Submission from the Institute for Urban Indigenous Health (IUIH)

to the Joint Standing Committee Inquiry into NDIS Implementation and Forecasting

PART A: PRACTICAL ACTIONS TO IMPROVE FORECASTING AND IMPLEMENTATION

1. About IUIH: Summary Profile

The Institute for Urban Indigenous Health Limited (IUIH) is an Aboriginal and Torres Strait Islander community-controlled company limited by guarantee under the Corporations Act 2001 (Cth). IUIH delivers services and programs across three service systems – disabilities, aged care, and primary health care – to more than 50,00 Aboriginal and Torres Strait Islander people in a service delivery footprint extending from Sunshine Coast down to the New South Wales border, and out to Ipswich. It also managing the delivery of aged care services in the Lower Gulf of Carpentaria and Wide Bay in Queensland and Mildura and Bendigo in Victoria. IUIH’s annual operating budget is more than $90 million per annum and it employs more than 700. IUIH directly employs around 750 personnel, 51% of whom are Aboriginal and Torres Strait Islander. IUIH comprises four founding Member Organisations which are collectively known as the IUIH Network. The founding Members are Aboriginal and Torres Strait Islander Community Health Service Brisbane, Kalwun Development Corporation, Kambu Aboriginal and Torres Strait Islander Corporation for Health and Yulu- Burri-Ba Aboriginal Corporation for Community Health. Together the IUIH Network employs more than 1,000 staff.

2. IUIH’s NDIS and NDIA Engagements

IUIH’s interest in the Joint Standing Committee’s current Inquiry into the implementation of, and forecasting for, the National Disability Insurance Scheme (NDIS) is principally attributable to our direct engagement with the National Disability Insurance Agency (NDIA) in relation to the “Indigenous NDIS Pilot Project of National Significance”, (hereafter referred to as the “Pilot Project”) and to subsequent encounters with the NDIA after the completion of the Pilot Project.

Negotiating the Pilot Project with the NDIA between late 2017 and March 2019 proved challenging. NDIA senior managers and middle managers rejected any suggestion that the NDIS should make provisions in contracts with community partners for Aboriginal and Torres Strait Islander Participant access targets and opposed proposed modifications, preferring ‘one size fits all’ implementation arrangements for access, assessment, Plan development and Plan determinations. NDIA senior managers and middle managers refused to accept the proposition that the commitments of the Australian Government and the eight jurisdictional Governments to “Closing the Gap” had any relevance to their agency or to the NDIS. However, with the support of one Deputy Chief Executive Officer in March 2019 a contract was finally offered to IUIH for an 18-month only Pilot Project; this Deputy CEO exited the NDIA several months later.

IUIH was required to furnish Monthly Progress Reports to the NDIA on the status of the Pilot Project’s implementation achievements against two contracted performance deliverables – 500 Aboriginal and Torres Strait Islander people living with disability to have achieved ‘access met’ status and 500 to have achieved ‘approved Plan’ status. The Monthly Progress Reports were also required to provide comments on implementation processes including obstacles, blockages, and case studies. We attach a copy of IUIH’s Final Report for August 2020 for the information of Joint Standing Committee members.

From the outset of the Pilot Project, at the end of March/beginning of April 2020, the NDIA failed to deliver on its core commitments and only began to do so around November 2020 when a particular Brisbane Regional Manager took an interest in the Pilot Project. This

Regional Manager identified that proper implementation of the arrangements envisaged by the Pilot Project led to the NDIS Pilot achieving ‘access met’ rates that were 3 times better, and ‘Plan approval’ rates that were 10 times better, than standard NDIS arrangements.

IUIH’s proposition to the NDIA had always been that culturally appropriate implementation through trusted, known Indigenous intermediary organisations could achieve realistic access and participation targets. This is not a new proposition. There are multiple examples of ‘one size fits all’ whole of population service delivery mechanisms failing Aboriginal and Torres Strait Islander people and of successful targeted mechanisms that achieve far more effective outcomes.

3. Improving NDIA’s Forecasting and Implementation

IUIH believes that the forecasting and the implementation of the NDIS by the NDIA should be thoroughly reformed.

On the forecasting dimension, the NDIA should be setting ‘access achieved’ and ‘Plan approved’ targets of at least 7% of all Aboriginal and Torres Strait Islander people.

On the implementation dimension, the NDIA should roll-out the parallel access- assessment-Plan arrangements which were successfully trialled in the Pilot Project across all regions in Australia.

3.1. Forecasting a 7% Access and Participation Rate for First Nations Peoples

IUIH proposes that a realistic minimum size of the potential NDIS Participant client market should be 7% of the Indigenous population.

This is based on the Australian Institute of Health and Welfare (AIHW) estimate of 7.3% of the Indigenous population with a severe or profound disability^1.

^1 AIHW Disability Support for Indigenous Australians, September 2019

range of relevant statistical collections. For example, among Indigenous Australians aged 15 and over living in non-remote areas, the rate of severe or profound disability was:

• 7.2%, according to the ABS 2015 Survey of Disability, Ageing and Carers (SDAC)
• 7.8%, according to the ABS 2014-15 National Aboriginal and Torres Strait Islander Social Survey (NATSISS)
• 8.5%, according to the ABS 2016 Census^2

These data reflect prevalence rates of Indigenous people with a severe or profound disability that are almost twice those of non-Indigenous Australians based on age-standardised rates.

Further, this minimum forecasting approach is corroborated by the NDIA’s estimation methodology, which has identified the ABS Census ‘Core Activity Need for Assistance’ (profound or severe) data as the preferred prevalence projection:^3

‘For planning and reporting purposes, the NDIA requires projections of Indigenous participants by geographical area, such as Local Government Area (LGA). The Census is therefore used as the basis for estimating NDIS Indigenous participant numbers as it is the only source providing the required level of geographical subdivision.

Based on these considerations, and using a conservative 7% target, the estimated potential national Indigenous NDIS Participants would be 61,252^4. The latest actual national Indigenous participant data reported in the NDIA September 2020 Report is 32,396^5. According to this data, only 52.8% of the potential Indigenous NDIS Participant population are receiving disability supports, with an estimated shortfall of 28,856 potentially eligible individuals.

^2 To calculate prevalence, the ABS Census “Core Activity Need for Assistance” is used, which is an approximation for the number of people with a profound or severe core activity limitation. People with a profound or severe core activity limitation are defined as those people needing help or assistance in one or more of the three core activity areas of self-care, mobility, and communication, because of a disability, long- term health condition (lasting six months or more) or old age. ^3 NDIS Aboriginal and Torres Strait Islander Participants. Available at: file:///C:/Users/tim.albers/Downloads/PB%20Aboriginal%20and%20Torres%20Strait%20Islander%20participa nts%20PDF%20(1).pdf ^4 Calculated as follows: Estimated Indigenous Population 0-64 at June 2020 (875,038) times 7% ^5 NDIS Q$ Full Report June 2021. Available at: https://www.ndis.gov.au/about-us/publications/quarterly-reports

Apart from a total national projection of 475,000 Australians expected to receive NDIS supports^6, the NDIA has not further identified specific prevalence targets for Indigenous populations. However, broadly consistent with the above estimated national 52.8% access rate, the situation in Queensland is provided as a case study, where the Queensland Government has set an Indigenous NDIS target:

The Queensland Audit Office (QAO) projected 14,500 Indigenous people being eligible for the NDIS in Queensland by 2019^7. This QAO projection equates to approximately 7% of the Queensland Indigenous Estimated Resident Population (0-64) in 2016. Growth over the last 4 years would now make this target higher by an additional 14.4%, based on intercensal growth rates. Latest NDIS data (as at September 2020) reports 7,151 Indigenous NDIS clients in Queensland^8. This indicates only 49% of the Indigenous participation target for 2019 has been met (compared to 86% for all Queenslanders) and highlights the urgent need for new approaches to be implemented to address access barriers for Indigenous people, such as those trialled under IUIH’s NDIS Pilot. Unfortunately, Indigenous access data is not published at the NDIS Service Area level, despite representations made by IUIH to the NDIA. Future granular reporting of this kind will be essential to support the enhanced accountability measures required to monitor closing the gap objectives.

The barriers contributing to these NDIS access rates are well known and include socio- economic factors and disproportionate levels of low literacy and numeracy. Compared with non-Indigenous Australians, Indigenous Australians are:^9

• 1.8 times as likely to have disability
• 2.0 times as likely to need disability supports

^6 Parliament of Australia NDIS Quick Guide. Available at: https://www.aph.gov.au/About_Parliament/Parliamentary_Departments/Parliamentary_Library/pubs/rp/rp18 19/Quick_Guides/NationalDisabilityInsuranceScheme ^7 Queensland Audit Office: The National Disability Insurance Scheme (Report 14: 2017–18). QAO quotes ABS estimates of 14,500 based on ABS 2016 212,534 Estimated Indigenous Population in Queensland 0-64 years ^8 NDIS Quarterly Performance Dashboard, Queensland, June 2020 ^9 AIHW Disability Support for Indigenous Australians, 2019. Available at: https://www.aihw.gov.au/reports/australias-welfare/disability-support-for-indigenous-australians

For Indigenous Australians, the need is often more complex in terms of more than one disability or health issue occurring together, and it is compressed within a shorter life expectancy.

IUIH submits that the NDIA’s manner of reporting on Aboriginal and Torres Strait Islander NDIS access and approved Plan figures disguises what is an egregious failure to deliver the minimal equitable outcome of 7% for this cohort. The NDIA presents the Aboriginal and Torres Strait Islander access and approved Plan data as a proportion of all Participants rather than reporting the actual numbers. So, in the Q4 Full Report for 2020/2021 up to 30 June 2021, the NDIA reports that people who identified as Aboriginal and Torres Strait Islander comprised 9.3% of all Participants who received a Plan during Q4.

IUIH has completed extensive demographic analyses to show the geo-spatial distribution of the Aboriginal and Torres Strait Islander population throughout Australia and to identify trends in the growth of this population. These demographic analyses have been valuable in assisting first the Royal Commission into Aged Care Quality and Safety, and the Australian Government at ministerial and departmental levels, to plan targeted reforms to the Aged Care System for Aboriginal and Torres Strait Islander Elders.

These demographic data analyses can also assist the NDIA to apply the 7% minimal NDIS access target to metropolitan, regional, and remote areas in Australia.

Figure 1 below uses Australian Bureau of Statistics (ABS) data to demonstrate that the Aboriginal and Torres Strait Islander population is NOT concentrated in remote/very remote locations but is concentrated in Major Cities (37%) and in regional towns.

An Urban not a Remote Population

Figure 1: Indigenous Population by Remoteness Category, Australia

Figure 2 below shows projected growth in the Aboriginal and Torres Strait Islander population to 2031 according to ABS Indigenous Regions.

Based on the ABS population growth projections, the NDIA can confidently forecast the

Indigenous Regions where it will have to concentrate its investments to achieve the 7% minimal NDIS access target. Clearly NDIA will have to start with the Indigenous Region of Brisbane (which corresponds with IUIH’s service delivery footprint), NSW Central and North Coast, the Sydney-Wollongong region, and Perth.

Projected indig Pop Growth 20136-2031, By indigenous Region, ABS

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Regionalisation AND Urbanisation

Three regions account for 50% of growth in Australia’s Indigenous population

Ex Australia’s Indigenous Growth ‘ —— »in 3 largest L a4 Indigenous ASS 2011- % Ss Region 2016 2016 Growth a Growth & Brisbane 70,735 17,467 33% = NSW Central 69,775 17,456 33% << & North oa Coast 5 Sydney- 66,015 13,842 27% nse Wollongong w

IUIH advocates that the blueprint which the NDIA should adopt for installing effective and culturally appropriate implementation arrangements in respect of Aboriginal and Torres Strait Islander people living with disability has been known and documented since at least November-December 2019. By this time the originally agreed implementation arrangements for the Pilot Project were being applied with a reasonable degree of consistency and with demonstrable results.

Appendix A presents a process flow diagram of how the Pilot Project was designed. A summary of these implementation arrangements is provided below in a sequence of 11 enumerated points, each with a brief explanatory statement.

• (i) The broad framework of the NDIS and its key process steps remain in place, but a parallel set of implementation arrangements were authorised by mutual agreement for application to Aboriginal and Torres Strait Islander people living with disability seeking to gain access to and participate in the NDIS.
• (ii) The key process steps in the NDIS are clustered under headings of “access”, “assessment”, “Plan development”, and “Plan meetings/Plan approval”. A set of Indigenous-specific implementation arrangements were put in place for each of these four process steps.
• (iii) Operational management of these mutually agreed implementation arrangements was contracted out to a trusted Aboriginal and Torres Strait Islander community-controlled organisation – IUIH for the Pilot Project – on the basis that the organisation can demonstrate that it has community recognition and trust; has stable and reputable governance systems; has demonstrated service delivery, administrative and financial management capabilities; operates at a regional scale which is at least equivalent to an NDIS service area but preferably several service areas; and which can draw on an existing workforce for parts of the implementation arrangements. A regional Aboriginal Community Controlled Primary Healthcare Service network such as IUIH satisfied these criteria.
• (iv) Dedicated ‘Trusted Indigenous Facilitators’ would be funded by the NDIA to implement agreed operational activities across the four clusters. The Australian Government has adopted Trusted Indigenous Facilitators for its 2021/2022 Budget reforms to the Aged Care System. This role was pioneered by IUIH during the Pilot Project and the equivalent personnel were given the bland job title of ‘Project Officers’ by the NDIA.

• (v) Performance management and daily supervision of, and support to, the NDIS Trusted Indigenous Facilitators/Project Officers was provided by the Indigenous community-controlled trusted intermediary organisation at senior executive level; and this organisation furnished quantitative and qualitative information and analytical performance Monthly Progress Reports to the funding body, in this case the NDIA.
• (vi) The authoritative foundation for all implementation arrangements was based around informed consent, given by each Aboriginal and Torres Strait Islander person living with disability who wanted to apply for access into the NDIS, to a nominated Trusted Indigenous Facilitator/Project Officer. This consent authorised the Project Officer to assist the Applicant with progress along the four key process steps. At Appendix B we provide a copy of the Consent Form, which met the requirements of the NDIA.
• (vii) To facilitate efficient and timely completion of information on each Applicant’s Access Request Form (ARF), the IUIH Pilot Project made the NDIS template ARF into a writable pdf document. This enabled Applicants, their family members, the Project Officers, and treating clinicians to progressively populate the ARF usually within a fortnight. The treating clinicians were typically professionals working in clinics of IUIH and its Member Network. IUIH’s senior executive coordinated delivery of a protracted series of NDIS information and explanation briefing sessions to about a dozen different kinds of treating clinicians across 21 clinics. This investment in on-site education was self-funded by IUIH because firstly, it was considered essential to secure buy-in to the NDIS by clinicians and secondly, clinicians had to be made aware that their population of Part F of the ARF must describe a ‘functional assessment’ impact of disability.
• (viii) It took the NDIA six months to align its internal systems with the prescribed Indigenous implementation arrangements. The principal and immediate failure occurred when the National Access Team (NAT) refused to accept and act upon signed Consent Forms attached to individual Applications lodged electronically

by IUIH Project Officers. Instead, the NAT personnel processed decisions for each application – i.e., access met, access not met, further information required - and did not inform IUIH’s central focal point for the Pilot Project located in Brisbane. The effect was to exclude IUIH from the subsequent key process steps. This situation was eventually resolved, but not before more than 100 Applications had been ‘lost’ in the system and only after IUIH ceased submitting new applications on the basis that the NAT was precluding IUIH from meeting any of its contracted targets. The solution was to apply an electronic ‘tag’ to electronic Applications submitted by IUIH, which the NAT recognised internally, such that a Perth-based focal point in the NAT promptly notified the IUIH focal point of receipt of the Application and the outcomes for Applications lodged on behalf of Aboriginal and Torres Strait Islander people living with disability.

• (ix) After each notification from the NATs that an IUIH-referred access/assessment outcome had been received by the NDIA Brisbane Regional Office, they would alert each other and, by agreement, the IUIH Project Officer would usually coordinate with the Participant and with the NDIA Delegate/Planner a mutually convenient date, time, and venue for the Plan Meeting. Prior to the Plan Meeting, the IUIH Project Officer would meet face-to-face with the Participant, assist them to clarify their personal goals, and identify the service supports available from the NDIS Guide that would be needed to achieve these goals.
• (x) A protocol was established between the senior IUIH executive for the Pilot Project and the NDIA regional Manager, which concerned ‘problem solving’ for Participant cases. This protocol ensured that IUIH’s computerised client data base, which tracked Participants applications throughout the cycle of access- assessment-Plan preparation-Plan implementation, could be correlated with the NDIA’s data base to eliminate most inconsistencies. The protocol also enabled IUIH to express any concerns regarding the process.
• (xi) IUIH and the NDIA agreed that Aboriginal and Torres Strait Islander people living with disability who were successfully assisted to gain access to the NDIS and

PART B: RESPONSES TO SPECIFIC TERMS OF REFERENCES

In this Part of our Submission, IUIH provides brief responses to specific issues using the enumeration identifier from the Terms of Reference, which have been highlighted in yellow colour for ease of identification. The full Terms of Reference have been reproduced at Appendix C.

\nb. 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;

IUIH submits to the Joint Standing Committee that it is now time for the NDIS to be re-positioned into an Integrated Model of Care which should incorporate at least three Australian Government service systems – disabilities/NDIS, Aged Care, and Primary Health Care.

Page 14

IUIH has already undertaken significant practical work to break down service system silos at

the community level, and in December 2020/January 2021 IUIH submitted to the

Department of Health (at its request) a comprehensive Feasibility Study on how to achieve

service system integration. The Department is currently convening a Co-Design Committee

on this matter.

For Aboriginal and Torres Strait Islander people living with disabilities, the most cost- effective infrastructure that can deliver regional Integrated Modes of Care is the national network of Aboriginal Community Controlled Primary Health Care Services. The key impediment to achieving service system integration specifically for Aboriginal and Torres Strait Islander people living with disability, is the ongoing refusal by the NDIS to operate within the framework of National Closing the Gap Agreement commitments and establish minimal access targets.

    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;

In IUIH’s experience, variations in the relevance of Plans – that is, the degree of correlation

between Plan-funded supports and assessed needs and individual goals – and variations in funding amounts are very closely aligned with the extent of each individual Participant’s access to competent, trusted and culturally appropriate community-based supporting intermediaries.

In this respect, the NDIS is not significantly different from the Aged Care System, in that

both are complex, national, remote, technology-driven, one-size-fits-all service systems whose design and implementation create access barriers and whose resource allocation decision-making processes constitute additional barriers to navigation for many Aboriginal and Torres Strait Islander people who have eligibility for these two service systems. The difference is that the Government has acknowledged this in relation to Aged Care Services.

The Minister for Health, Hon Greg Hunt, MP, is supporting the “redacted-Year Plan for Aboriginal and Torres Strait Islander Aged Care 2021-2026” developed outside of government, and the Department of Health is driving implementation of Budget-funded reforms, utilising Indigenous community-controlled infrastructure of trusted intermediaries.

Where there is access to an infrastructure of trusted, cultural appropriate community-based intermediaries – such as occurred in South East Queensland with IUIH during 2018 and 2019

• there are discernible improvements in five dimensions of implementation:

• efficiency of the whole access-assessment-Plan development cycle
• outcomes in terms of numbers of Indigenous Participants
• outcomes in terms of access rates of Indigenous Participants
• outcomes in terms of correlation of Plans to assessed needs
• outcomes in the value of Plans.

Inconsistent decision-making was observed by IUIH during the 18 months’ duration of the “Indigenous NDIS Pilot Project of National Significance”. However, because of arrangements for the Pilot Project agreed with the NDIA, IUIH was able to ensure that, in almost all cases, Indigenous Participants assisted by IUIH were able to bring an IUIH Project Officer into Plan Meetings and then escalate concerns up to the NDIA Regional Manager to redress.

The logical remedial measure to address inequitable variations in Plan funding is to apply the operational arrangements from the “Indigenous NDIS Pilot Project of National Significance” throughout all NDIS service areas with appropriate Aboriginal and Torres Strait Islander, community-controlled organisations.

d. How the NDIS is funded,

i. the current and future funding sources for the NDIS

IUIH is aware that the topic of current and future funding for the NDIS is a matter of heated, public debate. The NDIA prefers to present a picture of annual growth in NDIS costs being caused by two factors – the annual increase in numbers of Participants joining the NDIS over and above a 2017 forecast, and the nett increase in the annual costs of all funded Plans.

The Q4 Full Report on the NDIS for the financial year 2020/2021 dated 30 June 2021 at page 16 summarised this presentation clearly. See Box below.

The IUIH points out that in presenting cost data, the NDIA relies upon using what it variously terms a Productivity Commission ‘projection’ and an ‘estimate’ dating from 2017, as the authoritative baseline from which to evaluate increases in projections of NDIS expenditure described as unacceptable deviations. Thus, in July 2021 the NDIA presented its own “projections” as at 31 December redacted21, for expenditure on the NDIS as being $4,430M beyond the 2017 Productivity Commission prediction, with even larger upward expenditure deviations in subsequent years beyond the amounts estimated by the Productivity Commission in 2017. IUIH submits that it makes no sense to use the 2017 Productivity Commission’s cost projections or estimates as authoritative and legitimate baselines for determining the appropriate scale of annual Budget investments in the NDIS in the decade of the 2020s.

Governments of all political persuasions at Commonwealth, State and Territory levels have always refused to be bound by cost projections or estimates which they publicly release for major initiatives that require multiple years to complete, including physical infrastructure projects (such as toll roads, desalination plants, and tunnels), international sporting events such as the Olympic Games, or projects connected to national defence. When it was launched the NDIS was described as the largest single reform since the introduction of Medicare. It is inconceivable that decision-makers at ministerial and bureaucratic levels believed in 2017 that expenditure projections or estimates would be uniquely prophetic in their accuracy for years into the future.

Box: The cost of the Scheme is growing more rapidly than anticipated

The Agency released a comprehensive report on the financial sustainability of the Scheme on 3 July 2021. This report uses data as at 31 December 2020 to project the cost of the Scheme (and this projection is referred to as the 31 December 2020 update). The projection is higher than both the 2021-22 Portfolio Budget Statements (PBS) and the 2017 Productivity Commission (PC) projection.

Figure 12: Comparison of 31 December 2020 update, 2021-22 PBS and the 2017 PC projection

Both the estimated number of future participants and the average payment per participant are driving total higher costs.

e. Financial and actuarial modelling and forecasting of the scheme,

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

IUIH has submitted in Part A above that a parallel Indigenous Pathway must be established, which operates within the key process step framework of the NDIS access-assessment-Plan development-Plan meeting. IUIH also has submitted comprehensive demographic data for the Aboriginal and Torres Strait Islander population, including on geospatial distribution, regional and urban concentrations, and growth projections. These data can be used by the NDIA for forecasting where to focus investments for the Indigenous Pathway.

IUIH submits that NDIA modelling should now adopt a minimal participation target of 7% for age-eligible Aboriginal and Torres Strait Islander people in receipt of approved, funded and activated individual Plans. This will require urgent action to ensure that another 28,856 Participants receive their funded Plans.

f. The measures intended to ensure the financial sustainability of the NDIS (e.g.,

governance, oversight, and administrative measures),

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;

IUIH submits that the NDIA should routinely publish performance data at a regional level, such as for NDIS service areas, for reasons of transparency and accountability. IUIH completed, in 2020, a concordance analysis, which enables us to correlate demographic and client data from NDIS service areas with both the service footprints of the IUIH Network, and Aged Care Planning Regions to local government areas. In the Joint Monitoring Committee of the Indigenous NDIS Pilot Project of National Significance, IUIH formally requested that the NDIA’s Actuary regularly furnish performance data for Aboriginal and Torres Strait Islander Applicants and Participants for service areas within the scope of the Pilot Project, but this was not forthcoming.

g. The ongoing measures to reform the scheme

ii. planning policy for personalised budgets and plan flexibility

IUIH submits that planning policy for personalised budgets and plan flexibility should be reformed to align with the pertinent arrangements endorsed for, and applied within, the Indigenous NDIS Pilot Project of National Significance. In Part A above, we itemised and outlined 11 of these arrangements.

h. Any other related matters.

IUIH submits that the NDIA has consistently prioritised attention on expanding one aspect of market development, namely, to increase the supply of service providers, including Indigenous service providers.

IUIH submits that the NDIA has consistently under-invested in the demand side of market development, which has resulted in minimally equitable levels of NDIS access and approved Plans status achieved by Aboriginal and Torres Strait Islander people living with disability. Since 2017, IUIH has consistently stated that there is no point in expanding the supply of service providers if there are inadequate and inequitable numbers of Indigenous Participants. IUIH submits that this proposition has not been accepted by the NDIA and consequently has never been acted upon.

IUIH submits that the NDIA could incorporate into contracts with Indigenous organisations performance targets at the regional level to implement supports for access-assessment-Plan development-Plan meetings to achieve the minimal 7% target for access and Plan determination.

IUIH submits that the NDIA has not invested in capacity building of Indigenous community- controlled organisations to address either the demand or the supply sides of market development. This may reflect a lack of understanding of the complex change management measures which have to be implemented by these organisations to enable robust

engagement by them in the NDIS key processes on the demand side and/or for service delivery on the supply side. IUIH has extensive experience in assisting ACCHSs to install and integrate aged care services into their organisations, and the NDIS is at least as complex as the Aged Care System. IUIH submits that the NDIA should co-design a capacity building investment strategy with ACCHSs, such as IUIH, which have practical operational knowledge of and experience with the NDIS.

Attachment A: Process Flow Diagram for the NDIS Pilot Project of National Significance

Primary Contact and Consent Form — NDIS & QCSs

Client Information:

Client name: *Date of birth: Client address: Postcode:

Contact details:

Email: preferres): Postal address:*

In the event my nominated Primary Contact is unavailable for any reason, ! authorise, and request the NDIA or QCSS contact any member of the IUIH NDIS Access and Planning team on 1800 317 378 or via email at ndis@iuih.org.au

Client Signature Date

Client phone number only to be use to confirm consent]

Unless amended or withdrawn, this consent remains valid for 36 months from the date of my signature.

lam aware | may withdraw or amend my consent for IUIH to receive information about me, at any time. Should | choose to withdraw or amend my consent, | will advise the relevant agency directly.

The Institute for Urban Indigenous Health (IUIH) of 22 Cox Road, Windsor 4030, Queensland has been engaged by the NDIA to undertake NDIS Access, Pre-Planning and Plan development support activities with identified Aboriginal and Torres Strait Islander people living with disability in South East Queensland. IUIH has also been engaged by the Queensland State Government to support individuals who fail to gain NDIS Access, to apply for QCSS support.

Attachment (C)

Terms of Reference

As part of the committee’s role to inquire into the implementation, performance, and governance of the National Disability Insurance Scheme (NDIS), the committee has decided to conduct an inquiry into current scheme implementation and forecasting for the NDIS, with a focus on how the NDIS is implemented and funded, and what supports are or should be available for people with disability in addition to the NDIS.

Terms of reference

As part of the committee’s role to inquire into the implementation, performance, and governance of the National Disability Insurance Scheme (NDIS), the committee 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.

Committee Secretariat contact:

Joint Standing Committee on the National Disability Insurance Scheme PO Box 6100 Parliament House Canberra ACT 2600

Phone: +61 2 6277 3083 Fax: +61 2 6277 5829 ndis.sen@aph.gov.au