About Assistive Technology Suppliers Australia (ATSA)
ATSA is a national organisation representing assistive technology (AT) suppliers, including manufacturers, importers, distributors, retailers, tradespeople and technicians.
We have over 160 members comprising of businesses and not-for-profit organisations that range from small family-owned concerns to multinational organisations throughout Australia.
It is estimated that, excluding AT for communication and sensory disabilities, approximately 80% of the AT in Australia passes through the hands of ATSA members.
ATSA is a registered not-for-profit charity with the ACNC and requires that its members adhere to a comprehensive Code of Practice on the provision, sales and servicing of AT. We are also a member of the Australian Ethical Health Alliance.
Background
Thank you for extending the time for ATSA to present this Brief on key activities relevant to the review on the Current Scheme Implementation and Forecasting.
Comments against the following Terms of Reference:
a. Financial and actuarial modelling and forecasting of the scheme, including: ii. assumptions, measures, and methodologies used to forecast and make projections about the scheme, participants, and long-term financial modelling;
b. The measures intended to ensure the financial sustainability of the NDIS (e.g. governance, oversight and administrative measures), including: i. 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 ii. measures to ensure transparency of data and information about the NDIS;
As the Commission may be aware, on the 28th of February the NDIS announced a significant change to the approval process and access for consumers to mid-cost Assistive Technology (AT). Since the announcement, the NDIS has been providing webinars to providers and consumers on what these changes mean to them.
In summary, the definition of mid-cost AT has been extended to cover all AT costing between $1,500 and $15,000. Consumers will have more say in the purchase process and the level of intervention by the NDIS in the approval process has been decreased.
In addition, the NDIS has approved a significant number of back orders as part of this change to ensure people in need receive the AT they require for their independence in a more timely manner.
ATSA supports this change. We believe the shift to place more power in the hands of consumers will in turn create a more price and service competitive market place. We do however, want to alert to the Commission to the fact that this significant change will take time for all involved in the processes of assessment and procurement of AT to adjust. To support this change ATSA is working with the NDIS to develop further training for AT suppliers.
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The release of the back orders has been positively received, however some of our smaller – medium sized members have advised that due to supply restrictions resulting from the impact of Covid-19 on imports, the delivery time to consumers may be delayed. Some of the larger suppliers have advised they should have sufficient stock to support their customers but not sufficient to meet the total demand from the back orders.
The above may have the potential to create some lags in the measurements and forecasting for mid-range AT.
c. 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
In regard to the early childhood approach and the general shift towards the use of second hand AT we would like to make the Commission aware of the work to be undertaken by ATSA with the TGA following an industry meeting in March:
Risks of second hand Class 1 AT (can include mid-high range AT as defined by the NDIS)
Risks arise when:
- There are no quality or safeguard checks (including biocompatibility) undertaken on the AT by a qualified or experienced technician before it is on-sold to another consumer and/or
- The sale is made by a private individual and not by a registered AT business with qualified staff or a government program (e.g. the Department of Veterans Affairs’ Rehabilitation Appliance Program and state programs such as Enable NSW). When issued through government departments, the second hand AT is checked for quality and safety and the liability sits with the relevant Government entity. Currently, neither the ACCC or TGA hold private sellers responsible if there is a fault with the Class 1 AT they sell.
- A consumer purchases Class 1 AT without seeking appropriate clinical advice and buys a device which later causes harm to the consumer.
ATSA has raised these risks with the Early Childhood team within the NDIS who have established a process within the pilot for all second hand AT to be provided by registered providers invited to participate in the trial.
The concern ATSA has is when the pilot is opened up to a digital platform environment. Currently a number of digital platforms are selling AT which has not been tested to ensure it is safe for reissue. We are working with the TGA to develop a process to ensure all second hand AT sold in Australia is vetted prior to sale to ensure the necessary safety and quality for consumers. Additionally, we are working to ensure consumers have the information they require to know whether the AT has been vetted and when an approved assessor (such as an occupational therapist, mobility trainer or other qualified expert) is required to ensure the AT they are purchasing is right for them and will do them no harm. This is relevant for NDIS participants of all ages.
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Submission in response to:
To: The Joint Standing Committee on the National Disability Insurance Scheme
Email: seniorclerk.committees.sen@aph.gov.au
From: David Sinclair, Executive Officer, Assistive Technology Suppliers Australia