NDIA Accountability Project

Streamlining NDIS registration for community pharmacies

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SUBMISSION

Inquiry into the future of the NDIS

Comments by the Pharmacy Guild of Australia to the Joint Standing Committee on the National Disability Insurance Scheme: Inquiry into current Scheme implementation and forecasting for the NDIS

Date: 29 October 2021

National Secretariat Level 2, 15 National Circuit, Barton ACT 2600 PO Box 310, Fyshwick ACT 2609

INTRODUCTION

The Pharmacy Guild of Australia (the Guild) is the peak national pharmacy organisation representing community pharmacy. The Guild aims to promote, maintain and support community pharmacies as the most appropriate primary providers of health care to the community through optimum therapeutic use of medicines, medicines management and related services.

The Guild and its more than 5,800-strong community pharmacy network across Australia have a long record of delivering evidenced-based programs for Government and consumers, consistently demonstrating a capacity to deliver significant outcomes within substantial budget and time constraints in often complex and multi-organisation frameworks.

As the health system evolves, and community pharmacists seek to practise to their full scope in providing primary health care, the Guild will continue to invest its efforts in the future of community pharmacy, suring the profession is responsive to the community’s needs.

The Guild welcomes the opportunity to provide comments into the inquiry into National Disability Insurance Scheme (NDIS) planning and supported independent living, and in this case into current scheme implementation and forecasting for the NDIS. Our comments in this submission highlight the role and activities that pharmacists and community pharmacy provide to support people living with disabilities and their families. Our aim is to assist in the ongoing awareness of NDIS planners to understand and include community pharmacy as a resource.

Key points:

  • The National Disability Insurance Agency (NDIA) should consider streamlining the process for community pharmacies to become registered NDIS providers.
  • The NDIA should consider that community pharmacies can provide greater support as providers to NDIS participants especially in regional and rural areas.
  • The NDIA should consider increasing the avenues for community pharmacies to become NDIS providers, and the potential for rural and remote community pharmacies to become Local Area Coordinators to better support participants in these areas and reduce inequities.
  • As experts in quality use of medicines, medication management and safety, community pharmacists are integral to the NDIS service provision team.
  • The NDIA must address the current barriers to community pharmacies registering as NDIS providers, including complex registration requirements and the prohibitive cost of regular audits.
  • The Guild recommends that the NDIA incorporates the QCPP accreditation program into the NDIS registration requirements to replace the current accreditation requirements for pharmacies.

Terms of Reference

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;

Community pharmacies provide equipment and products to elderly patients and those living with a disability, including NDIS participants. These include mobility and independent living aids, and products such as incontinence aids and other personal care items that assist people to live independently. Provision of these supports is, however, often not funded through the NDIS, and there is potential for community pharmacies to provide greater support to NDIS participants in a funded capacity to ensure that NDIS participants are not impacted by barriers to service provision.

As Australia’s most frequently accessed healthcare providers,1 community pharmacies can improve the accessibility of NDIS services by:

  • Referring patients to a GP who can apply for the person to participate in the NDIS.
  • Providing information and resources to help those who are eligible to apply for the NDIS.
  • Providing evidence to assist with a person’s NDIS application, for example a statement of the medicines an individual takes, or evidence of the medical aids they use.

The complexity of the NDIS registration process is a barrier for NDIS providers, particularly due to differing compliance and reporting requirements across jurisdictions. The National Disability Insurance Agency (NDIA) should consider streamlining the process for community pharmacies to become registered NDIS providers. More registered community pharmacies providing funded NDIS services will maximise participant access to the NDIS. It is possible that there is a lack of awareness among pharmacies of how to become a registered NDIS provider, and the Guild could assist with promotion and provide support to pharmacies in the registration process. However, the NDIA must first address the current barriers to community pharmacies registering as NDIS providers, including complex registration requirements and the prohibitive cost of regular audits. We have detailed this further under our response to Terms of Reference H).

The NDIA should also consider the potential for community pharmacies to provide support through the Information, Linkages and Capacity Building grants program (ILC), particularly through Stream One: Information, linkages and referrals.2 Pharmacies can connect people with a disability, their families and carers with appropriate disability, community and mainstream supports by providing the following services from this Stream:

  • Information about targeted supports for people with disability, their family and carers, including generic community-based supports.
  • Support to use existing information sources or referral to relevant organisations to get information.
  • Information that addresses the needs of culturally and linguistically diverse consumers.

With appropriate resourcing and support, community pharmacies can also assist with public campaigns to

improve the community’s general disability awareness and understanding (part of Stream Three: Community awareness and capacity building)3 as pharmacies are highly involved in health-related public awareness campaigns.

In the interest of building genuinely connected and engaged communities, the NDIA should also consider the potential for community pharmacies to become Local Area Coordinators (LACs) to strengthen connections between NDIS participants and providers, particularly in rural and remote areas, where there are less avenues for access. Community pharmacists possess local knowledge of disability services and their local community, are a highly accessible service provider, and with appropriate resourcing and support are capable of delivering the LAC services described in the frame ILC Policy Framework.4

Terms of Reference 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;

Community Pharmacies Can Provide Greater Support As Providers To Ndis Participants

Many health services for NDIS participants provided through community pharmacy are not currently funded through NDIS plans or other programs, and many services are provided to people with a disability who are not NDIS participants. Instead, such services are paid for by patients. These services are held to a high standard under Quality Care Pharmacy Program (QCPP) requirements and are readily available to NDIS participants.

Beyond dispensing medicines, pharmacists support patients with identifying and managing a range of non-complex common conditions, including non-prescription treatments and/or referrals to other healthcare practitioners as appropriate. Community pharmacists also develop close relationships with consumers and are often vital advocates for the health and well-being of their communities. This community knowledge can facilitate tailoring of services to NDIS participants to support greater access and equity of service provision.

Community pharmacies can also provide services to NDIS participants living in community care homes or Specialist Disability Accommodation.5 For example, in South Australia some pharmacies provide medication management reviews to residents who are living with a disability in the community within Supported Community Accommodation services.6

Community pharmacists also offer support to patients in private consultation rooms, which can involve disease-state screening and referral to appropriate services as required. Some issues require different support mechanisms, for example patients may require advice on improved pain management or smoking cessation. Where there are identified clinical needs, patients can be referred to a GP for diagnosis and treatment.

Terms of Reference C) The reasons for variations in plan funding between NDIS participants with similar needs, including:

ii. the drivers of inequity between NDIS participants living in different parts of Australia, i i. 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;

The Guild supports the Joint Standing Committee’s investigation into the reasons for variations in plan funding between participants. It is imperative that the scheme is equitable for all participants regardless of their location, and any inconsistencies in NDIA decision-making and variations in plan funding must be avoided.

For example, reports have highlighted that “families from lower socio-economic backgrounds may have difficulty navigating complex NDIS systems”, and “support for families in remote and very remote areas needs to be improved from the Agency and from providers due to a supply/demand imbalance for allied health professionals.“7

In relation to inequities arising from remoteness, community pharmacies are ideally placed to provide equipment and aids to NDIS participants in remote areas where other health practitioners are not accessible. There are more than 5,800 community pharmacies across Australia,8 and on average 66% of people living outside capital cities live within 2.5 kilometres of a community pharmacy.9 The vast majority of pharmacies are open after-hours and on weekends,10 providing ready access to highly qualified health professionals without the need for an appointment. The NDIA should consider increasing the avenues for community pharmacies to become NDIS providers, and the potential for rural and remote community pharmacies to become Local Area Coordinators to better support participants in these areas and reduce inequities.

Increasing the avenues for community pharmacies to become NDIS providers will not only improve participants’ access to services, it will also mean that the activities of community pharmacies will be recorded within the NDIS system. This will enable the NDIA to obtain more accurate data about the services and supports needed by Australians with a disability, so that the NDIS can identify and address the needs of people with a disability who are not yet NDIS participants.

In regard to NDIS supports for Early Childhood Early Intervention (ECEI), there is also “room for improvement with promoting culturally safe and responsive practice for those from Aboriginal or Torres Strait Islander and Culturally and Linguistically Diverse backgrounds and for LGBTIQ families.“11 The guild is supportive of removing any barriers to access to ensure that the NDIS is equitable for all participants.

Terms of Reference D) How the NDIS is funded, including:

i. the current and future funding sources for the NDIS, i i. the division of funding between the Commonwealth, States and Territories, and iii. the need for a pool of reserve funding;

The Guild does not have a response to question Terms of Reference D.

Terms of Reference 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;

The Guild does not have a response to question Terms of Reference E.

11 NDIA, Department of Social Services, National Disability Insurance Scheme: A Framework for Information, Linkages and Capacity Building, November 2020, https://www.ndis.gov.au/media/2892/download?attachment

Guild Submission – Inquiry into he future of the NDIS p 6 of 9

Terms of Reference 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, iι. 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;

The Guild supports the appropriate disclosure of accessible and timely reporting of data and outcomes from the NDIS. We support and acknowledge the extensive reporting and information that is currently available, however we recommend further simplifying this information to ensure that it is accessible and transparent to a range of users including the public.

Terms of Reference 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

The Guild generally supports ongoing measures to reform the NDIS including the new early childhood intervention approach and the planning policy for personalised budgets and plan flexibility. The Guild supports the recommendations listed in the ECEI Implementation Reset Project Consultation Report12 to improve NDIS access for children under age 7 with developmental delay or disabilities and their families.

The Guild generally supports the new planning policy for personalised budgets and plan flexibility, however we acknowledge the concerns expressed by NDIS participants, their carers, and providers as outlined in the recent post-consultation reports.13 It is imperative that any new planning process primarily serves NDIS participants as the central stakeholders of the NDIS. While we acknowledge that this inquiry focuses on financial forecasting, the needs and perspectives of NDIS participants must be the primary focus of any new process and decision made about the scheme.

Terms of Reference H) Any other related matters.

The new policy for personalised budgets and plan flexibility should ideally make it easier for participants to choose where to obtain various mobility and independent living aids, equipment and products such as wheelchairs, walking frames, incontinence aids and other personal care items that help them to live independently. As community pharmacies frequently provide these equipment and products to patients, The new policy should make it easier and simpler for community pharmacies to become registered NDIS providers to provide these services in a funded capacity.

Recommendations:

  • The cost of delivering NDIS services by community pharmacists be considered and remunerated by the NDIA, as community pharmacies are a critical healthcare provider in a small business environment.
  • Addressing the complex structure of service delivery under the NDIS to reduce barriers to access for NDIS participants.
  • Received complaints from NDIS-registered pharmacies about claims through myplace portal taking up to six months to pay and non-user-friendly claiming portals.

Barriers to registration include:

  • Complex requirements such as compliance with NDIS Terms of Business, Guide to Sustainability, Quality and Safeguards requirements of the NDIS Commission, and State or Territory jurisdictional requirements for specialist disability support deliveries including additional compliance activities.
Cost considerations: Regular external audits required (three-yearly) performed by Approved Quality Auditors at costs ranging between $3000-$15000 which is prohibitive for small businesses despite 94% being accredited via QCPP program complying with AS85000:2017 standards. The NDIA should consider this accreditation sufficient.

We acknowledge that the Australian Government currently requires QCPP accreditation for a community

pharmacy to administer COVID-19 vaccinations, with the Expression of Interest form stating:

   "Please indicate if you hold Quality Care Pharmacy Program (QCPP) accreditation or will be in
    the process of attaining accreditation within six months of lodging the EOI to participate in the
  COVID-19 Vaccination Program (the Commonwealth may waive the requirement to hold or be
   seeking accreditation in order to ensure patients can access the program)."18

We recommend that the NDIA incorporates the QCPP accreditation program into the NDIS registration requirements to replace the current accreditation requirements for pharmacies. QCPP pharmacies undergo audit every two years, and the NDIA could exempt a pharmacy from undertaking an audit if it is already accredited through the QCPP program. This would allow pharmacies to avoid paying duplicative fees for multiple accreditation programs, which would lead to more pharmacies registering as NDIS providers and greater access opportunities for NDIS participants.

18 Pharmacy Programs Administrator, Portal User Guide Expression of Interest: Community Pharmacy COVID-19 Vaccine Roll Out, hhttps://www.ppaonline.com.au/wp-content/uploads/2021/02/Portal-User-Guide-EOI-Community-Pharmacy-COVID-19-Vaccine-Rollout.pdf