Submission to Joint Standing Committee re new inquiry into current Scheme implementation and forecasting for the NDIS.

Background:

This submission is provided by the Committee of Management for Waverley Helpmates Inc (WHM), based upon concerns evinced by parents and advocates for the Participants at WHM regarding the proposed “Joint Standing Committee new inquiry into current Scheme implementation and forecasting for the NDIS”.

WHM is an Australian Disability Enterprise (ADE) and has been operating for over 35 years. It is a supported employment and training program providing gardening, cleaning and ironing work in the local community for thirty-three (33) people with a disability.

WHM was initially founded with the support of & active participation from Rotary Inc, a local State MP (Geoff Coleman, Liberal, Syndal) , a Special School Principal and families who were seeking practical employment and support for their sons and daughters after leaving school.

Most Participants (also referred to as Helpmates) at WHM live with an evident intellectual disability, and many have other co-morbid psychosocial disability of some type. While they are correctly referred to as Persons with a Disability (PWD), it can be more helpful to describe Helpmates as Persons with an Intellectual Disability (PWID). As a guide, anyone who has a formal diagnosis of a Mild or Moderate Intellectual Disability has an IQ of less than 70 to 50, and 49 to 35, respectively. Mild, Moderate, Severe Intellectual Disability Differences | HealthyPlace

WHM is audited annually for compliance with the National Disability Standards and receives funding principally from the NDIS and other relevant government sources. Prior to the formation of the NDIS, WHM received funding & support from both the Victorian Government (DSS) and Centrelink/ Services Australia. [For further details about Waverley Helpmates and its role as an NDIS provider to its community of PWID, please refer to Section 4].

Most of the participants at WHM are over 25 years old, so their parents and advocates have already spent many years grappling with the various arms of government which administer support services for PWD.

Our families’ long interactions with the administration of those support services, navigating Services Australia/ Centrelink, the Departments of Education, the medical and Medicare systems, specialist Dental services, the Mental Health system, the local State DHHS for housing, and now the NDIS, mean that the Helpmates, their families and advocates generally have far more experience in and of the Disability ‘System’ than those who operate the disability system – in some cases, WHM families have been negotiating these systems for nearly 50 years.

There appears to be an underlying assumption within the NDIA that PWD = Dylan Allcott or Kurt Fearnley. That is, a highly intelligent and articulate person who is gifted, determined and in a wheelchair. Not a person who has an intellectual disability, who may not speak clearly, does not read well, looks physically normal at first glance and has aurally acquired a huge

database regarding actors who have formerly been in Star Wars movies, which he will willingly share with you at some length. He has what are euphemistically described as ‘splinter skills’.

We note that the NDIS caters for many more PWD (physical disability only) than PWID. The proportions are understood to be approximately 90% to 10%.

    At the risk of stating the obvious, none of the WHM Participants will ever cease
             having their intellectual disability. They will not “improve”.

The NDIS' limited understanding of the needs of PWID is at the core of the concerns for our

WHM Participants. They lack the ability to understand and communicate at the complex level necessary to deal by themselves with the bureaucracy, to manage the computer systems and administrative record keeping, and the occasional sophistry of the NDIS.

 Even simple examples such as using a mobile phone to check in with a QR code and
 accessing his COVID vaccination certificate becomes yet another task for the PWID’s
 advocates to remind and monitor.

 2.   Terms of Reference

     It is understood that as part of the Joint Standing Committee's (JSC) role to inquire into the
 implementation, performance and governance of the National Disability Insurance Scheme
 (NDIS), the JSC  will inquire into and report on current scheme implementation and
  forecasting for the NDIS, with particular reference to:

      a. The impact of boundaries of NDIS and non-NDIS service provision on the demand
           for NDIS funding, including:
                        i.    the availability of support outside the NDIS for people with disability (e.g.
             community-based or ‘Tier 2’ supports), and
                        ii.    the future of the Information, Linkages and Capacity Building grants program;
      b. The interfaces of NDIS service provision with other non-NDIS services provided by
         the States, Territories and the Commonwealth, particularly aged care, health,
        education and justice services;
       c. The reasons for variations in plan funding between NDIS participants with similar
        needs, including:
                        i.    the drivers of inequity between NDIS participants living in different parts of
                  Australia,
                        ii.   whether inconsistent decision-making by the NDIA is leading to inequitable
                 variations in plan funding, and
                        iii.   measures that could address any inequitable variation in plan funding;
      d. How the NDIS is funded, including:
                        i.    the current and future funding sources for the NDIS,
                        ii.    the division of funding between the Commonwealth, States and Territories,
            and
                        iii.   the need for a pool of reserve funding;
      e.  Financial and actuarial modelling and forecasting of the scheme, including:
                        i.    the role of insurance-based principles in scheme modelling, and

ii.

assumptions, measures, and methodologies used to forecast and make projections about the scheme, participants, and long-term financial modelling;

f. The measures intended to ensure the financial sustainability of the NDIS (e.g. governance, oversight and administrative measures), including:

• i. the role of state and territory governments, and the Disability Reform Ministers Meetings,
• ii. the arrangements for providing actuarial and prudential advice about the scheme, and
• iii. the way data, modelling, and forecasting is presented in public documents about the NDIS, (e.g. NDIS Quarterly Reports and Reports by the Scheme Actuary), and
• iv. measures to ensure transparency of data and information about the NDIS;

g. The ongoing measures to reform the scheme including:

• i. the new early childhood approach, including whether or how early intervention and other supports intended to improve a participant’s functional capacity could reduce their need for NDIS funding, and
• ii. planning policy for personalised budgets and plan flexibility; and

h. Any other related matters.

3. Terms of Reference relevant for Waverley Helpmates

Waverly Helpmates has considered the Terms of Reference insofar as they affect WHM’s ability to continue to serve their Participants so that they may

1. meet their potential, and
2. be assisted by having meaningful supported employment which enables them to contribute in a dignified and inclusive fashion and which they see as contributing to their active participation in their communities, and
3. be assisted by having relevant support and training to support the above objectives.

These objectives are generally covered by the NDIS support categories of - Capacity Building – Increased Social and Community Participation - Capacity Building – Finding and Keeping a Job

But may also have elements of - Core – Assistance with Daily Activities - Core – Assistance with Social, Community & Civic Participation

We note the following JSC Terms of Reference appear to be most relevant to WHM’s Participants:

1. Term of Reference C

i. whether inconsistent decision-making by the NDIA is leading to inequitable variations in plan funding, and ii. measures that could address any inequitable variation in plan funding;

The constant changes of direction from the NDIA which are sometimes at odds with the information conveyed to the LACs gives rise to a perception that there is insufficient understanding of the needs of both PWD and for WHM, of the PWID.

For example, we were advised that ALL Participant plans would be updated by December 2021 to reflect the inclusions of funding for Training In A Group. This has not happened. In fact, it has happened to very few of our Participants.

While some variability may be expected during a pandemic, one might have expected that decisions relating to changes would be subjected to some communication rigour. That robust management process seems to be lacking.

Although the Quotations provided to Helpmates /their Advocates are all based upon the same rates according to the NDIS Schedule, some Participants received different amounts, depending on their LAC and reviewer. Although it is understandable that some minor variation may occur, it would seem that ‘it depends who you get’.

It would seem that the use of Subject Matter Experts for PWID, Downs, ABI, CF, Autism, Anxiety disorders etc might be of assistance, and similarly, for those with familiar with intellectual rather than physical disability, it would be more sensible to use the treating specialists who are familiar to the PWID.

Any “assessment” that puts a PWID under any pressure is unacceptable including unfamiliar “professionals” asking them a barrage of questions. Moreover, the use of clinical assessment tools routinely used and benchmarked for clinical rigour by specialists trained in assessments for ASD, intellectual disability, anxiety, Fragile X, Prader Willi etc is more likely to be accurate than assessors who have no clinical training or who are rewarded for the number of interviews conducted per hour.

The overnight privatisation of the NDIS model instead of a steady, careful and progressively transition to a market model has not assisted, and rorts have been common, as in the Aged Care and Child Care sectors.

A further assistance might be to revisit the trial sites (which were relatively small communities) and determine what the benchmarks should be. It is not clear whether the Schedule of NDIS Rates are realistic or cost reduction targets.

Term of Reference E

ii. assumptions, measures, and methodologies used to forecast and make projections about the scheme, participants, and long-term financial modelling;

There is a lack of awareness of the role of Australian Disability Enterprises (ADE) and other Supported Employment businesses – and even where there is that awareness, those personnel frequently move on within the NDIA in a 12 month period. This means that policy development and financial modelling is probably undertaken with a lack of robust knowledge of the NDIS ADE suppliers for PWID, and of the ADE roles and capabilities.

It should also be noted that the predominant model of Employment Services /coaches/ suppliers to the NDIS are geared to deal with people who are physically disabled but not intellectually disabled. A 20 minute session of recruitment coaching and perhaps a TAFE course will not suffice for PWID. This necessarily skews the models adopted and despatching PWID in a ‘tick and flick’ manner to multiple interviews sets the Participant up

Term of Reference G

ii. planning policy for personalised budgets and plan flexibility;

Much is made in the Annual Financial Statements released in October 2021 of the disparity between the Productivity Commission’s estimates and the experience of costs since 2017.

It is understood that there was (election) year when the number of PWD significantly increased, and the number of Unemployed persons decreased, amazingly by the same order…. Changing criteria for political expediency is not the best way for determining future costs with any degree of rigour.

The criteria for predicting who is eligible to be designated as eligible for NDIS as either a PWD or PWID should be relatively easy to compare with the number of claims from Centrelink/ Services Australia for parents who claim for their disabled child, or for adults who claim the DSP. Cross correlation with enrolments with each State’s Education Department

Change of funder from DSS to NDIS

We note further that any assertions that NDIS costs have “blown out” do not relate to this ADE. Our annual financial operations were audited and reported to the 2021 WHM Inc AGM on 26th October 2021. Our [independent] accountant advised that the costs and income from operations, income from NDIS are remarkably similar to previous (non NDIS) years, for the same number of Supervisors, the same number of Participants/Helpmates, and the same quantum & range of work carried out within the community. The only variation being due to the Pandemic and related Jobkeeper support.

In other words, the change to the NDIS as the principal source of government funding rather than DSS has had no material impact on the financial operations.

As such, any assertion that costs have “blown out” is simply wrong.

Of concern to WHM and the Advocates and families who support their Participants at WHM are the following matters:

• There still appears to be a lack of transparency surrounding any changes to the planning arrangements for NDIS Participants – how is predictable and regular consultation with Families/Carers/Participants/Advocates going to be carried out with easy, understandable access by all these groups?

• How does the NDIS intend to establish “consistent, evidence-based decision making”?

• Where is the “co-designing a person-centred assessment approach” and how do Families/Carers/Participants/Advocates fit into this meaningfully?

WHM notes previous practice for planning for PWID prior to the NDIS:

All Participants at WHM, have, at various times prior, during and after completing schooling (when most of them were assessed as being eligible for Specialist Education, rather than Mainstream Education), undertaken a variety of assessments to establish that they were, and still are, eligible for the Disability Support Pension, and subsequently for most Helpmates, for the NDIS.

Previously, DSS used to complete an independent review of all participants using DMI (Disability Measurement Instrument) every two years. All Participants at WHM were included in this process as it had been agreed that their disability was permanent and long term.

It is understood that this has been recognised by some LACs who have adopted the biennial plan model in recognition of the relative stability of the Participants – especially those

working in ADEs.

It may be that this approach could be successfully adopted as part of future planning policy for personalised budgets and plan flexibility.

4. Waverley Helpmates Inc

At Waverley Helpmates Inc. we value and respect the people we work with and act as advocates for people with disabilities. WHM seeks to enable the transition of Helpmates into open employment where practicable.

a. Mission Statement

Waverley Helpmates, a supported employment and training program, seeks to enable participants to realise their vocational potential and develop their independence through meaningful work. The program provides a quality lawn mowing, ironing and cleaning service to the local community, whilst developing Participants’ work skills and ethics.

b. History

The concept behind the Helpmates commenced in 1982 from a number of interested families, a Special School principal, a local MP and members of the wider community.

• 1982 – Moorabbin Helpmates was established which grew from a voluntary community group.
• March 1986 – Demonstration funding (Commonwealth) was provided to develop a similar group in a different location. Staff were appointed and worked out of the Moorabbin office until an area was located.
• July 1986 – a public meeting was held in Ashwood identifying two previously disadvantaged groups. (The aged who require a reliable and affordable garden service and those who wanted to work but required ongoing support and training).
• December 1986 – permanent premises were located at 14 Mavron Street Ashwood after Waverley City Council (now the City of Monash) had provided a temporary location in Montclair Avenue.
• October 1987 – the program was evaluated. There were three staff, ten participants, 190 customers and an elected Committee of Management. The process of establishing an autonomous identity had begun.
• April 1989 – Waverley Helpmates became an Incorporated Body.
• June 1990 – State Government funded a further ten positions for Helpmates and an additional two staff members.
• September 1991 – Waverley Helpmates auspice a twelve-month project; Waverley Skills Development Program.
• July 1992 – all Employment programs were transferred to Commonwealth funding.
• January 1993 – the cleaning team was developed with four participants and one staff person.
• 1997 – two people accepted under Futures for Young Adults funding
• March 2003 – first Australians Working Together (AWT) case-based funding participant accepted.
• August 2004 – first group of Helpmates moved from Block Funding to Case Based Funding.
• 2005 – 2006 Renovations were completed and the office expanded to 3 offices with addition of toilets, showers and kitchen.
• January 2006 – all remaining Helpmates moved from Block Funding to Case Based Funding. Capacity had increased to 30 Helpmates.
• October 2007 Waverley Helpmates celebrated its 21st year of operation.
• January 2008 - Commonwealth Government provided funding for three additional Helpmate places, bringing the total to 33.

• March 2009 – beginning of a small ironing program based in the Mavron Street office.
• November 2011 – loss of the cleaning team school contract and development of new cleaning directions.
• 2016 Celebrate 30 years of operation of Waverley Helpmates Inc
• 2017 commence transition to the National Disability Insurance Scheme
• 2018 EBA for Helpmates successfully negotiated with Fair Work Commission
• 2018 Manager Heather Buckland commenced Long Service Leave after 30 years as Manager
• 2019 Prav Geega appointed as the new Manager, and Helpmates transferred progressively to NDIS funding.
• 2020 During the COVID 19 pandemic lockdowns, Helpmates continued to work when permitted, or to receive training and support in an approved fashion, related to their vulnerability. Supervisors received JobKeeper.
• 2021 WHM continued to work in compliance with the Chief Health Officer’s directions during the 2021 lockdowns. All Helpmates completed transition to NDIS

The gardeners work on private gardens or major site contracts (such as retirement villages) and the cleaners work at churches, halls, private houses and local businesses. The ironers iron baskets of clothes at the WHM office. All the Helpmates have their own jobs for which they are responsible and paid. Note – WHM participants are all over 18 years+.

Waverley Helpmates is managed by a Manager and supported by a voluntary Committee of Management who review all major decision regarding the operating process and procedures, costs, investments, machinery and equipment, programs and services. WHM is an approved Service Provider to the NDIS and receives Commonwealth funding via each Helpmate’s NDIS plan.

Waverly Helpmates employs Supervisors who are qualified at a minimum of Cert. IV Disability Services, First Aid, have completed a Defensive Driving Course and have experience and training in working with people with a disability. Continual professional and personal development is undertaken annually by all managers and supervisors.

Everyone works together at Waverley Helpmates as a team to make it an enjoyable place to work.

c. Why Do People Choose to Work at Waverley Helpmates?

• The small size of Waverley Helpmates means that the Supervisors really get to know Helpmates.
• Waverley Helpmates is an independent organisation and not under the umbrella of a larger organisation.
• Helpmates are placed on individual worksites and work independently of each other or in a collaborative team environment for large customers such as Aged Care facilities where they work on a regular once-a-fortnight basis (“Backyard Blitz” style to complete all work in 1 day).
• Each Helpmate is provided with a roster of regular customers and is supported to develop good working relationships with these customers and to provide quality service to customers. Often, The Helpmates develop strong associations with their customers.
• Support provided to the Helpmates is consistent and ongoing for the duration of employment.
• There is no end date for a Helpmate’s employment, they can work at Waverley Helpmates for an extended period of time.
• Helpmates can work full time or part time.
• Waverly Helpmates has a social and training aspect as well as the work roles. Some activities regularly organised at Waverely Helpmates are: planned supported holidays, cooking courses, basketball, Melbourne Show visit, working bees for charities, cultural events reflecting the wider or Helpmates community (eg Chinese New Year, Diwali etc), Christmas parties and excursions.
• Waverly Helpmates is committed to developing a social conscience in its participants and enables and encourages fundraising and volunteering activities for other charities.

• example, Clean-up at Reefton Country Fire Association buildings, helping Avalon support the homeless, fundraising at Bunnings Chadstone sausage sizzles etc).
• Waverley Helpmates embraces cultural diversity and celebrates individual differences through events, such as cultural awareness days.
• Helpmates work on individual goals which can be solely related to their employment, or more holistically related to other aspects of their lives. These goals are based on their interests and wishes.
• Staff at Waverley Helpmates are experienced and well trained and stay for many years because they love the job.
• All Supervisors are accessible to the Helpmates on a daily basis and establish good working relationships.
• Staff members all work together as a team to support participants/Helpmates in the best way possible.
• The Helpmates have elected representatives on the COM and participate in decision making at weekly Friday meetings.
• Waverley Helpmates uses innovative methods to achieve goals, such as the “Green Card” system of individual aims and rewards, aligned with their work and NDIS goals.
• Family, friends, carers and advocates are invited to become involved in many ways and their support is encouraged and valued.

Mavron St, Ashwood, Victoria 3147 Tel (03) 9807 1155 October 2021