NDIS Joint Standing Committee: Current scheme implementation and forecasting for the NDIS Via online submission system
Australian Music Therapy Association
NDIS Joint Standing Committee: Current scheme implementation and forecasting for the NDIS
The Australian Music Therapy Association (AMTA) is the peak body for music therapy in Australia. AMTA represents Registered Music Therapists (RMTs), music therapy students and advocates for access to music therapy on behalf of the community. Our mission is to enable, advance and advocate for excellence in music therapy.
AMTA is the regulating body responsible for registering music therapists, accrediting music therapy courses, and maintaining professional standards and ethics. A member organisation of Allied Health Professions Australia (AHPA) and National Alliance for Self-Regulating Professions, AMTA supports RMTs to use research-based practice that actively promotes the health, wellbeing and functioning of Australians.
Introduction
AMTA acknowledges and welcomes this Joint Standing Committee’s consultation. AMTA is committed to providing advice to ensure the NDIS meets its aims, is centred on the needs of its participants, offers high quality and safe supports and delivers ‘value for money’ without sacrificing the progress and successes of the Scheme to date.
RMTs are allied health professionals accredited at Masters level who deliver evidence-based supports to NDIS participants. As such, our response to the terms of reference outlines how the NDIA’s economic decisions and operationalising these decisions are impacting NDIS participants, allied health professionals and those businesses providing therapeutic supports.
We would welcome further conversation and consultation on NDIS and its implementation. The AMTA is consistently involved in NDIA/NDIS consultations; however, many of these consultations result in no change or reflection of the content of submissions. We trust that this Committee’s consultation is genuine and will deliver meaningful recommendations for change.
How music therapy makes a difference in the NDIS
RMTs are allied health professionals with expertise in music engagement to activate complex neurological structures. RMTs use targeted music therapy techniques (e.g. improvisation, songwriting, therapeutic singing, music assisted counselling, active and receptive music engagement) to influence behaviour, improve cognition and communication, develop and rehabilitate motor skills, and develop emotional awareness and competence. These techniques are complex, evidence-based, and require highly skilled musicians with advanced knowledge in contemporary theories, therapeutic practice and research to know when and how to use music therapy safely to improve health and wellbeing outcomes. For NDIS participants, music therapy can significantly impact mood, thinking, behaviour, communication, movement, and increase independence and community participation.
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The impact of boundaries of NDIS and non-NDIS service provision on demand for NDIS funding
There are inadequate supports for people with disabilities outside the NDIS, and those that do exist may be costly or inaccessible. Potential community-based supports may require capability development to support people with disability. The Information, Linkages and Capacity Building (ILC) program could reinforce capability building partnerships with community-based supports; however, this program is inconsistent in its implementation and impact.
The ILC grants program has the potential to create real and positive social change for people with disabilities. However, the lack of clarity about the program’s longevity impacts local planning and innovation. Without certain, continued funding, local businesses and service providers may not feel confident to invest in the program. RMTs have described innovative local programs that have created broader connections across community organisations and sectors, increased social participation and positive economic outcomes for people with disabilities. There is a need to consider further how to measure the impact and outcomes of these programs, make decisions about grant funding, and promote and spread successful models. There is potential to expand and extend these programs, but this is incredibly difficult and unlikely without guaranteed funds.
Interfaces of NDIS service provision with other non-NDIS services
Experiences of intersection and interaction of services inside and outside the NDIS are fraught. The recent Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability exposed the many issues people with disability experience in the health sector^1. Many of these issues extended from poor coordination and communication, governance issues, and unclear responsibility for different aspects of care. Poor communication between NDIS providers and non-NDIS services can result in delayed or inappropriate care and directly impact short and long-term health and wellbeing. Different languages, models and frameworks across the various sectors (e.g. treatment, maintenance, rehabilitation, capacity building, recovery) increase complexity for professionals and disempower NDIS participants.
Complex interfaces require planned and coordinated approaches to improve communication, integration, and participants’ outcomes. Instead, issues at these interfaces are often considered isolated issues pertaining to individual participants. As a result, these issues are managed by the participant, their carer or support person, often at great personal burden and expense.
The issue of ‘duplication’ is a recurring one and one we have raised previously with the NDIA. Our members report that engagement with non-NDIS services can result in exclusions of goals or supports from participant plans (with NDIS citing duplication) or extended delays as different segments of government debate responsibility for funding or delivering care. The AMTA regularly reminds the NDIA that allied health professions offer unique, specific value to participants. Music therapy provides unique and distinct value to participants that is different from other allied health professionals. Participants may benefit from and actively select collaborative and multidisciplinary approaches involving more than one profession to address their NDIS goals. Multidisciplinary and interdisciplinary care, where participants, carers, support people and professionals work together to address shared goals, is not duplication; it is best practice.
^1 https://disability.royalcommission.gov.au/public-hearings/public-hearing-4
AMTA Submission to NDIS Joint Standing Committee: Current scheme implementation and forecasting for the NDIS February 2022
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Reasons for plan variations in plan funding between NDIS participants with similar needs
Drivers of inequity between NDIS participants living in different parts of Australia
Geographical inequities across Australia pose a significant challenge to the NDIS. Many of the causes of inequitable access to supports for participants are not unique to the NDIS. Issues such as workforce shortages and scarce allied health resources impact both on availability of supports and local planner knowledge. Limited availability of specialist services and the digital divide also impact the ability of the NDIS to provide equitable supports across regional, rural and remote areas.
There are opportunities to examine the available services in local areas and determine where capacity might be further developed (funded) within existing services. For example, the NDIA could commission existing, local health, community-controlled or aged care organisations to provide some disability supports to local participants. The NDIA could invest in building local capabilities to deliver supports in those areas of particular need. These approaches all require a commitment to longer-term, future- focussed funding, which would be difficult within the current Scheme.
One positive, unanticipated outcome of the COVID-19 pandemic has been increased availability and accessibility of supports via digital health technologies. Telehealth has become a powerful and widely accepted method of service delivery and should continue to be supported as a valued tool in disability support and healthcare provision. Virtual health approaches have the potential to address some of the access issues facing people living in rural Australia (though these are reliant on reliable and accessible digital health infrastructure).
Inconsistent decision making by the NDIA leads to inequitable variations in funding
Our members witness inequities in access to supports regularly. Participants and providers refer to their at times combative relationships with the NDIA. Participants and providers tell us that those with the bureaucratic literacy and the available mental and emotional resources can ‘fight’ for NDIS access and supports. However, this is often protracted, complex, distressing and exhausting. Providers often provide additional (unfunded) support to applicants or participants to facilitate access or reinforce requests at reviews.
The planning process continues to be the aspect of the NDIS causing the most distress to participants and the most concern to providers. Choice and control for participants is best facilitated by coordinators and planners who understand the breadth of supports available to participants and the benefits and outcomes these deliver. NDIS participants and our members continue to express concerns that decision- makers may not have sufficient knowledge, training or skills to enable participants’ active role in decision making, make valid decisions about participant goals and plans or identify the most suitable providers for support. NDIA planning and coordination requires a high-level understanding of complex disability and a detailed understanding of the disability sector and the value of available supports. AMTA is concerned that planner workloads and time pressures negatively impact the decision-making process. AMTA is concerned about the knowledge and skills of planners and coordinators who have made decisions based on incorrect information or without an understanding of the available evidence base, particularly relating to music therapy. AMTA has previously presented evidence to the Committee and the NDIA on this subject.
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AMTA members are concerned by participants’ levels of distress when planners disregard their choices and opinions. Lack of information about decisions made (in particular their justification) limits the ability for participants to question and challenge the planning and decision-making process and undermines the principles of choice and control. Transparent and collaborative decision-making would enable participants and providers to question decisions, troubleshoot, and work together with the NDIA to develop a plan that truly meets participant needs. Transparent decision making would minimise waste and administrative burden, reduce AAT reviews and potentially improve access to relevant supports for participants.
Often, AMTA hears of misrepresentations of music therapy by LACs and planners who have told participants that music therapy is not an approved funded support. AMTA continues to receive complaints from its members regarding some NDIS planners’ misinformation about music therapy and ultimately their refusal to fund music therapy in NDIS plans - irrespective of participants’ requests, and comprehensive reports describing strong outcomes across all domains of daily functioning. Some participants and RMTs report that the NDIA denies participants access to music therapy supports without reading clinical reports, paid for with their funds. AMTA has communicated regularly with the NDIA about these ongoing issues and provided information, evidence reviews and case studies. We have offered training. We would urge the NDIA to collaborate with AMTA to address these ongoing issues.
Inconsistent decision making is also occurring across time for individual participants. Participants report to AMTA that music therapy may have been a primary support one year, yet is not approved for the following year, despite ongoing needs and a clinical recommendation for continued funding. AMTA is concerned by decisions to remove primary supports despite participant choice and clinical recommendations. These decisions have serious consequences for a participant’s health and wellbeing and could be viewed as a failed duty of care. AMTA also questions the need for frequent planning reviews for those participants with stable and ongoing needs. Less frequent reviews for participants could promote continuity and minimise the stress associated with the NDIS funding and planning process. For providers, less frequent reviews could enable longer-term planning for participant supports, reduce funds expended on non-contact activities, and reduce the workload for the NDIS. NDIA could review a plan when there was a change in circumstance, as needed, or at a 2-3 yearly period.
AMTA draws attention to the increasing number of AAT processes over the past 12 months. This represents participants’ responses to approaches and decision making they perceive as incorrect or unjust. Participants, their carers and support people would not need to take this action if the NDIA engaged in genuinely transparent, person-centred and equitable decision-making. AMTA suggests that decision support tools and increased education for planners and coordinators would better support this process. It seems clear that the decision-making processes in the NDIS are not currently working.
Measures to address inequities in funding
AMTA supports increasing participant choice and control and enabling flexible budget expenditure to maximise the use of their available funding. AMTA supports flexible budget expenditure that prioritises participant choice, such as participants’ use of core funding for capacity building supports if that is their choice and meets reasonable and necessary criteria.
Stable rural, remote, and very remote services rely on consistent funding arrangements to attract and retain rural and remote practitioners and enable design (and co-design) and delivery of flexible and innovative service delivery models. We would welcome a detailed study of rural and remote service costs
AMTA Submission to NDIS Joint Standing Committee: Current scheme implementation and forecasting for the NDIS February 2022
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to ensure funding models do not drive further inequities in access, health and outcomes for people living in rural and remote areas.
AMTA stresses the importance of safety and strong clinical governance as accepted foundations of the Scheme. RMTs are a self-regulated allied health profession recognised by AHPA and NAHSRP. RMTs have specific expertise in evidence-based approaches to the use of music to improve health and wellbeing. Substitution of allied health professionals with assistants, unqualified or unregulated workers reduces the quality of supports, risks participants’ outcomes, and is potentially unsafe. Acceptance of this level of risk would not occur in another government-funded system of care.
Funding the NDIS
AMTA draws attention to the complexity of the existing funding model, the NDIS Pricing Arrangements and Price Limits for 2021-22 and the administrative burden (time and costs) for providers to ensure they understand the scheme and meet requirements to deliver supports. This complexity negatively impacts the ability of providers to think, plan, and provide supports differently.
The complexity of funding guidelines also impacts the ability of applicants and participants to make informed choices and decisions about their support needs, priorities and goals. The focus for applicants and participants is, “How can I make the best use of the available funds to address my support needs?” not, “Where does the funding come from?”. The participant perspective is often lost when conversations take place with NDIA. LACs and Planners must have the requisite skills to manage conversations about finite resourcing and personal support needs meaningfully and sensitively. These skills and interactions significantly impact the relationships of planners and coordinators with participants, often placing them as an adversary rather than a facilitator.
AMTA recommends the NDIA commits to a 3-year pricing model (with CPI increases) to give providers the stability to undertake future-focussed business modelling, build some momentum and systems in the field, and enable more significant innovation and program model development. Allied health professionals must have the opportunity to collaborate on this pricing model. AMTA recommends AHPA as the lead party in this process as Australia’s national voice for allied health.
Financial and actuarial modelling and forecasting of the scheme
Financial and actuarial modelling and forecasting are essential for the NDIS’ longevity. However, financial modelling provides only one lens to inspect the inputs, outputs, outcomes and impacts of the Scheme. AMTA would urge the NDIA to review measures used to identify the social, individual and economic impacts of the NDIS, to obtain further insights into the critical outcomes the Scheme is achieving with people with disabilities and our nation as a whole. To exclude these measures is to misunderstand the purpose of the Scheme.
The NDIA may improve its sustainability by identifying and addressing waste, such as burdensome administrative processes and increasing rates of AAT reviews. Participants and their support people must not bear the costs of recent modelling, forecasting and sustainability concerns. AMTA reasserts the importance of a stable and informed NDIA workforce that is suitably prepared and supported to effectively collaborate with participants and their support people to make high quality and meaningful decisions.
AMTA Submission to NDIS Joint Standing Committee: Current scheme implementation and forecasting for the NDIS February 2022
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Ongoing measures to reform the scheme
AMTA remains concerned about the NDIA’s level of commitment to consultation with people with disabilities, NDIS participants and NDIS providers. Many providers and participants report the NDIA has lost their trust. AMTA has dedicated considerable time and resources to providing the information requested by the NDIA, often within the context of very short timelines. Our participation in several consultations and our members’ representations to the NDIA has seen little change in policy direction, implementation or local decision making. Allied health professionals must be consulted if the NDIA is genuinely committed to providing high quality, evidence-based supports to people with disabilities.
AMTA welcomes the opportunity to meaningfully collaborate with the NDIA to improve the Scheme for participants and ensure appropriate access to music therapy.
Contact: Bridgit Hogan Chief Executive Officer Australian Music Therapy Association e. ceo@amta.org.au m. +61 438 444 439
About the Australian Music Therapy Association
The Australian Music Therapy Association (AMTA) is the peak body for music therapy in Australia. AMTA represents Registered Music Therapists (RMTs), music therapy students and advocates for access to music therapy on behalf of the community. Our mission is to enable, advance and advocate for excellence in music therapy. AMTA is the regulating body responsible for registering music therapists, accrediting music therapy courses, and maintaining professional standards and ethics. A member organisation of Allied Health Professions Australia (AHPA) and National Alliance for Self-Regulating Professions (NASRHP), AMTA supports Registered Music Therapists (RMTs) to use research-based practice that actively promotes the health, wellbeing and functioning of Australians. RMTs work in private practice and allied health teams in hospitals, residential facilities, community services and schools. They use evidence-based music therapy techniques to promote better health outcomes for vulnerable and unwell Australians.
AMTA Submission to NDIS Joint Standing Committee: Current scheme implementation and forecasting for the NDIS February 2022
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