27 November 2018

Committee Chair:

The Hon. Kevin Andrews MP

Joint Standing Committee on the National Disability Insurance Scheme

P.O. Box 6100 Parliament House CANBERRA ACT 2600

dear sir

to: The Joint Standing Committee on the National Disability Insurance Scheme – Assistive Technology (Melbourne Public Hearing 22nd Nov 2018).

The State-wide Equipment Program (SWEP) is grateful for the opportunity to provide clarification regarding a number of discussion points raised during the course of the proceedings at the Public Hearing that may assist the Committee in their findings and subsequent recommendations.

We note that when the Commonwealth funded ‘Program of Aids for Disabled People’ was handed over to the States and Territories in 1981, each jurisdiction ‘tailored’ their programs to meet the needs of their jurisdiction, maintaining the overarching goal to support people who have a long term disability and/or are frail aged with subsidised aids, equipment and home and vehicle modifications to enhance their independence, facilitate community participation, and reduce carer burden.

In Victoria, the program was rebranded as the ‘Aids & Equipment Program’ and in 2010 was outsourced by the Victorian Government to Ballarat Health Services who manages the state-wide service under the umbrella of the ‘State-wide Equipment Program (SWEP).’

In addition to management of the State-funded programs, during the first three years of trial phase, SWEP was nominated by the State Government as an ‘in-kind’ service provider to the NDIS as were most of the other State/Territory jurisdictions. Post 2016 in Victoria, SWEP has negotiated formal ‘Working Arrangements’ with the NDIA in recognition of ‘value-add’ elements of our model that the Agency considered worthy to leverage from. More information about some of these elements will be explained in more detail in this response that may provide clarification for the Joint Standing Committee about the State/Territory schemes’ capacity to support the NDIA with provision of AT for NDIS participants.

to date, this financial year SWEP is working within an informal ‘business as usual arrangement’ with the agency pending ongoing discussions to formalise these arrangements for the remainder of the financial year. For the first time, SWEP has been challenged this financial year to retain a workforce and

Clarification Facts

Robust Registration and Credentialing Framework and Practitioner Accountability

Since 2012, SWEP has implemented a Prescriber Registration and Credentialing Framework that respects professional qualifications of practitioners / prescribers and recognises advanced prescriber knowledge and skills.

This framework supports accurate and client-appropriate prescriptions, prescriber accountability and provides support for novice prescribers. The credentialing component recognises the complex interactions of the skills of the practitioner, the client or participants characteristics and contributing factors, and the complexity of AT items.

This does not replace nor supplant professional registration or professional association standards but supports the maintenance of professional registration requirements within a prescriber’s chosen scope of practice (i.e. assessment and prescription of Assistive Technology); nor does it impose regulation outside the SWEP environment.

SWEP credentialed prescribers are allocated a traffic light colour for each AT category which relates to their formal qualification (threshold credentials), years of experience, frequency of prescribing AT and continuing professional development (CPD). A ‘white’ prescriber provides administrative support to registered prescribers only, they cannot prescribe. A ‘green’ prescriber can prescribe AT for clients that is considered non-complex. An ‘amber’ prescriber will have a higher level of expertise and experience, while a ‘red’ prescriber is recognised as an expert in their field. These prescribers will provide support to complex clients who have more complicated AT needs. Within the credentialing framework there is the capacity for less experienced prescribers (i.e green) to prescribe for more complex clients or AT items (i.e. amber or red), with the support of a more experienced prescriber.

Framework for Prescribing Assistive Technology

We currently have over 8,000 prescribers registered with SWEP across the disciplines of occupational therapists, physiotherapists, orthotists, podiatrists, speech pathologists, continence nurses and respiratory physicians.

The framework establishes:

Threshold credentials for each AT category
Performance expectations of prescribers at each level (green, amber and red)
Client characteristics that may impact prescription
Robust, accountable and credible system that defines standards of competence
A matrix for categorisation of AT, client and prescriber
Standards for minimum requirements for registration

In addition, our framework provides registration pathways for:

Inexperienced prescribers
prescribers upgrading credentialing level
prescribers re-credentialing at the same level
experienced prescribers registering for the first time as an

The Framework also supports the following:

CPD activity guidelines
CPD prescriber point values
CPD summary portfolio
application forms for the pathways described

This framework ensures a robust, accountable and credible system, reduces inconsistencies and errors in prescribing, and has defined the standard levels of competence resulting in the highest quality assessments to ensure people receive the right AT to meet their needs.

Where there are ‘thin’ markets in regional and rural areas, inexperienced prescribers are still able to prescribe, supported by either a higher credentialed mentor prescriber within the region, or by the SWEP Clinical Advisory Panel which is explained in Point 2 (Assessor Support).

SWEP has an ongoing commitment to a competency-based education model supporting prescribers in evidence-based prescription. SWEP offers endorsement of education as part of our continuous professional development program; and aligns with the regulatory body’s registration requirements.

This educational model ensures a prescribing workforce who have relevant expertise, and a clear understanding of the legislative frameworks including concepts such as “Reasonable and Necessary”.

We have built mutually respectful relationships with relevant Professional Associations to ensure we are working together to enhance skills and knowledge of prescriber base.

Assessor Support

A Chief Allied Health Officer (CAHO) and a Clinical Advisory Panel has been contracted consisting of highly skilled, recognised and credible professionals from the Allied Health, Continence Nurse and Respiratory Physician disciplines with particular knowledge and skills across equipment categories and/or expertise in both adults and children’s AT.

Infrastructure & Governance Framework

The SWEP service delivery model is underpinned by a governance framework with a clinical overlay that ensures a non-clinical administration team can manage applications submitted by allied health/medical practitioners, with in-built automated functionality to check prescriber registration status and ensure that non-clinical staff do not undermine recommendations of our assessors.

Applications by assessors are submitted into a purpose built online web portal that automatically checks prescriber registration status.

This framework ensures equity of allocation of funds/AT based on urgency of need, enables communication channels with stakeholders, has robust and transparent budget and demand strategies, has established picklists and catalogues and standardised assessor templates.

Each year, a team of ~60 staff arrange supply of over 50,000 goods and services for nearly 30,000 clients. This team accepts over 30,000 applications from over 8,000 registered prescribers and take over 90,000 incoming phone calls per annum. Approximately 70% of these clients are funded by the State, and the remaining 30% are NDIS participants, however over 40% of applications received by SWEP are for NDIS participants.

Template assessor forms (AT prescription forms) have been developed within a risk management context, requiring the assessor to consider implications of non-provision against the paradigms of safety, independence, health maintenance and carer burden to ensure those people who need support most urgently are readily identified. Relevant client characteristics that may impact on the credentialing level required are considered, along with other critical information that will enable a non-clinical staff member to process the application without undermining the expertise of the assessor. SWEP has worked closely with funders including the NDIA to ensure essential data is captured to enable ‘reasonable and necessary’ decisions, without the requirement for additional information.

Repairs

SWEP recognises that many AT consumers require support 24/7, and as such, provides a unique, equitable and valued support service regardless of geographical location 365 days per year.

Within the model SWEP triages response timeframes based on AT consumer need rather than repairer availability, and KPI’s are built into contractual agreements and monitored closely.

SWEP has implemented viability rules to ensure that AT is replaced when no longer viable to repair and that loan equipment is provided where necessary.

The model also facilitates identification of design faults leading to influencing manufacture design changes, education for service users to avoid repetitive AT failure, and salvages reusable parts from AT no longer viable to maintain.

Common spare parts are readily available to fast track repairs.

Refurbished Equipment

SWEP assets in the State-funded schemes which are no longer required by a client are returned to SWEP. The item undergoes a viability check to determine ‘reusability’ prior to being refurbished to a high standard.

There is no wait time for access to our reissue asset pool (other than time taken to refurbish or modify AT) to meet individual consumer needs.

This service operates out of a central warehouse in the metropolitan area, and prescribers have access to both clinical and technical expertise to custom build from reissue componentry as well as assist with identification of suitable assets for clients.

An online state-wide reissue database provides details of AT and provision for SWEP registered prescribers to search, view and reserve assets for their clients prior to submission of an application to SWEP.

This service enables both on and off-site access to items during the trial phase for any consumers, regardless of their location in the State.

The value of the refurbishment model to SWEP has been >$3M per annum in savings (approx. 15% of total budget spend) with an average of 2,500 items reissued each year. This percentage will increase as State funded budgets reduce as the NDIS rolls out in Victoria. Indicative savings achieved by refurbishing AT are evidenced in the table below, representative of actual wheelchairs that have been reissued to SWEP clients in the last six months.

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Item Details

Item	Age	Current Price (New)	Current Price (Second hand)	Savings
Quickie Iris manual customised wheelchair	4 years	~ $11,000	$1,256	$9,744
Quickie 2 manual customised wheelchair	2 years	~$6,500	$1,247	$5,253
QM710 customised power wheelchair & specialised backrest	2 years	~$14,000	$3,666	$10,334
Q6 Edge 2 customised power wheelchair	1 year	~$18,500	$2,935	$15,565

Table 1: SWEP Cost Comparisons of Supply Reissue v New Wheelchairs

The repairs and reissue models are sophisticated, integrated, and inextricably linked between SWEP and the contracted service provider with a fleet of mobile workshops/vans that ensure coverage of the entire State of Victoria.

Photos of the warehouse below are indicative of the volume we ‘recycle’, with over 1,500 items in stock at any one time. Storage costs have been minimised by reducing AT footprint, with four-tiered shelving.

Image 1: Three function beds folding beds

Located: Postal Address: 23 Wetlands Drive P.O. Box 1993 Mt. Helen. 3350 Bakery Hill BC

Image 2: Storage of hoists, manual wheelchairs, strollers & rise recline lift chairs

Image 3: Custom fitted delivery van with scooter

The initial intention of this model was that regardless of original fund type, assets could be reissued to any SWEP clients, however agreement about this would need to be reached by both the Commonwealth & State Governments.

6. Priority of Access

SWEP is committed to ensuring that subsidy is allocated to our consumers in a priority order based on transparent guidelines. Key characteristics of consumers and their support people influence priority of access. The intention of this framework is to provide stakeholders with an understanding of the order in which consumers will receive access to services and supports, as well as to provide reassurance that our program is committed to enhancing safety, independence, community access and psycho-social wellbeing.

In order to consider the potential implications of non-provision, or delayed response, SWEP has developed a risk management approach to prioritisation based on the AS/NZ ISO 31000:2009 Risk Management – Principles and Guidelines. Risk to consumers based on potential consequence is assessed in a context of relative likelihood. Articulation of risk is intended to guide SWEP as to the level of urgency.

This framework has been adapted to inform NDIA Planners when SWEP submits applications to the Agency on behalf of participants to readily identify those most urgently in need of supports.

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It is important to note, although not directly relevant to the NDIS participants, that SWEP has implemented a budget and demand management tool that is agile and ensures program capacity to respond to urgent applications at any time in line with the priority of access framework. Monthly sub-budgets are set for each AT category, with a percentage allocated to repairs, reissue, and high and low priority applications. This strategy ensures that there is an equitable access to funding regardless of AT type, and also ensures that those people who have been waiting for support the longest, regardless of priority can still benefit.

In Table 2, a case study outlines the State and Commonwealth schemes response timeframes for urgent provision of highly customised powered wheelchairs, noting that the State scheme case study relates to provision of a refurbished power wheelchair.

Process	State funded Scheme (Victoria)	NDIS
Identification of suitable item	01/10/18	06/10/17
Application received by SWEP	02/10/18	09/10/17
Quality assurance check undertaken by SWEP	05/10/18	11/10/17
Application sent to NDIA for R&N decision	N/A	11/10/17
Approval to order received from NDIA	N/A	26/02/18
Order placed	09/10/18	26/02/18
Wheelchair modifications & build commenced	10/10/18	unknown
Item delivered to participant	19/11/18	09/07/18
TOTAL TIME TAKEN	49 days	277 days

Table 2: Case Study comparison between State & NDIS AT systems for urgent AT access

Strategic Procurement

Given SWEP procures a significant proportion of assistive technology in a retail environment, price increases (influenced by factors such as currency exchange rate fluctuations, technological advances and (potentially) increased demand driven by NDIS) lead to contraction in ‘buying power’ and create its own pressures for innovative, robust approaches to procurement.

Since its inception, SWEP has actively pursued better outcomes for our AT users from strategic procurement. SWEP encourages choice and control in AT selection within the parameters of safety, functionality and durability within the funding body’s requirements for dignity of personal risk for consumers. Wherever possible, SWEP now offers its’ consumers a range of items within each AT category.

In line with competitive tendering and best practice procurement SWEP has an overarching strategic procurement plan within a corporate governance framework. This robust and transparent procurement approach ensures that AT is supplied providing best value for money. This approach considers supplier capability, legislative and relevant standards compliance and a robust selection process, ensuring that AT is suitable and fit for purpose, quality and durability tested, adjustable, easy to clean and maintain, has clear warranty arrangements, is ‘reissue-able’ (if appropriate), includes delivery KPI’s, availability of spare parts, warranty, installation and education, at the best price.

Responses are assessed by Evaluation Panels including key stakeholders against (weighted) selection criteria that critiques capability of tenderer prior to the actual assessment of goods and services offered or pricing or the consideration of pricing.

Contractual Arrangements

These contractual arrangements have ensured SWEP has access to AT at significant discount to retail prices for all items. Savings across all contracted items have resulted in ~$2.5M pa (approx. 7% of total budget and up to 50% of some specific AT product ranges) which has resulted in more people being able to be supported within the same budget. These advantages can be leveraged for all AT consumers who access AT through SWEP systems where contracted items are selected. Our experience has been that outside of formal contractual agreements, suppliers charge retail price regardless of volume of items purchased.

This also reduces assessment timeframe for prescribers with the introduction of a SWEP catalogue that includes a standardised picklist list of AT and negates the need for supplier quotes.

SWEP procurement processes are transparent and consistent with Victorian Government Purchasing Board (VGPB) requirements, with Expressions of Interest (EOI) and Requests for Tender (RFT) announced on the Vic Tenders website. An external probity advisor is usually appointed for each procurement activity.

Contracts with suppliers cover the most significant areas/programs of operation including the provision of:

Domiciliary oxygen equipment
Continence aids (>3,000 items)
Non-customised AT (suite of 79 items ranging from shower chairs and over-toilet aids, beds and mattresses, manual wheelchairs, hoists, scooters, walking aids, specialised seats and pressure care items)
Repairs and maintenance to assets of the program
Reissue of refurbished assets
Home modification suppliers
A software solution to replace the existing database that manages client records, AT tracking and financial systems.

SWEP has sought to emphasise the protections of the Consumer Guarantees provided by Australian Consumer Law in its purchase of AT. Our contracted AT suppliers have agreed to provide equivalent consumer protection.

It is important to note that AT can still be recommended that is ‘off-contract’, where it is demonstrated that a contract item will not meet the needs of the consumer. These suppliers do not enter into ‘formal agreements’ as such, however they do need to register as a ‘vendor’ with SWEP, which includes standard commercial trading agreements.

While there are no performance measures in place for ‘non-contract’ suppliers, there is an expectation that non-contract suppliers provide evidence of relevant Australian Standards or equivalent /TGA, to specify how long pricing is fixed for, and for explicit information about warranty/spare parts.

Organisational Agility

The market sector that SWEP operates within is undergoing significant change with policy reforms in both the Aged Care and Disability sectors. Service providers who have historically been ‘block funded’ will increasingly transition to a ‘fee for service’ model to continue to support those consumers who are transitioning from the State funded model to the Commonwealth fee for service models.

Service providers like SWEP who had previously been awarded ‘exclusive contracts’ as single state-wide service providers by the State government in a ‘quarantined market’ will be required to evidence their ‘perceived value’ to funders to remain competitive in an open market environment with few barriers to entry for new competitors, and many points of entry.
SWEP is a conscientious corporate citizen, continues to meet our funding body accreditation requirements and is subject to the Disability Services Commissioner’s complaints mechanism. SWEP is familiar with all relevant state and national legislative requirements and the diversity of service models, key stakeholders and relationships in the sector. The Quality and Safeguards Framework rolls out in Victoria on 1st July, 2019 and to date, SWEP is unaware of the implications, cost or otherwise and additional obligations that will be incurred.

Yours sincerely

Jeni Burton SWEP Operations Director

10 Located: Postal Address: 23 Wetlands Drive P.O. Box 1993 Mt. Helen. 3350 Bakery Hill BC