Capability and Culture of NDIA
October 2022
EXERCISE & SPORTS SCIENCE AUSTRALIA
(ESSA) SUBMISSION
RE: CAPABILITY AND CULTURE OF NDIA Joint Standing Committee on the National Disability Insurance Scheme
Thank you for the opportunity to provide feedback to the Federal Government’s Capability and Culture of NDIA consultation.
Exercise & Sports Science Australia (ESSA) is the peak professional association for exercise and sports science professionals in Australia, representing more than 10,000 members comprising university qualified Accredited Exercise Physiologists, Accredited Sports Scientists, Accredited High-Performance Managers and Accredited Exercise Scientists.
The capability and culture of the NDIA reflects the way its operational processes and procedures are structured. Some of these processes reflect a culture that lack proper understanding of allied health scope of practice, causing a negative impact on NDIS participants trying to the access supports. More specifically, the agency has shown a clear bias against Exercise Physiologists, failing to recognise their qualifications and understand the potential benefits they can offer to NDIS participants.
The two instances where this is evident are in the delegation of supports and the NDIS price arrangements. Participants have had Accredited Exercise Physiologist (AEP) supports replaced by regular physical activities provided by carers, resulting in negative consequences to participants’ functional capabilities. Additionally, the NDIA incorrectly views AEPs as professionals with lower skills and qualifications than their allied health counterparts. This view is reflected in the NDIS price arrangements, where AEPs have much lower price limits than other allied health professions.
ESSA emphasises that the NDIA staff should have better understanding of qualifications and scope of practice of allied health professionals, especially exercise physiology, so they are treated fairly and NDIS participants fully benefit from of the services they provide.
We welcome the opportunity to provide further detail or appear before the Committee if invited. Please contact ESSA Policy & Advocacy Advisor, Felix Meyer on 07 3171 9661 or at policy@essa.org.au for further information or questions arising from the following submission.
Yours sincerely,
Jeffrey Allen Felix Meyer Manager Policy & Advocacy Policy & Advocacy Advisor
Exercise & Sports Science Australia Exercise & Sports Science Australia re
PORTS SCIENCE AUSTRALIA
1.0 ABOUT OUR PROFESSIONALS
Accredited Exercise Physiologists (AEPs) are four-year university degree qualified allied health professionals. They provide services to people across the full health spectrum, from the healthy population through to those at risk of developing a health condition, and people with health conditions, a disability, and aged related illnesses and conditions, including chronic, complex conditions 1. Exercise physiology services are recognised by Australian compensable schemes including Medicare, the National Disability Insurance Scheme (NDIS), Department of Veteran Affairs (DVA), workers’ compensation schemes and most private health insurers. Australia’s exercise physiology profession comprises approximately 7,000 AEPs, with over 1600 of these in Queensland.
AESs are three-year university degree qualified professionals who deliver exercise programs to Australia’s well populations to prevent chronic disease, injury and disability, and improve health, fitness and performance. They empower, motivate and coach clients to adopt long-term behavioural changes. AESs work in numerous sectors spanning allied health as Allied Health Assistants (AHAs); the NDIS as Therapy Assistants; personal trainers in the fitness industry; coaches in sporting organisations; and as program coordinators in education and corporate health. There are more than 700 AESs working in Australia today.
2.0 SUMMARY OF RECOMMENDATIONS
- Recommendation 1: The NDIA should implement a delegation of supports process that recognises the risks and impacts to participants, providing effective training and guidance to NDIA staff on Exercise Physiology scope of practice and how participants can benefit from it.
- Recommendation 2: Exercise physiology price limits should be increased to meet the price limits of all other allied health professions.
3.0 DELEGATION OF SUPPORTS
The Improved Daily Living supports, under NDIS Capacity Building services, offer funding for assessment, training and therapy interventions to increase NDIS participants’ skills, independence and community participation. According to the NDIS service guideline, in situations where the maximum medical improvement for a participant has been reached, these supports can be used to facilitate small functional improvements or to prevent functional decline. In those conditions however, the NDIS requires the delivery of supports to be made by carers able to be trained and guided to provide specialised supports. Even if a participant has a medical condition requiring a particular specialised intervention to maintain functionality or to prevent deterioration of a medical condition, support items under Improved Daily Living should be used mainly for training of non-qualified personnel.
This requirement establishes the need for a delegation of specialised supports process, that carefully considers the support delegation risks, limitations and applicable circumstances. This process should also guide NDIA staff to properly assess how and when delegation of supports should be implemented. This careful balanced process, however, has not been developed nor implemented. As result, ESSA members have reported that NDIA planners are removing, or greatly reducing, exercise physiology funding with the justification that these clinical interventions can be performed by support workers or other carers. Unfortunately, in most situations, that is not possible. Even with extra training provided to support workers and carers, they just do not have the clinical experience necessary to conduct exercise therapy. The table below shows the qualifications and expertise of professionals involved in exercise supports.
Table 1. Comparison of Professional Skill and Scope of Practice
Scope to Scope to Mini Scope to Scope to Scope to promote Profession cevcunase Mest prevent prescribe supervise | lifestyle Training health : : ; ; éondions disease exercise exercise behaviour change . Delivery and Teach, coach 4-year cushions supervision and motivate university Use exercise Development to prescribe of exercise __ clients to Accredited degree, prescription and delivery ecules programs for facilitate self- Eyorciac bachelor or to improve of programs programs people with manage Physiologist master’s level. functionand to prevent accommodating complex exercise and Na5) 500 hours wellbeing, no disease and pativichaed pathology, lifestyle practical invasive disease preferences according to behaviours placement. treatment. progression. and complex individual using models equiions needs. of behaviour ; change. Can design Able to Can deliver Do nottreat and deliver eseribe and Can provide conditions, programs to i artes supervise health 3-year but can improve programs that exercise education, Recnaciiteel university design and health and accommodate Programs for advice and Exercise degree, deliver prevent individual people with _— support to Scientist bachelor level. exercise chronic nielerances complex enhance (AES) 120 hours programs to disease. and ables but pathology, health and practical improve Need to nead in Gansulk provided wellbeing, placement. health, consult AEP AEPs for clients they have and to wellbeing for clients wii complex: been prevent and function with complex noneihene prescribed disease. ; Can use goal Can deliver setting, exercis motivation, thats aasiet ws Cannot Can guidance and Do not treat the prescribe supervise social Personal Certificate or le las sad prevention of — exercise for ees but Trainer diploma Srecascun ~ chronic oe clients of low Pe iting in intervention. Sauiniray conditions or ee = behaviour provision of disability. change public health oo Information. interventions. Cannot do nottreat donottreat prescribe Disability N/A conditions or conditions or exercise for Support provide provide clients with N/A N/A Worker therapeutic therapeutic health intervention. intervention. conditions or disability.
Skills Development
skills, namely, to build and maintain friendships, recognise and understand emotions, and learn strategies to self- regulate his emotions.
Weekly sessions were implemented during AEP’s first year of interventions and, at the 12-month plan review, the NDIS participant was showing improved confidence in the gym, increased engagement and communication with the AEP, increased exercise tolerance, increased time engaging within community, improved motor skills and reduced parental support during therapy when compared to the previous year. The participant’s AEP recommended the maintenance of the ongoing support to preserve the functional gain and to push improvements by increasing exercise tolerance from 45 minutes to 1 hour per week.
Despite AEP’s recommendation and participant’s family preference, all funding for exercise physiology was removed with the justification that physical activity was available from school. Funding for occupational therapy and psychology remained, however. After just a few months, the child’s parents contacted his AEP with the feedback that he was disengaging from school, lacking the confidence, coordination and the social skills to participate in social and sporting activities. In addition, the participant was not properly responding to the remained allied health therapies.
NDIA CAPABILITY AND CULTURE
The capability and culture of the NDIA, reflected in its operational processes, procedure and staff employment structure have had an impact on the experiences of people with disability trying to access supports from the scheme. This case study highlights that the NDIS planner did not know the difference between exercise physiology and regular physical activity. This lack of understanding impaired the NDIA assessor to evaluate the impacts of its funding decision on participants’ motor skills, coordination and social engagement.
NDIA staff has an important responsibility on participants’ funding decisions. Despite that, they have shown insufficient understanding of allied health’s scope of practice, particularly exercise physiology, lacking essential knowledge to determine NDIS participant’s allied health needs. As result, supports have often being replaced by lower cost alternatives, against clinically justified recommendations, under the disguise of support delegation. The improper management of supports causes harm to NDIS participants and needs to be addressed. Adequate training and guidance for NDIA workers are essential to ensure funding allocation set the ideal conditions to reach participants’ best outcomes.
Recommendation 1:
The NDIA should implement a delegation of supports process that recognises the risks and impacts to participants, providing effective training and guidance to NDIA staff on Exercise Physiology scope of practice and how participants can benefit from it.
5.0 PRICE INEQUALITY
The NDIS has described the professional requirements for allied health workers providing services under Improved Daily Living support items. For Early Childhood supports, for example, the requirements generally include a bachelor’s degree in their relevant area and current registration or membership with their relevant professional body. Professional requirements for Developmental Educator, Early Childhood Educator, Social Worker, Speech Pathologist, Physiotherapist, Exercise Physiologist and others were also described with relative equivalence. In general terms, the requirement is a bachelor’s degree in their relevant area and current registration or membership with their relevant professional body. The table below shows how professional requirements for various allied health professions were set by the NDS.
Table 2. NDIS Professional Requirements
| Professional Requirement |
|---|
| Bachelor’s degree or higher and has current full membership with Developmental Educators Australia Inc. |
| Certified Practising Speech Pathologist as approved by Speech Pathology Australia. |
| Current AHPRA Registration as a Physiotherapist. |
| Professional Member with the Australian, New Zealand and Asian Creative Arts Therapy Association (ANZACATA). |
| Accredited Practising Dietitian with the Dietitians Australia. |
| fea exercise physiologist with Exercise and Sports Science |
Extracted from: NDIS Pricing Arrangements and Price Limits 2022-2023 (p91) 2
However, since the introduction of the NDIS, the pricing structure has failed to recognise the exercise physiology profession in line with other allied health professions. AEP qualifications, regulation and accreditation requirements are comparable to other allied health professions delivering supports under the NDIS, but the current price limits imply that the AEPs have lower skills and professional requirements within the scheme, which is incorrect. The tables below show how price limits were set for different allied health professionals.
Table 3. NDIS Early Childhood Support Items Price Limits
| Item Number | Item Name and Notes |
|---|---|
| Early Childhood Supports — Early Childhood Professional | |
| e Developmental Educator | |
| e Early Childhood Teacher or Educator | |
| e Occupational Therapist | |
| e Social Worker | |
| e Other Professional | |
| 15_003_0118_1_3 | Early Childhood Supports - Physiotherapist _ Hour |
| 15 609 0118.13 | Early Childhood Supports - Exercise a |
Extracted from: NDIS Pricing Arrangements and Price Limits 2022-2023 (p91) f
|$193.99 $271.59 $290.99| |_$224.62 $314.47 $336.93| |$166.99 $233.79 $250.49 K|
EXERCISE & SPORTS SCIENCE AUSTRALIA
Table 4. NDIS Support Items Price Limits
| Item Number | Item Name and Notes |
|---|---|
| Assessment Recommendation Therapy or Training | |
| Assessment Recommendation Therapy or Training - Music Therapist | |
| Assessment Recommendation Therapy or Training - Occupational Therapist | |
| Assessment Recommendation Therapy or Training - Orthoptist | |
| Assessment Recommendation Therapy or Training - Physiotherapist | |
| 15 | 200 0128 |
| 1.3 Hour §$46699 $166.99 $233.79 $250.49 | |
| 15_615 | 0128 |
| 1.3 Hour $19399 $19399 $271.59 $290.99 | |
| 15_617 | 0128_1_3 Hour $193.99 $193.99 $271.59 $290.99 |
| 15_618 | 0128 |
| 1_3 Hour $193.99 $193.99 $271.59 $290.99 | |
| 15_055 | 0128 |
| 1_3 Hour $193.99 $224.62 $314.47 $336.93 | |
| Assessment Recommendation Therapy or Training - Podiatrist | |
| Assessment Recommendation Therapy or Training - Psychologist | |
| Assessment Recommendation Therapy or Training - Rehabilitation Counsellor Hour $193.99 $193.99 $271.58 $290.99 | |
| 15_619 | 0128 |
| 1_3 Hour $193.99 $193.99 $271.59 $290.99 | |
| 15 | 054 0128 |
| 1.3 Hour $214.41 $234.83 $328.76 $352.25 | |
| 15 | 620_0128 |
| 1 3 | |
| Assessment Recommendation Therapy or | |
| Training - Social Worker | |
| Hour $193.99 $193.99 $271.59 $290.99 | |
| 18_621 | 0126_1_9 Training - Social Worker |
| Hour $193.99 $193.99 $271.59 $290.99 | |
| Assessment Recommendation Therapy or Training - Speech Pathologist | |
| Assessment Recommendation Therapy or Training - Other Professional | |
| 1_056_0128_1_3 Training - Other Professional Hour $193.99 $193.99 $271.59 $290.99 | |
| 15_622 | 0128 _1_3 Hour $193.99 $193.99 $271.59 $290.99 |
AEPs undertake a minimum of 4 years equivalent study in clinical exercise physiology at an Australian Qualification Framework (AQF) Level 7 or above. This is an equivalent level of study and qualification required of physiotherapists, psychologists, speech pathologists, occupational therapists, music therapists and many other allied health professionals, all of which currently are remunerated at a higher hourly rate than AEPs.
Further, AEPs are subject to practice standards that are comparable to other allied health professions delivering supports under the NDIS. ESSA takes steps to ensure that AEP accreditation and regulation is aligned with other allied health professions through membership with the National Alliance of Self-Regulating Health Professions (NASRHP). NASRHP is an independent body providing a quality framework for self-regulating health professions. NASRHP has a set of standards for membership that have been closely modelled on the standards that health professions regulated by Australian Health Practitioner Regulation Agency (AHPRA) are required to meet. This demonstrates equivalent regulation and oversight of AEPs compared with both AHPRA registered professions and other self-regulated professions.
AEPs are employed under the same national and state awards as other allied health professionals delivering supports under the NDIS and, as a result, are subject to the same wages as other allied health. This would imply that allied health professionals should attract the same prices under compensable schemes, which is the case under the Medicare Benefits Schedule (MBS), Workcover Western Australia and Workcover Queensland.
NDIA CAPABILITY AND CULTURE
The capability and culture of the NDIA, reflected in its operational processes and procedures, and staff employment structure have had an impact on the experiences of people with disability and NDIS participants trying to access supports from the agency. The price guide published by the NDIA disadvantages Exercise Physiologists and K reflects a poor understanding that AEPs have lower skills and qualifications than other allied health professionals.
EXERCISE & SPORTS SCIENCE AUSTRALIA
Recommendation
ESSA maintains that the current price limits for exercise physiology are not adequate and should be increased to meet the price limits of other allied health professions delivering supports under the NDIS.
Recommendation 2:
Exercise physiology price limits should be increased to meet the price limits of all other allied health professions.
6.0 CONCLUSION
The capability and culture of the NDIA, reflected in its operational processes and procedures, have had an impact on the experiences of people with disability trying to access supports from the scheme. It is clear through its actions that the NDIA has a prejudice towards Exercise Physiologists, likely due to lack of understanding of the qualifications, scope of practice and potential benefits that AEPs can offer to NDIS Participants.
The two instances where this is demonstrably true are in the delegation of supports and the NDIS price arrangements. Participants have had AEP supports replaced by regular physical activities provided by non-qualified carers which can have negative consequences to their functional capabilities. Additionally, the NDIA views Exercise Physiologist as professionals with lower skills and qualifications than other allied health professionals. This view is reflected in the NDIS price guide, where AEPs have much lower price limits than their allied health counterparts.
ESSA emphasises that the NDIA should have a better understanding of professionals’ qualifications and scope of practice, especially Exercise Physiology, so allied health professionals are treated fairly, and NDIS participants can benefit from the full potential of allied health services.
7.0 REFERENCES
-
Exercise & Sports Science Australia. Accredited Exercise Physiologist Scope of Practice. 2021. -
National Disability Insurance Agency. NDIS Pricing Arrangements and Price Limits 2022-2023. 2022.
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