An Inquiry into the Capability and Culture of the NDIA

submission by Priya Fernandes 16 December 2022

TERMS OF REFERENCE

The committee will inquire into and report on the implementation, performance, governance, administration and expenditure of the National Disability Insurance Scheme (NDIS), with particular reference to:

a. the capability and culture of the National Disability Insurance Agency (NDIA), with reference to operational processes and procedures, and nature of staff employment;
b. the impacts of the NDIA capability and culture on the experiences of people with disability and NDIS participants trying to access information, support and services from the Agency; and
c. any other relevant matters.

INTRODUCTION 2

MY JOURNEY WITH THE NDIS 3

KEY ISSUES, IDEAS and RECOMMENDATIONS 5

#1 Rebranding and Marketing of the NDIS and NDIA 5

#2 Raise Accountability and Responsibility of the NDIA 5

#3 Simplify and Streamline the NDIS, and Improve Efficiency 7

#4 Remove Discrimination - Inclusivity and Diversity of People with Disabilities (PWD) 8

#5 Improve Staff Knowledge, Skills, Training and Education 9

CONCLUSION 10

APPENDIX A - Excerpt: Recommendation Report (2 pages) 11

INTRODUCTION

Trust. It’s a fickle thing. It takes a lot to build and gain, and only a moment to break.

The mismanagement of the NDIS these past few years has diminished the integrity of the Scheme. To restore trust in the Scheme and for it to function as originally intended, it is important to improve upon the practices and culture within the NDIA.

Dear Committee Members,

I appreciate the opportunity to be a part of this conversation. Thank you for taking the time to read my submission.

My name is Priya Fernandes. I am 33 years old and have been living with disability for most of my life. I am an NDIS participant, accepted into the Scheme under permanency.

My journey with the NDIS began in 2018, and I was finally accepted into the Scheme in 2020. Being accepted as a participant of the NDIS took me almost two and half years and multiple appeals that involved the Administrative Appeals Tribunal and the NDIA legal team.

The process to access the NDIS was long, drawn out, unreliable, and at times, illogical. And once you are accepted into the NDIS, that does not change.

I know that in my case, I also faced additional challenges due to having complex and less understood impairments and disabilities. Yet these challenges were ones that should have been avoidable. I highlight this because regardless of the type of disability one has, all individuals must address the same questions and criteria as each other. For example:

what is your disability and is it permanent?
what are the impairments of your disability?
give examples of how these impairments impact your functional capacity and daily living?

The answers to these questions provide context that not only informs whether an applicant should be approved but it also informs the NDIA about the types of support the participant is in need of.

My understanding and perspectives on disability draw from my own lived experience as both a carer and as a person with a disability.

My 81 year old father has been significantly impacted by Retinitis Pigmentosa (RP) for over thirty years. RP is hereditary and degenerative, and he is now completely blind. At age 13, I became a co-carer to my maternal grandparents. They lived with us for ten years - one was partially paralysed from a stroke, and the other suffered from severe dementia and physical disability.

And then, there is my own disability….I live with Severe Myalgic Encephalomyelitis (ME). ME is a neurological condition that has caused significant impairment of my physical and cognitive function. I was a teenager when it first surfaced, at age 23 it began to progress severely, and by age 25 I had to give up work permanently. As a result, I had to move back home to live with the support of my elderly parents, who also need support themselves. I am mostly housebound and limited around the home in my activities, and on most occasions outside the home I require the aid of a wheeled walker or attendant-propelled wheelchair. There are periods of being bedridden too - for a few days to weeks and months.

All this combined and continued lived experience allows me to see and better identify some of the gaps and lapses in our community, economy, and operational systems.

MY JOURNEY WITH THE NDIS

The journey to where I am now has been complicated, and with little support. Many people think that it’s easy to access necessary support. But that is far from being true. I first applied for the NDIS in 2018. The access request form seemed simple enough, though perhaps it could have been more specific. When my application was rejected, I requested for an internal review. Twelve months later, the NDIA called me to discuss further evidence required, which I supplied. They also requested and scheduled a phone call with one of my physicians who rearranged his schedule to accommodate the call, except that no one called, rescheduled, gave an explanation, or apologised. This review was not successful. The many reasons outlined in NDIA’s letter to me were honestly a little ridiculous and easy to counter argue, and it did not list supplied key evidence, so I took my case to the Administrative Appeals Tribunal (AAT).

(The above also shows how little thought actually went into assessing my application and/or the lack of knowledge and skills among NDIA staff, with possible bias influencing their decision.)

While there are objective criteria that must be applied when assessing applications, this is not something many of us believe is being applied correctly. Perhaps staff capability is not the only concern here. Perhaps the existing frameworks also require improvement - from written guides, to the access process and developing of participant plans, and to the allowances and restrictions on how funds can be used. These all appear to be tailored to and accepting of more “traditionally” thought of disabilities rather than being inclusive of those of us who are “different”. This is not to say that “traditional” disabilities do not face challenges with the NDIS and NDIA as well.

The incompetence, discrepancies, and inconsistencies of the NDIA, and in their reasonings, continued throughout the AAT mediation process as I went head-to-head with the NDIA’s lawyers. After the NDIA presented their T documents (ie. copies of all relevant review documents that the NDIA used to make their decision), it confirmed that not only was key evidence missing (which I submitted multiple times) but that opposing decisions were made only one day apart about me meeting the criteria for permanent disability. Their rejection letter stated that I did not meet the criteria for permanency (or early intervention). In our first case conference, the NDIA was no longer contesting permanency but still found it could not understand how ME impacted my functional capacity in a severe way, and why I would require lifelong support. Apparently being mostly housebound and unable to work for several years, and at times being bedridden for up to six months each time, did not qualify for severe loss of functional capacity. Not to mention that the missing key evidence addressed this specific query. What irks me even more is that I know that other types of disability (and applicants) have not been subject to the same (stringent) criteria or need to be as severely impaired to be successful with their applications. So how can one say that bias is not at play here.

Interestingly, the NDIA had decided to add conditions to my original application and use them to further justify rejecting my access request. Except I never applied to the NDIA with those conditions. I also had to deal with different lawyers throughout this process, which, on their part, led to delays, late attendance, requests to extend agreed upon deadlines, and last minute rescheduling.

The NDIA organised an Occupational Therapist (OT) to assess me and requested that I provide a Statement of Lived Experience. As the NDIA (staff) struggled to understand ME and how it affects function, I also wrote and included an extensive but simplified guide to ME for them to refer to. The OT submitted a thorough report that was in my favour. A supplementary report was then requested by the NDIA. The OT’s professional assessment did not change, and she had in fact already addressed their additional queries in her original report. It was clear that there were no more reasons to continue to deny my application, and eventually the NDIA granted me access.

I had little help with my application and appeals. Though it did challenge me emotionally, it mostly came at great expense to my physical and cognitive functional capacity - part of which was definitely avoidable.

As I mentioned, the journey to access the NDIS was long, difficult, unreliable and, at times, illogical. And once you’re accepted into the NDIS, that does not change. It instead continues as a drawn out fight for rights; the right to be able to make reasonable and necessary decisions without having to prove your disability and impairments again and again, when you’ve already done that - you cannot access the Scheme without having

done that.

This micro-managing of participants is resulting in an inefficient and demoralising NDIS, and a Scheme that is difficult to interpret and navigate.

Last year we heard of lives put at risk and lives lost while individuals waited months and even years for important supports and assistive technology (AT) to be approved like seizure alert mattresses and seizure detecting dogs. My own supports and AT are being put on hold and/or denied due to an overly complicated process.

When the NDIA hired an OT to assess and report on my eligibility and support needs, the OT’s report outlined all that would be considered reasonable and necessary to fund, including a range of AT items. But post-access, for each (high cost) AT item, an OT must submit a report with evidence from the literature, before it can be approved. This process often takes several months, sometimes longer. To then have an AT application rejected because the NDIA decides that there is not enough evidence that stated impairment(s) are real or applicable to the disability, or if considered applicable, that managing it would not lead to any real benefits or reduce the need for support, is mind boggling. This is considering that the NDIA had to acknowledge and accept these impairments as being true and relevant to your disability when they accepted you onto the Scheme. To deny the existence or relevance and impact of impairments makes a mockery of the entire process, Scheme, and NDIA. Moreover, even reasonable and necessary low cost AT, often need support letters from allied health professionals. This wastes NDIS funds or can lead to out-of-pocket expenses for the participant. In my case, this may also be related to the type of disability I have.

If funding for any AT is denied, you can request an internal review. If the outcome of the review is the same, then the next step is, once again, going to the AAT. If you’re lucky, mediation works and you do not have to become involved in an AAT public hearing or worse, take the matter to Federal Court. There are time limits for appealing these decisions. So far, all of my high cost AT requests have not been approved, and it has not been possible to appeal - my OT was unavailable and it was difficult for me to tackle on my own. It’s a similar process to appeal other reasonable and necessary supports denied, or funding cuts to plans.

For example, last year, my internal review to fund a much needed Support Coordinator (which was removed from my second plan) was rejected on the basis of duplicate funding - ie. because Local Area Coordinators (LACs) are suitable instead. There are many reasons why an LAC is not adequate - poor response time; no one dedicated contact throughout; unable to address specific needs and queries; prioritising of access applications and first-time plans over assisting existing participants with other matters; and poor knowledge - nor are they actually funded in individual participant plans. I do not have the capacity to take this to the AAT. The lack of a Support Coordinator has severely impeded my ability to use my funding and receive support, and as a result, I have been without most of my supports this year. This has severely impacted my already limited functional capacity. It has also created anxiety and stress as we’re led to believe that if we do not use our funding by the time our plan is up for review, we lose it and cannot expect to receive the funding in our next plan unless we can justify, to the NDIA’s standards, why the funding was not used. The assumption is that we must not need the funding. It also feels like many staff are untrained, and sometimes lack a necessary level of empathy and/or logic in their reasonings, as do some processes and protocols.

Dealing with the NDIS is a full time job, and it shouldn’t be. Much time, effort, dollars, and resources are being wasted when they could be directed elsewhere. Participants (and their carers) are being bogged down with too much administration and red tape that prolongs reasonable and necessary requests. This prevents participants from being able to use their funding productively to achieve their plan goals; and it prevents opportunities to move forward with their lives, instead buckling under a continuously growing mound of paperwork.

KEY ISSUES, IDEAS AND RECOMMENDATIONS

I understand that there is a need for protocols and other measures to be put in place to ensure that the Scheme is fair, well-run, and accountable. But the Scheme was never meant to take away people’s autonomy, nor was it about controlling every aspect of their life or subjecting them to repeated questioning. It can be stressful, draining, and at times, undignifying. Justifying everything all the time takes away from choice and control, and makes people with disabilities forever dependent upon and subject to someone else. This is in contrast to the intended purpose of the NDIS - an NDIS that was and should be about empowerment and encouraging and building independence; and about seeing people with disabilities as valuable members of our wider community; a community in which they wish to engage and contribute to the best of their abilities.

Recommendations for reform include but are not limited to:

#1 Rebranding and Marketing of the NDIS and NDIA

The NDIS and NDIA need a serious overhaul of their image. Information around what the NDIS is, and NDIA does, is often misrepresented or misinterpreted. It is not a handout. In fact, it should be viewed as an investment. The NDIS forms part of a circular economy that, as of 2021, was noted in the ‘False Economy’ report (composed by Per Capita for National Disability Services) to be returning $2.25 for every dollar invested in the Scheme.

A rebranding strategy and campaign needs to be developed and implemented. It should:

Identify, challenge and change underlying negative or misinformed attitudes towards the NDIS and NDIA - from the wider community, to internal staff and partner organisations, and to people with disabilities and NDIS participants
Community support is key
- if people do not have an adequate understanding of the Scheme, and do not feel that they can connect with its vision, they won’t feel passionate about it and therefore they won’t want to actively support it
lack of support equals unnecessary challenges, wasted resources to combat negative press and views, and barriers to inclusivity would also remain
Combat negative press and improve understanding through proactive public relations (PR) strategies
- promote the benefits of the NDIS and NDIA
eg. the contribution to our economy vs. the “burden” it places on society/taxpayers
- target social media, press releases, TV interviews and/or advertisements, and written articles
- remain transparent (and accurate) about practices and mishaps
Review and reframe the language being used - written, verbal, and in PR strategies
Include and promote more realistic and true representations of disability within the organisation and externally

#2 Raise Accountability and Responsibility of the NDIA

The NDIA oversees the management and running of the NDIS, and as such, is responsible for the people on the Scheme - applicants, participants, and their carers - including their physical and mental wellbeing; and the consequences and impacts of all decisions, and organisational culture and practices. The NDIA has fallen behind in its responsibility. It needs to raise both its own and industry standards and accountability. It can achieve this by:

Simplifying and streamlining operational processes and procedures - make them thorough but efficient

2.1. Reestablish stability, and rebuild trust and confidence in the Scheme

a. ensure stability for participants

prioritise opportunities that establish long-term viability and stability of the NDIS and NDIA
binding cross-party cooperation to ensure that sustainability and integrity of the NDIS and NDIA remains regardless of any changes in government
reduce fear and anxiety by reassuring participants accepted under ‘permanency’ that their eligibility will not be reassessed with the introduction of new rules, regulations, processes and procedures (eg. the ‘Independent Assessments’ proposal)
reduce fear and anxiety around funding use, and NDIA scheduled or participant requested plan reviews

b. disseminating accurate knowledge and information

improve staff education and training
consistency across written documents and promotional materials
consistency of information available across the NDIA, NDIS, LACs, Support Coordinators, Plan Managers, and all other relevant third-party organisations

c. provide advocacy and recourse opportunities

ensure it is an effective and efficient feedback system
facilitate opportunities and programs for advocacy support that applicants and participants can access
these processes should be simple and easily accessible

d. put processes in place that allow for quick yet thorough investigation and answering of queries raised with the NDIA by applicants, participants or staff

e. follow through and follow up on promises, appointments, deadlines, and complaints

f. assist with service agreements between self and plan-managed participants and independent providers

a lot of misleading information is provided to participants around the hire of support staff and services, and particularly affects plan-managed participants
currently, the NDIA states that it is not party to or responsible for any service agreements created
participants are advised to liaise with the Australian Taxation Office (ATO) to ensure that they are abiding by the necessary rules and regulations of the ATO and Fair Work Commission (FWC)
many providers operate under a client-contractor relationship compared to an employer-employee one, however, participants need ongoing support that often blurs the line between these types of relationships
these organisations have been unable to provide relevant and consistent guidance, leaving NDIS participants open to potential legal complications
participants should not be placed in a position where they have to hire a lawyer to create service agreements or get advice on what should be clear government guidelines to be able to use their plan/funding
if participants are required to hire a lawyer for such NDIS activities, then:
- the lawyer’s fees should be funded through participant plans, and/or
- a free or subsidised legal service needs to be made available that specialises in NDIS matters
create and supply a service agreement template(s) - independently or collaborate with the ATO and FWC

#3 Simplify and Streamline the NDIS, and Improve Efficiency

How data about a participant is collected, and more importantly, interpreted is key to getting it right from the start. It’s key to assessing eligibility for the Scheme; to understanding the needs of a participant, and in developing tailored plans that are effective; and it’s key to changing staff capability.

Challenges arise particularly for participants who either have an invisible disability, a non-typical disability, or who have more than one disability; keeping in mind that no one person has the same combination of disabilities and impairments. And while each disability is defined in its own right, they do not exist separately when found together in one person. The way in which multiple disabilities interact with and affect each other can change how a disability presents in a person. So yes, how data is interpreted, is key to success. While some changes have already been made, the current operational processes and procedures still need further amendment and to be more efficient. Some areas for review include:

3.1 Applying to access the NDIS

 a. better learning opportunities available to physicians and specialists on how to assist patients with their application

 b. ensure that the access request form is specific enough

clearly states the selection criteria using easy-to-understand language
asks all the questions necessary to make a sound assessment

c. guides and examples should be included to assist applicants and their physicians

d. respect privacy - applicants (and participants) often have to divulge much personal and medical information, which is kept on record
minimise intrusive-like queries and requests without just and reasonable cause
staff training and education, and improved guidelines/reference documents will be useful here

e. this will assist in reducing requests for further information and/or appeals, improve the efficiency of processing applications, and, if accepted, contribute better to developing accurate participant profiles

3.2 Participant Profiles

 a. keep clear and relevant records which may include a quick reference checklist against each participant's NDIS profile 
    (particularly relating to their impairments)

 b. this will assist in developing more accurate participant plans, and with post-access assessments

 c. reduces needless paperwork, delays in meeting participants' needs, and internal and AAT appeals - due to reasons like "insufficient evidence"

or staff incapable of assessing relevance to a participant’s disability

3.3 Using your funding

 a. have clear and concise rules, regulations and guidelines on how to use your funding including how explanations and examples are worded and presented

 b. there is still much confusion around this and NDIA, LAC, Support Coordinator and Plan Manager staff are not able

to adequately or consistently answer questions on how to use funding; even providing contradictory information or referring participants to generalised information instead of giving a specific answer

3.4. Remove barriers and improve efficiency

a. reduce the red tape, middlemen, conflicting advice, and unnecessary steps that prolong decision making timelines

b. improve flexibility, choice and control

return autonomy and dignity to participants by eliminating the micro-managing of plans and funding
increase flexibility in how funds can be used without requiring “constant” allied health support letters through staff training, and by including specific examples of invisible and non-typical disabilities in the guidelines
acknowledge and accept that the literature may not always be sufficient to provide the necessary evidence but that a physician or allied health professional’s assessment can still be valid without it
trust in the recommendations being made by a participant’s qualified physicians and other allied health professionals (eg. OTs) instead of always querying their judgment
use a participant’s profile and previously supplied information (about their impairments and disabilities) to assist with assessing the appropriateness of funding and support requests

#4 Remove Discrimination - Inclusivity and Diversity of People with Disabilities (PWD)

A person is more than just any one ability. People with disabilities are as multi-faceted as anyone else, and no two people, even with the same type of disability, are the exact same. We have our own personalities, dreams, opinions, aspirations, and strengths and weaknesses; and we may also have more than one type of disability; all of which make us who we are as a person. Our disabilities do not represent us entirely, but nonetheless they cannot be separated or removed from the rest of who we are. And it is this unique combination of a whole person that the NDIA is currently failing to capture and support.

4.1. Age barriers

 a. having an existing or developing a new disability AND being over 65 years is not the same as experiencing difficulties resulting from ageing

 b. people who developed a disability before they were 65 years old should not be denied access just because the NDIS came to fruition after they turned 65 years old

 c. My Aged Care, in its present form, is not suitable to support the needs of a person with severe disability

 d. people with significant disability aged over 65 years either need to be allowed access to the NDIS or the My Aged Care system needs to be revised to negate displacement of these individuals

4.2. Type of disability

 a. the view of "traditional" disabilities continues to persist despite the list of disabilities allowed on the NDIS having been amended to be more inclusive, resulting in bias and inconsistency in NDIA decision making

 b. broaden and actively promote the definition of disability to include invisible disabilities and non-typical disabilities that challenge the traditional stereotypes

4.3. Amend the framework and guidelines, and improve representation

 a. adapt written guidelines and relevant documents that underpin all operations to better reflect diversity

 b. recognise that other types of disabilities and impairments exist, and ensure that these participants are able to use their funding and plans without having to always provide extra evidence

 c. consult with PWD and actively include them in the management of the NDIS at all levels

 d. ensure a diverse representation of PWD within the NDIA, partner organisations, and advisory committees

#5 Improve Staff Knowledge, Skills, Training and Education

Lack of knowledge, personal and professional biases, and poor training and education of NDIA and LAC staff heavily influence NDIS access, and funding and plan use. Many staff struggle to understand how best to provide or facilitate opportunities for support. Those that do understand admit that the system is flawed and built on attitudes that are dated in their considerations, and that it does not accommodate the wide range of disabilities that do exist.

5.1. Improve staff understanding of disability and attitudes towards PWD - across all levels of the NDIA, and including LACs

 a. better education and training initiatives

 b. staff responsible for assessments and decision making should be skilled to assess all types of disability - training should focus on expanding these skills, or even allocating staff to different specialities

 c. more focus on meeting participant needs accurately and efficiently over trying to keep funding spend low

5.2. Ensure staff feel supported and confident to carry out their duties

 a. develop written reference modules and opportunities for refresher training

 b. create a safe environment to raise queries (with team leaders, managers and above), and to provide feedback and input

 c. inform staff of changes before they happen - eg. briefings, and checklists to refer to for when liaising with participants

 d. this should increase staff satisfaction, reduce potential abuse towards staff, and lessen the delays in accurately answering participants’ queries

 e. the simplifying and streamlining of operational processes and procedures should also assist

The above five select recommendations stem from opinion articles and a recommendation report that I began working on prior to this inquiry, and that focus on topics such as the ‘NDIS and the Economy’ and ‘Restoring Trust in the NDIS and NDIA’.

An excerpt is provided in Appendix A of the recommendation report, which may present further insight to opportunities worth exploring.

Submission by Priya Fernandes_v16.12.2022_final Page 9 of 12

CONCLUSION

There are many fundamental flaws arising in the Scheme that need to be addressed and be given urgent attention. The issues run deep. It’s systemic, and brings into question the capability and culture of the NDIA.

I fought hard to gain access to the NDIS because I hoped it would be a positive step towards establishing some security and stability for myself, and to lessen the current and future stresses and strain on my family and friends. But it has felt anything but stable.

With relevant supports, participants hope to live with more dignity. We hope that it will improve our functional capacity or at least allow us to better utilise our existing capacity. Being an NDIS participant has not achieved this for me; rather it has become a burden on me, and monopolises my capacity.

The key issues, ideas, and recommendations in this submission draw from my own experience and those of other individuals.

Measures and strategies focussed on brand repositioning; raising industry standards and accountability; simplifying and streamlining processes and procedures; reviewing guidelines and the framework; being more inclusive and diverse; efficient use of resources; and developing staff knowledge and skills, will increase efficiency and help prevent risk to participants, as well as improve the image of and trust in the NDIS and NDIA.

The NDIS has been life changing for many, but there is more that can be done to improve the participant experience and to find ways to make the Scheme better, simpler, faster, and more flexible. We need a fair and sustainable NDIS, and we need to restore trust in the NDIS and in those who are tasked with its management.

I hope that my submission serves as a productive contribution to this inquiry. I am passionate about remaining involved in this conversation, and welcome any further contact.

Committee Members, thank you for your time.

APPENDIX A - Excerpt: Recommendation Report (2 pages)

Restoring Trust in the NDIS and NDIA - a working draft by Priya Fernandes

REPORT SUMMARY

The NDIS is a valuable asset to our nation that offers many social and economic benefits, and opportunities to both people with and without disabilities. It has been life changing for many, but there is more that can be done to improve the participant experience and to find ways to make the Scheme better, simpler, faster, and more flexible. We need a fair and sustainable NDIS.

The below identified key issues and ideas serve as a springboard for reform, recovery and progress.

KEY ISSUES AND IDEAS

Diversity of People with Disabilities (PWD): ensure a diverse representation and inclusion of different types of disability.
Inclusive Environment: active involvement of PWD in the running of the Scheme - decision making, strategising, implementation, and debriefing. Via consultations, internal employment in key roles/departments, advisory boards/committees, and feedback opportunities.
Branding & Marketing of NDIS: brand repositioning, awareness campaigns, remove misconceptions, brand ambassadors, and proactive measures to combat negative press. Change the public’s view and understanding of the NDIS - strategies to improve representation, awareness and understanding of the scheme and PWD, and to promote a view that the NDIS is not a drain on taxpayers but rather a smart investment in our economy and our community. Rebuff the notion of the NDIS being unsustainable. Create brand loyalty - ALL stakeholders need to connect with and feel invested in this Scheme, including taxpayers. Clearly showcase how the NDIS benefits everyone (not just PWD). All this will allow efforts and resources spent on combating and discussing the validity of the scheme to be redirected elsewhere.
Branding & Marketing of PWD: reviewing and reframing language so that it positively influences image (eg. valuable vs. vulnerable), and realistic and diverse representation that shows the ways in which PWD contribute to the community - ie. their value.
Staff Training in the NDIA: support staff to carry out their jobs effectively and empathetically, training in skills and education relevant to the job, emotional support, and reduce assessor subjectivity and bias. Regular refreshers and new updates’ training. Increase employee pride. Training and workshops run by/with PWD, modules developed by/with PWD, sensitivity training, consistency in staff knowledge. Make similar strategies to providers, support workers, and other relevant workers and organisations available.
Rules, Regulations & Resources: review and amend. For participants and providers/workers. Ensure consistency, certainty, and simple format for easier interpretation and navigation by all.
Raise Industry Standards & Accountability: monitoring and reviewing of the Scheme and providers. Implementation of safeguards to ensure minimum industry standards are being met re: quality, transparency, corruption and costs. Minimum requirements for those providers who are not NDIA-registered or possibly having a tiered registration model. Improved guidance re: service agreements, independent contractors/employees, tax and super.
Remove Barriers: middlemen/steps/red tape that prolong decision making timelines. Admin load on participants/ carers, and participants continuously having to re-justify and re-prove their disability. Access age limits and disability type biases. Simplify and streamline the NDIS.
Improve Consistency: NDIS staff and service provider knowledge, between organisations (eg. NDIA, ATO, FWC), across disabilities re: eligibility criteria, and in applying rules and regulations. Give justifications re: access and funding decisions that are logical and not contradictory.

10. Participant Access, Plans & Reviews: better training of staff re: how to correctly interpret and apply information collected about participants so that funding is relevant, reasonable and necessary.

Removing participant fear that queries and AT applications will trigger a (negative) plan review or eligibility being revoked. Moving away from interrogative style questioning to a method aimed at understanding needs and context. Building plans to support disability needs which should also include an understanding of the participant’s abilities and how best to support these abilities and capacity to use them. Allocating adequate time and resources in the first place to make accurate assessments, and reduce admin and internal and AAT appeals. Improve communication - eg. more frequent and/or accessible progress updates.

11. Flexibility, Choice & Control:

return autonomy and dignity to participants, reduce micro-managing of plans and participants, increase flexibility in how funds can be used, and trust in health professionals’ (eg. OT) recommendations.

12. Non-Typical Disabilities:

be more inclusive of less “traditional” disabilities and ensure supports are available to them - the current NDIS model is limited in its support options.

13. Reducing Waste:

inrelevant funding in participant plans, and reducing the need for AAT involvement pre and post access. Reduce job outsourcing - increasing jobs and developing staff in-house will increase productivity, allow for better quality control, and will save dollars.

14. NDIA Staff/Contractor Hire:

refine recruitment process, preferred qualifications, training opportunities including for inexperienced applicants. Increasing staff will streamline processes, reduce admin costs, and improve efficiency which reduces turn-around times on applications and assessments. Improved efficiency and training can help lower risk of negative outcomes (eg. to health, wellbeing and even death of participants/carers). It improves participant and staff satisfaction and therefore staff productivity, and increases economic benefits to the community (eg. employment, smarter use of participant/carer capacity and being able to engage in the community sooner, and reduced strain on health and other systems).

15. Advocacy and Recourse:

effective and efficient feedback system, and advocacy support for participants. It should be simple and easily accessible.

16. Agenda, Vision and Goals:

prioritise opportunities that establish long-term viability and stability of the NDIS. Binding cross-party cooperation to ensure sustainability and integrity of the NDIS remains regardless of any changes in government.

17. Realistic Representations:

of PWD and their varied support needs - important for setting industry work standards, improving workforce stability, and attracting the right type of workers (eg. misleading TV ads by Mable). Misrepresentation also prevents the public from recognising the true value of PWD, and does not focus enough on their abilities.

18. Ineligible PWD:

is it possible to amend the NDIS framework to accommodate another stream of PWD, similar to having an ‘early intervention’ stream? If not, developing/collaborating on a system or resources that support those PWD and/or significant chronic illness who are not currently eligible for NDIS but cannot be adequately supported by the health system is also required. For example, a disability discount card similar to a seniors discount card would help reduce financial and mental health burdens on those who are strictly limited to working casual/part-time only but have increased costs relating to their disability. Extend the concept and practicality of ‘early intervention’ to operate outside the NDIS, and it should include our school and health systems. Without additional support measures, these individuals are at risk of becoming worse which would increase their need to access greater supports such as the NDIS and DSP. Additionally, if age barriers cannot be removed from the NDIS or accommodated under another option (as suggested above), then the My Aged Care system needs to be amended to better service the needs of PWD who are over 65 years of age - eg. a separate Home Care Package specifically for PWD or changing the assessment criteria for existing levels.

There is much to explore within and in addition to the key issues and ideas outlined above. An opportunity to speak with you further on this important subject would be much appreciated.

Challenges accessing and navigating the National Disability Insurance Scheme