designed to be accessible for all types of conditions. The funding categories in the Portal do not always match the terminology within the participant’s plan, which causes further confusion.
3. Phone calls to the NDIA for clarification can result in different answers from different consultants.