Joint Standing Committee on the National Disability Insurance Scheme

PO Box 6100 Parliament House Canberra ACT 2600

Dear Committee Secretary,

Inquiry into the capability and culture of the NDIA

Richmond Fellowship is a community organisation that has supported the Canberra Community for over 45 years.

We were one of the first organisations to participate in the NDIS scheme, under the ACT pilot program. Since the introduction of the NDIS we have been focussed on providing supported living services to people who have psychosocial disabilities as a result of mental illness.

Our residential recovery program is designed to support individuals live in the community. This is more than providing a home, getting the bills paid and attending appointments. It is about meeting individual needs for fulfilment and helping to take steps – however small they may appear – towards goals that support this. It is also being cognisant of the episodic nature of psychosocial disability and to support the individual’s personal recovery journey.

The majority of our workforce are frontline care workers for people with disability – we call them Support Workers. They work across ten houses in the ACT and Goulburn, NSW. In addition, we have a small team that delivers support services to people who live independently in the community, and provide group activities in Canberra and region to enhance social engagement and the fulfilment of personal goals.

As one of the first organisations to deliver NDIS services and working closely with the National Disability Insurance Agency since the introduction of the NDIS, we make the following recommendations for consideration:

That the National Disability Insurance Agency (NDIA):

Provide a skilled, trained and experienced NDIA workforce in relation to psychosocial disability
Provide responsive and personalised communication channels to assist service providers to navigate NDIS rules, regulations, policies and procedures
Reduce the administrative burden placed on service providers to bill for services performed
Provide financial support to invest in training for employees of service providers

Responses to the Terms of Reference

1. The capability and culture of the National Disability Insurance Agency (NDIA), with reference to operational processes and procedures, and nature of staff employment

1.1 Provide a skilled, trained and experienced NDIA workforce in relation to psychosocial disability

1.1.1 Since its inception the NDIS has not adequately addressed the needs of participants with psychosocial disability and service providers delivering services as per the participant’s plan.

The NDIS process does not adequately address the episodic nature of psychosocial disability and recovery programs.

1.1.2 It is not always the case that people in this cohort have the personal capacity to make decisions or have good friends and families to assist them to make decisions that are right for them.

1.1.3 Our experience in the plan and plan review processes is the NDIA demonstrates little understanding that a participant may need assistance with their decisions about ongoing daily needs and, more importantly, what support they require to fulfil their life as they define it.

1.1.3.1 This can result in a plan being inadequate; and in the case of the plan review it simply may be rolled over – or worse, decreased – without sufficient knowledge or understanding of the real levels of support the participant needs.

1.1.3.2 This leads to more time, resources and administration to undertake a plan Change of Circumstances review, which delays the release of funds to deliver the services and supports the participant requires. This means that participants either have their much-needed services ceased or service providers continue to provide the service for free until the plan is in place and the funding is made available.

1.1.3.3 This burden could be avoided by a greater understanding within the NDIA of psychosocial disability, the impact of the episodic nature of psychosocial disability, and what supports are required for capacity building and recovery.

1.1.3.4 The result would be more energy and resources spent focussed on the care and support of the participant.

1.1.4 There is a high turnover of staff within the NDIA. This likely is contributing to the level of knowledge and understanding of the disability services sector.

1.2 Provide responsive and personalised communication channels to assist service providers to navigate NDIS rules, regulations, policies and procedures

1.2.1 We acknowledge that the workload is demanding, and this impacts the timeliness and quality of information and advice received by NDIA staff. We would welcome and support an overall increase in the size of the NDIA Team.

1.2.2.Having been one of the first NDIS service providers in Australia we have noted a marked difference in the quality of support provided by the NDIA Team over the years.

1.2.3.At the inception there was greater personalised service provided to us to respond to specific queries and requests relating to participants and their plans, as well as general information and advice in navigating the NDIS legislation, regulations and compliance.

1.2.4.Today, we are hampered by just two avenues to communicate, namely, the impersonalised, faceless email inboxes of info@ and complaints@. This is completely unsatisfactory for our business. Often, we need timely answers to provide the standard of services we wish and expect to deliver to clients. Responses through these two general email inboxes are slow, if at all. In some instances, we have waited up to twelve months for a response. While it is improving from this extreme example, there are still a number of times where response times are inadequate.

1.2.6.The present impersonalised system seems to be incredibly inefficient for all concerned. If we all follow the above advice about ‘how to get prompt attention’, no doubt this system is inefficient equally for the NDIA staff managing these two distinct inboxes.

1.2.7.Internal communications within the NDIA requires improvement also. For example, we have been waiting on the outcome of a request for Change of Circumstance for one client who has been in hospital for over three months. In the meantime, having no visibility of the request for Change of Circumstances on the client file, a separate section of the NDIA has contacted us to initiate a plan review.

1.2.8.When making calls to the NDIA, often the person answering the phone is not in a position to assist and is not able to transfer us to someone who might be able to assist. In desperation staff will attend the NDIA in person. This is not a solution that providers across Australia can access. Nor is it a satisfactory solution for us as this is an inefficient way to access information we require in order to deliver services to our clients.

2. The impacts of NDIA capability and culture on the experiences of people with disability and NDIS participants trying to access information, support and services from the Agency

2.1. Reduce the administrative burden placed on service providers to bill for services performed

2.1.1.The present systems and processes is like a Gordian Knot – several knots all so tightly entangled that it is impossible to see how they are fastened.

2.1.2.We support a review to find simple and effective solutions that lead to better outcomes for participants, service providers and the agency.

2.1.3.Frequently the roster of care plan submitted for inclusion in an NDIS plan are not accepted. This results in a shortfall of the actual needs of the participant and the funding provided for the services.

2.1.4.In addition, a portion of the agreed funds must be invoiced in such a way that adds to the paperwork and process - unnecessarily and unfairly, in our view. Should this portion of funds not be used within the plan’s lifecycle it is not provided in subsequent plans. This is on the basis that its non-use is evidence of it not being required, rather

than it being symptomatic of the difficulty to access it once the service has been

provided.

2.1.5.We frequently experience a lack of communication regarding changes in plan funding through reviews, roll-overs and plan extensions. This results in time and energy being focussed on re-aligning plans and service agreements rather than spending resources focussed on the care and support of the participant.

any other relevant matters

3.1. Provide financial support to invest in training for employees of service providers

3.1.1.Ongoing training for the workforce is an important feature for the successful delivery of the NDIS for the quality and safety of participants and the work force.

3.1.2.Currently there is no specific funding provision for training. NDIS pricing does not take into account appropriate and necessary training of the workforce. It is expected to be absorbed as a ‘cost of doing business’. This is not and will not be sustainable into the future.

3.1.3.With a high turn over of workforce this means the number of adequately trained staff to deliver services today, compared to at its inception, is falling. Ultimately, this impacts on the quality of services provided to NDIS participants over time.

3.1.4.Appropriate levels of funding must be provided directly to businesses to compensate for the increasing cost of training new staff.

3.1.5.This funding provision should also take into account training for NDIA staff regarding psychosocial disability, as well as knowledge of working in the disability services sector generally.

Richmond Fellowship endeavours to work constructively with the staff of the NDIA and acknowledges the pressure they, as we, feel in navigating the rules and requirements to administer the NDIS.

We acknowledge the price increases announced in June 2022 as well as the ‘one-off’ payment in recognition of the cost of compliance for registration and accreditation. While greatly welcomed, this cannot be ‘one-off’, but must be reviewed continually to reflect changes to SCHADS, as well as the increasing need to provide adequate training, support and supervision for the benefit of the workforce and our clients. (NDS State of the Disability Sector Report, November 2022.)

We acknowledge the NDIS Psychosocial Disability Recovery-Oriented Framework (2021) developed to ensure the NDIS is more responsive to participants living with psychosocial disability. After consultation with people with lived experience, their families and service providers, six principles were identified. It is imperative that these principles are applied to demonstrate the commitment to improving the lives of people living with psychosocial disability.

This submission provides an anecdotal snapshot of our experience as a service provider. Much of what we have provided here is more eloquently put, with supporting evidence, in a number of

Joint Standing Committee on the National Disability Insurance Scheme – Capability and Culture of the NDIA (2022)

submissions already received; and also, as described in the NDS State of the Disability Sector Report

2022 (released November 2022).

Notwithstanding, as one of the original NDIS service providers, we felt it was important to contribute to the debate and put ourselves forward as an organisation willing to assist in finding solutions to the issues raised and take an active and positive role going forward.

We are happy to discuss the contents of our submission and invite the Committee to visit ichmond fellowship to expand on our experiences documented herein.

We are also happy to attend a hearing of the inquiry should you invite us to do so.

We thank you for the opportunity to provide comment on the culture and capacity of the ndia through this Inquiry.

Yours sincerely,

Katie Whitehead Chief Executive Officer richmond fellowship act inc

18 december 2022

Joint Standing Committee on the National Disability Insurance Scheme – Capability and Culture of the NDIA (2022) 5

360 Fairbairn Avenue, Pialligo ACT 2609 | PO Box 1304, Fyshwick ACT 2609 P: 02 6248 6118 F: 02 6247 7691 E: info@rfact.org.au W: rfact.org.au