NDIA Accountability Project

Consultation and communication with providers

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Submission to the Joint Standing Committee on the NDIS

Inquiry into the Capability and Culture of the NDIA

Introduction

Music therapy is an evidence-based practice and allied health profession, and in Australia is delivered by registered music therapists (RMTs). RMTs design and deliver individualised music- based interventions that support social, communicative, sensory, emotional, cognitive and behavioural skills. RMTs are recognised therapy service providers for the NDIS and provide crucial, and life-changing supports for people with disabilities and their families and carers.

The Australian Music Therapy Association (AMTA™) is the peak body for music therapy in Australia, and is responsible for registering RMTs, accrediting music therapy courses and maintaining professional standards and ethics. AMTA™ is a member organisation of Allied Health Professions Australia (AHPA) and the National Alliance for Self-Regulating Health Professions (NASRHP).

AMTA™ acknowledges and welcomes this Joint Standing Committee’s consultation. Our response to the terms of reference outlines how the NDIA’s culture and capability impact NDIS participants, alied health professionals, and businesses providing therapeutic supports. We welcome further conversation and consultation with the NDIA on the Scheme’s implementation.

AMTA™ is consistently involved in NDIA consultations; however, many of these consultations result in no change or reflection of the content of submissions. We trust that this Committee’s c onsultation is genuine and will deliver meaningful recommendations for change.

AMTA™ strongly supports and endorses the submission by AHPA (Submission 8, with attachment).

The nature of consultation and communication with the NDIS

AMTA™ is firmly committed to the NDIS and the potential it offers participants. However, this potential is often overshadowed by operational roadblocks and communication issues.

Consultation and communication with providers

AMTATM’s experiences of consultation with the NDIA are: - genuine engagement is limited and largely tokenistic - consultation processes are often so constrained in terms of scope, lines of questioning, and methodology, that findings are rendered largely meaningless and do not represent the views of participants or providers - there are minimal opportunities for two-way conversation or discussion.

Inquiry into the Capability and Culture of the NDIS – AMTA™ Response

The experience of independent assessments

The experience of independent assessments is just one example of the NDIA’s approach to consultation with participants or providers that did not encapsulate the perspectives of those consulted.

The 2022 publication of the updated NDIS Pricing Review

The 2022 publication of the updated NDIS Pricing Review, Pricing Arrangements and Pricing Limits guide was fraught with errors and omissions due to limited consultation with participants and providers of the Scheme before publication. These issues resulted in prompt retraction and work to correct the errors. Consultation on the Arrangements before publication could have avoided these issues. AMTA™ has communicated directly with the NDIA regarding several unresolved issues and awaits a response.

Changes to NDIS plans, processes and practices without consultation

Changes to NDIS plans, processes and practices without consultation and often without notice impact directly on participants, families, carers, providers and workforce availability.

Consultation and communication with participants

At an individual level, AMTA™ has heard many instances of participant supports being removed or drastically reduced without consultation with participants. Participants tell us about plans developed without their or their family’s consent or engagement, with participants denied the opportunity to have input or make changes.

Lack of consultation with participants:

  • disempowers participants to make their own choices and decisions
  • can result in plans that are not relevant to participants, their families or carers
  • can create risks to participant safety and wellbeing
  • is in direct conflict with the intent of the NDIS
  • can lead to difficult objection and appeal processes that cause significant distress for participants, their families and carers.

There are concerns that NDIA decision-making processes are administratively-driven and economically-motivated.

Operational processes and procedures

The processes and procedures within the NDIS are protracted, complex and often lack transparency, consistency and predictability for participants and their support people.

Fragmentation and inconsistency

Fragmentation within the NDIA is highly problematic for participants and providers and frequently results in inconsistent and sometimes conflicting information delivered by staff. Inconsistencies that directly impact participants and providers include:

  • information about which supports are/are not funded
  • information about how planning and funding approval processes work
  • provider processes within the Scheme, such as billing for supports
  • decision-making over time for individual participants
  • disparate decision-making and funding outcomes for participants.

Inquiry into the Capability and Culture of the NDIS – AMTA Response

Our members have identified trends in music therapy funding approvals and rejections based on participant location/region. Inconsistences within and across teams impact the participant experience and their ability to access vital supports. These inconsistencies also waste precious and finite resources, both within the NDIA and external to the NDIA, as providers seek to clarify or correct information, and as participants appeal decisions.

Inconsistent decision-making impacts significantly on individual participants. Participants report to AMTA that music therapy may have been a primary support one year yet is not approved for the following year despite ongoing needs and therapeutic value. AMTA™ is concerned by decisions to remove primary supports despite participant choice and clinical recommendations.

AMTA™ supports the need for 2- and 3-year plans which promote continuity and reduce the stress to participants and families associated with the planning process. For providers, less frequent reviews could enable longer-term planning for participant supports, reduce proportionate funds expended on non-contact activities, and reduce the workload for the NDIS. Conversely, the NDIS must be able to enact rapid changes for those participants with rapidly changing needs.

Our members witness inequities in access to supports regularly. Participants and providers refer to their, at times, combative relationships with the NDIA. Participants and providers tell us that those with bureaucratic literacy and the available mental and emotional resources can ‘fight’ for NDIS access and supports, while those who do not have this ability are disadvantaged. This complexity pushes the participant experience further from an ‘ordinary life’ and is often protracted, complex, distressing and exhausting,

Staff capability

Planning decisions made by NDIA staff have raised questions about the qualifications, skills and training of people working at the NDIA. Our concerns include planners’ and LACs’:

  • limited understanding of music therapy
  • false beliefs that music therapy is not an NDIS-funded therapy (it is)
  • comments that music therapy is a duplication of other allied health supports.

Planning decisions based on incorrect information or assumptions have serious consequences for a participant’s health and wellbeing, and can reduce their capacity to meet their therapeutic goals.

Despite our involvement in numerous workforce-related meetings and consultations, AMTA™ remains uncertain about the qualifications and competencies of NDIS Planners. This is particularly concerning when NDIA staff disregard or undermine allied health recommendations. Concerns about qualifications and training reflect deeper concerns about the quality of decision-making, a lack of transparency about agency conduct and process, and provider and participant trust in agency staff.

Approach to allied health professions

AMTA™ stresses the importance of safety and strong clinical governance as accepted foundations of the Scheme. Music therapy is a self-regulated allied health profession recognised by AHPA and NAHSRP. RMTs have specialist expertise in evidence-based approaches to the use of music to improve health and wellbeing.

Inquiry into the Capability and Culture of the NDIS – AMTA Response

The processes of the NDIA demonstrate the limited understanding and regard for allied health professions, our expertise and value. This is reflected in:

  • participant experiences of working with planners and LACs
  • inconsistent access to music therapy
  • removal of primary supports, despite participant choice and RMT recommendations
  • the value placed on allied health reporting and professional advice
  • the suggestion that allied health can be substituted with other workers
  • the need to undertake frequent, costly and complex audits with the NDIS Safety and Quality Commission, despite regulation by their professional bodies (requiring compliance with professional standards, safety and ethical requirements)
  • consultations with the NDIA.

NDIA often cites multidisciplinary approaches as ‘duplication’. AMTA strongly rejects the NDIA’s denial of participant supports when therapeutic supports address the same or similar goals. Team approaches to care and support are central to achieving positive outcomes for many participants. Multidisciplinary care, where professionals, participants, families and carers work together to address shared goals, is not duplication; it is best practice.

In discussions with NDIA about the importance of allied health therapy supports, we have repeatedly been met with concerns about costs and suggestions that less qualified health workers could do the same work at a lower price. Substitution of allied health professionals with assistants, unqualified or unregulated workers reduces the quality of supports, risks participants’ outcomes, and is potentially unsafe.

Experiences of NDIS planning processes

The planning process continues to be the aspect of the NDIS causing the most distress to participants and the most concern to providers. Choice and control for participants is best facilitated by coordinators and planners who understand the breadth of supports available to participants and the benefits and outcomes these deliver.

NDIA planning and coordination requires a high-level understanding of complex disabilities and a detailed understanding of the disability sector and the value of available supports. NDIS participants and our members continue to express concerns about:

  • decision makers’ knowledge, training and skills to enable participants’ active role in decision making
  • the validity of decision-making processes about participant goals and plans
  • planner workloads and time pressures negatively impacting the decision-making process
  • decision makers’ abilities to identify the most suitable providers for support.

Inquiry into the Capability and Culture of the NDIS – AMTA Response

AMTA™ members continue to express concerns about the nature of decision-making and its impact on participants:

  • Participants experience high levels of distress when planners disregard their choices and opinions.
  • Limited information about the decision-making process limits participants’ ability to question and challenge the planning and decision-making process.
  • Decision-making processes often undermine the principles of choice and control.
  • Limited genuine engagement with participants and providers results in waste and unnecessary administrative burdens.

AMTA™ draws attention to the high number of Administrative Appeals Tribunal (AAT) processes over the past 18 months. AMTATM suggests this represents participants’ responses to approaches and decision-making they perceive as incorrect or unjust.

This situation could be significantly improved through transparent, person-centred and equitable decision-making. Collaborative approaches would enable participants and providers to question decisions, troubleshoot, and work together with the NDIA to develop a plan that genuinely meets participant needs. AMTA™ suggests that decision support tools and increased education for planners and coordinators would better support this process.

Knowledge and understanding of music therapy

Music therapy is an approved, funded NDIS support. However, AMTA™ often hears of misrepresentations of music therapy by Local Area Coordinators (LACs) and planners who have told participants that music therapy is not an approved funded support. Some NDIS planners refuse to fund music therapy in NDIS plans - irrespective of participants’ requests and comprehensive reports describing strong outcomes across all domains of daily functioning.

Participants and RMTs continue to receive false information from LACs and Planners. Some staff incorrectly suggest music therapy:

  • is not a funded support
  • will only be approved in some regions, for some participants
  • duplicates another service
  • can only be provided with a referral from a psychologist/paediatrician.

Music therapy funding has been denied without reading clinical reports written by RMTs (paid for via participants’ NDIS funds).

AMTA™ has communicated regularly with the NDIA about these ongoing issues and provided information, evidence reviews and case studies. We have offered training. We urge the NDIA to collaborate with AMTA™ to address these ongoing issues. Our optimism for the future

AMTA continues to advocate for participants and is optimistic that an era of positive change and improvement is coming to the NDIS. The experiences of our members point to a system primarily managed via algorithms, which stifles innovation and the ability to deliver individually-tailored supports and approaches. We hope that there is positive change to come that reorients practices,

Inquiry into the Capability and Culture of the NDIS – AMTA Response

processes and policies toward the original intent of the Scheme. We hope that this change will be led by participants and their support people and embed participant choice and control as a necessary part of how the whole of the NDIA functions. This will require a readiness for change at all levels and capability development with NDIA staff. AMTA™ welcomes meaningful collaboration with the NDIA to improve the Scheme for participants and ensure appropriate access to music terapy.

We recognise the value the NDIS could bring to the lives of people with disability, their support people and the broader community. AMTA™ believes strongly that the potential of the Scheme is yet to be realised – we have a long way to go. We are optimistic about further developing a positive and collaborative relationship with the NDIA to maximise the benefits possible through the NDIS. This Scheme has the potential to transform people’s experiences and lives positively – we hope to work with the NDIA to make this a reality.