NDIS implementation and performance

Submission by Osteopathy Australia to the Parliamentary Joint Standing Committee

October 2021

Contact

Contact Peter Lalli, Senior Policy Officer- Clinical Excellence, for questions or comments about this submission via phone: (02) 9410 0099

Executive summary and recommendations

Osteopathy Australia welcomes the opportunity to lodge a submission to the Joint Standing Committee.

We are regularly involved in discussions concerning the NDIS, legislative and operational issues through our frequent involvement with Allied Health Professions Australia’s Disability Working Group, liaisons with participants and service providers themselves, including members of Osteopathy Australia servicing self and/or plan managed participants, and other providers. As such, this opportunity for feedback is valued and we hope the committee receives our feedback in a spirit of partnership toward improving the service experience for NDIS participants and creating the person-centred flexible scheme that was originally envisaged.

Specifically, our submission addresses the following Terms of Reference for the inquiry and makes the following recommendations:

The interface 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

Recommendation 1: to provide for a diversified and cost-efficient future service market, the Joint Standing Committee should recommend that the NDIS move away from a registration approval model for allied health professionals based upon titles and toward one based on professional scopes of practice per the Medicare Benefits Schedule precedent.

Recommendation 2: the Joint Standing Committee should recommend the NDIS publish a clear guide for allied health professions wishing to apply for registration to deliver services for specific support clusters per their scopes of practice, such as therapeutic supports.

Recommendation 3: the Joint Standing Committee should recommend that all professions able to provide ‘disability related health supports or complex health care’ under the Commonwealth ACFI be generally accepted as appropriate to provide such supports to NDIS participants.

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Recommendation 4: the Joint Standing Committee should recommend that the NDIS recognise the strong overlap between assessing functional impairment and likely permanency in acquired disability and inherited disability, and allow all professions involved in the former within state or territory systems to participate in the latter. This would relieve system pressure, demand, and wait times.

Whether inconsistent decision-making by the NDIA is leading to inequitable variations in plan funding, and measures that could address any inequitable variation in plan funding

Recommendation 5: the Joint Standing Committee should recommend the NDIS take a rigorous approach to plan management service accreditation requiring continuous:

Proof the plan management service has recruited staff with a strong and proven track record of applying person-centred, client-focused approaches
Proof plan management services have provided their staff with person- centred communication and engagement training once recruited.

Recommendation 6: to prevent conflicts of interest that could impact participants, the Joint Standing Committee should recommend the NDIS require plan management services to publicly disclose all local services (allied health and non- allied health) with which they have a partnership, cross promotional relationship or affiliation that could have a coercive effect. This would enable participants, their families, and carers to assert their rights more appropriately in plan use and service access decisions.

Recommendation 7: the Joint Standing Committee should recommend that the NDIS take an active role in growing plan manager awareness of the roles various allied health professions may have in achieving funded support goals; the scheme could draw from associations including Osteopathy Australia and the national peak body, Allied Health Professions Australia (AHPA). Doing so would go some way toward establishing the diversified provider markets the scheme has long sought. Written resources, webinars, and e-learning modules are all strongly advised options.

Recommendation 8: the Joint Standing Committee should recommend the NDIS take an active role in assisting participants to make informed choices about the allied health professionals they could access. Written checklists featuring clear prompts to distinguish appropriate practitioners, irrespective of title, could be used. For example, applied to osteopathy and comparable neuromusculoskeletal disciplines, this checklist could be as simple as ‘is the osteopath talking to you about exercise approaches they could use with you?’, ‘is the osteopath talking about how they can best support you to use your program in the community, such as in parks, open spaces, with your family and friends?’, ‘is the osteopath talking to you about how

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they will track changes you make toward your goal?’. Such checklists would legitimise the choices participants may wish to make in the face of misplaced or inappropriate plan manager or scheme resistance.

Recommendation 9: the Joint Standing Committee should recommend that the NDIS fund more independent individual disability advocacy services and better promote such services to participants.

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

Recommendation 10: the Joint Standing Committee should recommend the NDIS fund trials of various multidisciplinary and transdisciplinary service configurations to identify models that may work toward meeting its vision of early optimal intervention in naturalistic environments. The Joint Standing Committee should impress upon the NDIS, need to consult with professional associations including Osteopathy Australia in identifying clinical roles that could be assumed in trial designs with reference to full professional scopes of practice.

The planning policy for personalised budgets and plan flexibility

Recommendation 11: the Joint Standing Committee should recommend the NDIS amend its support clusters and pricing support guides, removing the limited profession specific criteria now applied. For domains of musculoskeletal functional care able to be provided in the community, guides should simply specify ‘AHPRA registered musculoskeletal practitioners’.

Recommendation 12: the Joint Standing Committee should recommend the NDIS engage in consultation with peak professional bodies to differentiate plan goals where specialist service access is advised as opposed to generalist services or professionals— whether osteopaths or physiotherapists in a general primary care setting.

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Osteopaths and people with a significant lifelong disability

Osteopaths are skilled government regulated allied health professionals applying adaptable and diverse clinical management approaches. Osteopaths complete a dual Bachelor or Bachelor/Masters qualification covering functional anatomy, biomechanics, human movement, the musculoskeletal and neurological systems as well as clinical intervention approaches.

As a defining characteristic, the osteopathic profession emphasises the neuromusculoskeletal system as integral to function and uses client-centred biopsychosocial approaches in managing presenting issues. Evidence informed reasoning is fundamental to case management and clinical intervention. Osteopaths prescribe skilled clinical exercise, including general and specific exercise programming for functional improvement in activities of daily living. ii

Osteopaths are consulted for advice on physical activity, positioning, posture, and movement in managing a diverse range of neuromusculoskeletal functional impairments. Most osteopaths are consulted within primary care practices, being a key source of allied health advice for tens of thousands of people per week. Osteopaths work within hundreds of primary health care practices, both osteopathy specific and multidisciplinary. Osteopaths also work in aged care, disability service or rehabilitation settings/programs, including settings receiving state jurisdictional or Commonwealth government funding.

For people with acute or persistent pain, osteopaths may offer lifestyle and/or movement advice, injury specific exercises, manual therapy, and health promotional strategies to aid symptom recovery. Osteopaths apply contrasting clinical management approaches when managing people with significant physical disabilities and/or other disability syndromes with a physical impact. Osteopaths acknowledge that growing skills for self-coping and community participation is the overarching goal, despite what may be persisting health care symptoms.

Osteopaths, applying person-centred care:

Review and identify functional capacity and movement barriers to individual goal fulfillment and/or community participation
Aid and educate participants, their families and carers on mobility, mobility strategies and whole-body movement for participation in the home and community
Assist participants in developing and applying physical skills needed for activities of daily living, including coordination, strength, flexibility, stability, conditioning, and balance
Assist participants in establishing whole body movement styles and postural interventions preventing injury in activities of daily living

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Where appropriate, manage pain associated with movement that could compound core activity limitations.

Osteopaths, in meeting these disability care objectives:

Observe participant movement and function in specific environments to assess barriers to whole-body physical skill use
Perform assessments of physical function, including but not limited to muscular strength, joint movement, and limb function
Recommend and prescribe mobility equipment assisting participants to stand, walk and move around more easily or independently within their home, school or local community
Provide advice and education to participants on positioning and posture in undertaking daily living activities
Design and prescribe exercises, motor related activities and tasks, whether land or water based (hydrotherapy) that can enhance whole-body movement or specific functional skills.

These skillsets inform tertiary educational content for all osteopaths in the country. Osteopathy regulators, the Australian Health Practitioner Regulation Agency (AHPRA) and Osteopathy Board of Australia (OBA), require each osteopathy registrant to possess attributes and skills aligned with the Capabilities for Osteopathic Practice (2019).Osteopaths must make a measurable contribution to neuromusculoskeletal function, adhere to best available neuromusculoskeletal evidence, work in an interdisciplinary and coordinated fashion, and encourage individual empowerment in clinical care.i

Specifically, on graduating an osteopathy course, registrants must be able to:

Identify and understand individual goals and concerns
Evaluate the social determinates of core activity limitations interacting with physiology
Develop and review management plans based on sound clinical evidence to facilitate optimum participation in activities of daily living
Development clinical management interventions incorporating manual therapy, exercise and activity-based interventions, educational interventions, and assisted movement strategies

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Apply appropriate standardised outcome measures for milestone mapping, including measures of disability and function. ii

These overlapping capabilities are shared by other allied health professionals, including musculoskeletal physiotherapistsiii; as such, they are interdisciplinary and are not the preserve of any one profession.

Many osteopaths are consulted by self and plan managed NDIS participants for support goals associated with growing skills for daily activities- among the most important being independent living skills like mobility, coordination, physical conditioning, gross or fine motor skill management and dexterity. Osteopaths also work with carers, families, plan managers and support coordinators to maximise participant capacity for community participation.

Osteopathy Australia

Osteopathy Australia is the national peak body for the osteopathic profession. We promote standards of professional behaviour over and above the requirements of AHPRA registration. A vast majority of registered osteopaths are members of Osteopathy Australia.

Our core work is liaising with state and federal government, and all other statutory agencies, professional bodies, and private industry regarding professional, educational, legislative, and regulatory issues. As such, we have close working relationships with the Osteopathy Board of Australia (the national registration board), AHPRA, the Australasian Osteopathic Accreditation Council (the university accreditor and assessor of overseas osteopaths), schemes in each jurisdiction, and other professional health bodies through our collaborative work with Allied Health Professions Australia (AHPA). Osteopathy Australia sits on AHPA’s Disability Working Group that explores and reviews legislative, reform and operational issues for the allied health sector. We also engage extensively with service delivery networks in the community, including plan management organisations, individual plan managers, support coordinators, NDIA staff and with participants themselves. In our capacity, we offer this submission to the Joint Standing Committee inquiry into NDIS implementation and performance.

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Opening comments

Osteopathy Australia greatly appreciates the role of the Parliamentary Joint Standing Committee in giving oversight to NDIS implementation and performance.

Unfortunately, we are not sure what the scheme itself does with feedback received, although it does open a new consultation quite often. We hold concerns consultation arrangements initiated by the scheme tend to be ‘tick the box’ opportunities given there is hardly a single summary released on themes captured, what the scheme will take onboard, what it will not, and why or why not.

It is simply not satisfactory that the scheme receives regular feedback on how to strengthen provider markets, better manage demand, reduce cost pressures, as well as offer greater choice and control, yet does what appears to be nothing with it. We therefore sincerely thank the Joint Standing Committee for its role.

Please note, recommendations made within this submission may apply to the NDIS proper, the NDIS Quality & Safeguards Commission, and/or operations performed by both arms.

The interface 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

The NDIS has failed to adopt advancements from other Commonwealth care schemes, as well as state and territory regulated rehabilitative services for people with acquired disabilities. In particular, the scheme does not make full use of appropriate allied health professional markets for indicated assessment and clinical therapeutic services despite strong cross agency and cross jurisdictional precedents for provider diversification. Diversification would make for a more seamless interface between NDIS operations and other jurisdictional or agency programs applying an ‘enablement’ or ‘recovery’ philosophy, while also relieving continuing NDIS market and cost pressures. Below we outline three key examples and recommend specific learnings and actions be adopted in NDIS regulatory and operating frameworks.

Medicare Chronic Disease Management (CDM) and & NDIS rules- logical inconsistencies

The Medicare Benefits Schedule Task Force (2015-2020) ruled that in determining allied health professional groups for chronic disease management, scopes of professional practice, competencies and skills override ‘professional titles’. For this reason, the Chronic Disease Management Program (CDM) deems osteopaths and physiotherapists equally appropriate for the management of persistent neuromusculoskeletal disorders, injuries, and related issues. Both professions are not circumscribed in the interventions they can provide within the program, and both

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often apply aligned musculoskeletal assessments, outcome measures, active management approaches, movement instruction (with or without assistance) and positional advice. Instead of seeing this as an inter-professional parity, the scheme has sometimes fallaciously pointed to the participation of osteopaths within Medicare as “proof” that the profession is health focused, while ignoring the same point for physiotherapy.

Scheme determinations regarding allied health professional group participation within registered support clusters are altogether disconnected from the Medicare Benefits Schedule approach; the scheme’s model for profession group approval for a support cluster continues to rely upon professional titles, with inevitable restrictive market supply outcomes and cost inflation. The broader consequence is that people with complex or chronic health support needs (whether with or without a disability) have greater choice of allied health providers under Medicare than within the NDIS. This is paradoxical given the scheme was created with the ostensible goal of optimising ‘choice and control’.

NDIS participants unable to have choice between competent allied health professionals with overlapping scopes via the scheme return to Medicare services for referral to allied health providers of their choice for evidence based clinical therapeutic services that help them participate in their community; this is a cost displacement onto another Commonwealth portfolio for disability related support within the ambit of the NDIS.

We have engaged with the scheme to understand the profession group approval assessment processes in place for registration approval within support clusters. While we have been informed of a process informally, we have been unable to follow it up in widely published scheme documentation.

Recommendation 1: to provide for a diversified and cost-efficient future service market, the Joint Standing Committee should recommend that the NDIS move away from a registration approval model for allied health professionals based upon titles and toward one based on professional scopes of practice per the Medicare Benefits Schedule precedent.

Recommendation 2: the Joint Standing Committee should recommend the NDIS publish a clear guide for allied health professions wishing to apply for registration to deliver services for specific support clusters per their scopes of practice, such as therapeutic supports.

The Aged Care Funding Instrument (Complex Health Care) and NDIS/plan manager determinations regarding appropriate allied health professions for disability related health support and/or disability related pain management- logical inconsistencies

We sometimes hear from dissatisfied self or plan managed participants with NDIS funding for disability related health supports who have faced obstacles to accessing

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an osteopath for care. This is despite that an osteopath is entirely appropriate wherever a health support or pain management intervention is linked to a physical disability or other disability with a physical impact.

We have witnessed occasional correspondence to self and plan managed participants from the scheme or plan managers stating that “osteopathy is a complementary practice that is not funded by the NDIS”. With this approach to market restriction, it is little wonder the scheme is experiencing the cost blow-outs it is, as well as pricing deregulation barriers.

We again stress that osteopathy is a recognised neuromusculoskeletal allied health discipline that has proven precedent in offering disability related health supports for Commonwealth funded services. We state emphatically that the NDIS sometimes stands alone from other Commonwealth programs in its determinations. Take for example, residential aged care services for people with a disability related to the ageing process; such services can access funding for an osteopath (as one of an exclusive group of allied health professionals, including physiotherapists) via ACFI 12 Complex Health Care funding arrangements. When a facility accesses this funding, osteopaths, like physiotherapists, can offer complex care assessments, pain management services and technical interventions requiring specific types of equipment. This is precisely what the NDIS would define as a disability related health support.

The inevitable consequence is that older people with a disability (or facilities on their behalf) can have more choice to consider an osteopath for disability related health supports than people under the age of 65 with significant lifelong disabilities. This is clearly an equity issue.

Recommendation 3: the Joint Standing Committee should recommend that all professions able to provide ‘disability related health supports or complex health care’ under the Commonwealth ACFI be generally accepted as appropriate to provide such supports to NDIS participants.

Functional capacity & disability assessments for people with acquired disabilities from a serious injury within state-based schemes and the NDIS- logical inconsistencies

In the two jurisdictions osteopaths mainly reside (NSW and Victoria), the profession is approved to be employed within workplace rehabilitation services offering neuromusculoskeletal disability assessment services.

These services conduct assessments of movement and physiological potential for undertaking activities of daily living; the services grade a person’s impairment and likely ongoing impairment for work and/or domestic tasks after a serious accident or injury. Another function of these services is reviewing the clinical support plans of professionals involved with a person to appraise the extent to which they maximise

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capacity for client recovery, empowerment and independence. In NSW, physiotherapists, osteopaths, and exercise physiologists can be employed to provide these services and to our knowledge, the same applies in Victoria. We stress that many people accessing workplace rehabilitation services have significant lifelong disabilities acquired through an incident causing major life change, not dissimilar to NDIS participants with an inherited disability.

However, referring to the NDIS, osteopaths are not even an in-scope profession for writing participant letters of support. The profession is excluded from providing recognised assessment evidence for participants despite its experience using disability outcome measures including WHO-DAS, WHO-DAS 2, PEDI-CAT and its background in functional capacity assessment delivery. Clearly, there are significant workforce skills being under-utilised by the NDIS either through ignorance or deliberate neglect. Either way, fuller use of the workforce would better enable demand management, reduce wait times, and lead to more timely determinations for participants.

Recommendation 4: the Joint Standing Committee should recommend that the NDIS recognise the strong overlap between assessing functional impairment and likely permanency in acquired disability and inherited disability, and allow all professions involved in the former within state or territory systems to participate in the latter. This would relieve system pressure, demand, and wait times.

Whether inconsistent decision-making by the NDIA is leading to inequitable

variations in plan funding, and measures that could address any inequitable variation in plan funding

For our response to this item, we focus not so much on inconsistent decision making by the NDIS, but by partnered plan management services. Firstly, while we have had thoroughly insightful discussions with some plan managers who are willing to explore all possibilities with participants and facilitate as much scope for independence as appropriate, we encounter some who are not even sure what their role is, or what they should be doing. This is not said in jest, although we wish it were. For us, this raises flags around the effectiveness of service accreditation for quality and safeguarding, recruitment and upskilling processes in plan management services.

More broadly, we are aware of instances where participants with similar impairments, syndromes and personal strengths have had vastly unequal levels of decision making over their support plan and funding. Plan managers, even when sure of their role, sometimes take completely divergent approaches toward participants able to make their own service decisions. Some plan managers interpret their role to mean ‘gatekeeper’ and ‘enforcer for the NDIS’ and have given this construct a higher priority than person-centredness. This is not what the NDIS was designed to achieve. We recall the scheme being promoted early in its rollout with

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slogans like the scheme will move away from ‘system-centred approaches’ to ‘person-centred approaches’, and that is certainly not what has happened across the board.

It is accurate to say some ‘system-centred’ plan managers actively undermine the plan management model, making it no different to the very structured services a participant would have received in historical state or territory arrangements, albeit in the community. The result is that some participants are directed toward services a plan manager may be familiar with at the expense of an open and transparent review of suitable options. In these instances, plan managers contravene the very scheme guidelines they are meant to follow. We refer to three relevant portions of these guidelines below (September 2020), outlining the role of plan managers as background for the Joint Standing Committee:

2.4 Consumer awareness

Plan management providers are expected to uphold participant rights as consumers, and in line with their plan, enable a participant to exercise greater choice and control over the supports and services they engage.

These rights apply to disability items or services bought with NDIS funding, in the same way they apply to other goods and services. With the support of a plan management provider, a participant should be encouraged to make informed choices within the market.

providing access as required to a wider range of service providers, including non-registered providers, while ensuring compliance with the price limits contained within the NDIS Price Guide.

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4.1.5 Information regarding providers of supports

A plan management provider may be aware of available providers (including registered and non-registered providers) in a location where a participant lives and can provide this information where needed. While a plan management provider may choose to provide this information to a participant, the decision remains with a participant as to how they exercise their choice and control over the providers of the services they need.

A plan management provider is required to

As stated earlier in this submission, many osteopaths apply functional movement interventions, graded movement interventions, gross and fine motor skill interventions, and assisted movement or positioning advice in naturalistic environments to increase independence for people with a disability. These interventions are not dissimilar to those that would be offered by counterparts in physiotherapy and exercise physiology.

Despite that our members across the country put much work into liaising with plan managers in a risk managed way before commencing a service relationship with participants, namely, by documenting the sub goals to be worked toward in meeting a milestone, progressions indicated and their basis in evidence, some plan managers simply refuse this documentation without reason, or offer the proforma response we touched on earlier in this submission. They then go on to direct a participant toward services which unsurprisingly offer little difference in intervention approach but are endorsed for no reason other than provision by a physiotherapist due to professional ‘title’. It is not appropriate for allied health professionals to have their scopes determined by those who are neither clinically trained nor knowledgeable of the allied health service market.

Participants also have a paucity of information available about the service options they could seek in achieving a funded goal, and factors they should consider in selecting a service. This paucity of information continues to give leverage to some unperson-centred plan managers who make decisions for participants rather than with them.

Finally, attention does need to be given to the differing self-advocacy skills of participants Sometimes, if a participant is persistent, they will receive additional scheme benefits, funding or service access privileges that other participants with similar needs minus self-advocacy skills will not. There is indeed need for more funding for disability advocacy organisations, and increased visibility and promotion of those that are funded.

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Recommendation 5: the Joint Standing Committee should recommend the NDIS take a rigorous approach to plan management service accreditation requiring continuous:

Proof the plan management service has recruited staff with a strong and proven track record of applying person-centred, client-focused approaches
Proof plan management services have provided their staff with person- centred communication and engagement training once recruited.

Recommendation 6: to prevent conflicts of interest that could impact participants, the Joint Standing Committee should recommend the NDIS require plan management services to publicly disclose all local services (allied health and non- allied health) with which they have a partnership, cross promotional relationship or affiliation that could have a coercive effect. This would enable participants, their families, and carers to assert their rights more appropriately in plan use and service access decisions.

Recommendation 7: the Joint Standing Committee should recommend that the NDIS take an active role in growing plan manager awareness of the roles various allied health professions may have in achieving funded support goals; the scheme could draw from associations including Osteopathy Australia and the national peak body, Allied Health Professions Australia (AHPA). Doing so would go some way toward establishing the diversified provider markets the scheme has long sought. Written resources, webinars, and e-learning modules are all strongly advised options.

Recommendation 8: the Joint Standing Committee should recommend the NDIS take an active role in assisting participants to make informed choices about the allied health professionals they could access. Written checklists featuring clear prompts to distinguish appropriate practitioners, irrespective of title, could be used. For example, applied to osteopathy and comparable neuromusculoskeletal disciplines, this checklist could be as simple as ‘is the osteopath talking to you about exercise approaches they could use with you?’, ‘is the osteopath talking about how they can best support you to use your program in the community, such as in parks, open spaces, with your family and friends?’, ‘is the osteopath talking to you about how they will track changes you make toward your goal?’. Such checklists would legitimise the choices participants may wish to make in the face of misplaced or inappropriate plan manager or scheme resistance.

Recommendation 9: the Joint Standing Committee should recommend that the NDIS fund more independent individual disability advocacy services and better promote such services to participants.

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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

In referring to ‘the new early childhood approach’, we presume the Joint Standing Committee requests comment on the framework outlined in NDIS Early Childhood Intervention Approach (June, 2021) available at: https://ourguidelines.ndis.gov.au/early-childhood/early-childhood-approach

We support the eligibility principles featured within this framework; namely, that a child need not require a specific diagnosis before the age of seven to access short term capacity building interventions funded through an NDIS Early Childhood Partner. This removes one key barrier to children, their families and carers accessing timely supports. For some children, this may support them to reach certain milestones or maximise their potential early. We also strongly support the imperative of delivering services within naturalistic environments for a child; for some children, this may mitigate the possibility of a life hemmed into specialist disability support services, including accommodation and respite. The guiding principles of the new approach are sound in our view.

The gap lay not in guiding principles however, but in tangible evidence of what services, specific interventions, and providers work to maximise potential early in naturalistic environments for children with a disability. There is now a paucity of Australian evaluation or trial evidence derived from pilots of traditional and non- traditional service configurations that may work toward achieving the objectives of the new early childhood approach. As the peak body for osteopathy in the country, we would very much appreciate buy in to any such trials and discussion of how osteopaths could be included to deliver specific services and collate outcomes data to support the new approach.

Recommendation 10: the Joint Standing Committee should recommend the NDIS fund trials of various multidisciplinary and transdisciplinary service configurations to identify models that may work toward meeting its vision of early optimal intervention in naturalistic environments. The Joint Standing Committee should impress upon the NDIS, need to consult with professional associations including Osteopathy Australia in identifying clinical roles that could be assumed in trial designs with reference to full professional scopes of practice.

The planning policy for personalised budgets and plan flexibility

For true flexibility in individualised or personalised budgets, the NDIS pricing and support clusters guides should allow a more diversified market of providers to participate in domains of support. A modified planning policy detached from these amendments will not fix the now inflexible approach for some participants.

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We understand there are occasions where specialist disability services would be most appropriate, and we believe there is room in revised pricing and support clusters guides to better specify plan domains, goals or needs where specialist service access is advised as opposed to generalist services or professionals— whether osteopaths or physiotherapists in a general primary care setting.

Recommendation 11: the Joint Standing Committee should recommend the NDIS amend its support clusters and pricing support guides, removing the limited profession specific criteria now applied. For domains of musculoskeletal functional care able to be provided in the community, guides should simply specify ‘AHPRA registered musculoskeletal practitioners’.

Recommendation 12: the Joint Standing Committee should recommend the NDIS engage in consultation with peak professional bodies to differentiate plan goals where specialist service access is advised as opposed to generalist services or professionals— whether osteopaths or physiotherapists in a general primary care setting.

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References

i Osteopathy Board of Australia, Capabilities for Osteopathic Practice (2019) [online]; https://www.osteopathyboard.gov.au/Codes-Guidelines/Capabilities-for-osteopathic-practice.aspx pp. 3-8

ii Osteopathy Board of Australia, Capabilities for Osteopathic Practice (2019) [online]; https://www.osteopathyboard.gov.au/Codes-Guidelines/Capabilities-for-osteopathic-practice.aspx pp. 9-17

iii Physiotherapy Board of Australia, Physiotherapy Practice Thresholds Statement [online]; https://www.physiotherapyboard.gov.au/Accreditation.aspx

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