Streamlining NDIS accreditation processes through aligned national standards

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WISE Employment Ltd ABN 68 093 718 766 552 Victoria Street, North Melbourne, VIC, 3051 P: 1800 685 105 E: enquiries@wiseemployment.com.au www.wiseemployment.com.au

Committee Secretariat

House of Representatives

Joint Standing Committee on the National Disability Insurance Scheme

Re: Submission to NDIS General Issues Inquiry

Dear Committee Secretary

WISE Employment presents the following submission for consideration in the Committee’s 2023 annual report on General Issues.

Kind Regards

Matthew Lambelle

CEO – WISE Employment

30/06/23

Joint Standing Committee on the National

Disability Insurance Scheme

Submission to the

NDIS General Issues Inquiry 2023

WISE Employment Ltd

Date: June 2023

WISE Employment Submission to the NDIS General Issues Enquiry 2023

Contents

Introduction / Summary …………………………………………………………………………………………………………. 2

Submission Recommendations …………………………………………………………………………………………….. 2

About WISE Employment …………………………………………………………………………………………………….. 3

Employment ………………………………………………………………………………………………………………………….. 3

Background ……………………………………………………………………………………………………………………….. 3

Benefits of employment ……………………………………………………………………………………………………… 4

Pathways and Employment Outcomes ………………………………………………………………………………….. 7

Understanding between NDIS & DES …………………………………………………………………………………….. 9

Accreditation processes ………………………………………………………………………………………………….. 11

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Introduction / Summary

WISE Employment (WISE) welcomes the opportunity from the Joint Standing Committee on the National Disability Insurance Scheme to share its experience and suggestions through the NDIS General Issues Inquiry and contribute to an improved and effective NDIS.

In this submission, WISE Employment emphasises the importance of an increased focus on employment goals and outcomes in NDIS participants’ plans and the benefits this provides for participants in terms of well-being, relationships, financial security and flow on effect to the community and economy. It also encourages better understanding and alignment between the NDIS and Disability Employment Services. The submission also addresses the issue of excessive red tape experienced by providers in meeting NDIA standards and proposes a National whole of government accreditation process for disability organisations.

WISE draws its submission from more than 30 years’ experience as a disability employment support provider and as a NDIS provider (since 2015) as well as from its research and the views and experiences of its customers.

Submission Recommendations

Recommendation 1

Increase the number of NDIS plans with Employment as a goal by promoting to NDIS participants the personal benefits of employment, with Employment goals to be discussed as a mandatory feature of NDIS planning and reviews.

Recommendation 2

Among the employment outcomes considered in employment goals, part-time work should be strongly encouraged as a flexible option and a pathway to increasing employment capacity.

Recommendation 3

Better education, understanding and promotion of how NDIS and DES services can complement each other be promoted amongst all stakeholders as well as adjusting existing systems to accommodate joint servicing to achieve outcomes and support a holistic service based on customer needs.

Recommendation 4

The NDIS Quality and Safeguards Commission support and lead a uniform national set of service standards for people with disability that would cover all disability programs across all government departments, states and territories.

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About WISE Employment

WISE Employment is an Australian not-for-profit employment services provider established in 1992 to assist people with disability and from disadvantage into employment.

WISE has been an NDIS provider since 2015, from locations in Tasmania and Melbourne for supports including Assistance to access and maintain employment (finding and keeping a job), Specialist employment support (through its social enterprises), Development of life-skills, Participate in community and Therapeutic supports, as well as School Leaver Employment Supports (SLES).

As a high-performing Disability Employment Services (DES) provider with 31 years’ experience, WISE has services in metropolitan and regional areas across New South Wales, the Northern Territory, Queensland, South Australia, Tasmania and Victoria. In addition, WISE delivers Workforce Australia services in Sydney, Melbourne, Adelaide and Perth, along with Employability Services Training (EST) in Melbourne, Newcastle, Darwin and south-east Brisbane and Time to Work Employment Services (TWES) to First Nations individuals in Port Augusta Prison (SA).

WISE’s innovative programs include GradWISE, assisting graduates with disability to find employment commensurate to their qualifications and WISE Idea, a multi-disciplinary team of mental health and employment specialists researching and developing innovative programs to assist people living with mental health conditions to build skills for employment and employers to provide responsive workplaces.

WISE’s award-winning Social Enterprises employ people with disability or from disadvantage who find it challenging to secure or maintain employment in the open labour market. With a workforce of approximately 400 people, Clean Force Property Services (since 2001) is based in Melbourne, Bendigo and western Sydney and Equity Labour Services (ELS) (since 1999) operates from Ulverstone Tasmania.

Employment

Background

The NDIS has previously acknowledged the importance of employment with its stated goal of adressing the low participation rates of people with disability in the labour force and the additional barriers faced by people with disability in finding and keeping employment. Currently, just over half (53% or 1.1 million) of working-age people with disability are in the labour force, compared with 84% (or 11.8 million) for people without disability (AIHW, 2022)1. WISE was supportive of the NDIS Participant Employment Strategy 2019 – 2022 and its vision that NDIS participants have the same opportunities to work as other Australians and the target of 30% of participants of working age

1 https://www.aihw.gov.au/reports/disability/people-with-disability-in-australia/contents/employment/labour-force-participation

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being in paid employment by the end of June 20232. However, at the last National Quarterly Performance Dashboard3 as at 31 March 2023 this target was not achieved, with 23% in paid employment from a baseline of 21%. In addition, as at 31 March 2023, only 36.6% of active plans for participants of working age had identified goals related to employment4. Further analysis from the March 2023 Quarterly Report5 shows the total annual supports for Capacity Building – Employment at $102.09 m (0.31% of total funding) paid with $288.7 m (0.65%) committed and not used.

WISE believes that to exceed this target of 30%, it is essential to promote the importance of work goals to NDIS participants at planning stages, by emphasising the benefits of employment and also presenting flexible employment pathways. In addition, there needs to be a greater and improved understanding and cooperation between NDIS and DES providers and their respective programs.

Benefits of employment

Recommendation 1

Increase the number of NDIS plans with Employment as a goal by promoting to NDIS participants the personal benefits of employment, with Employment goals to be discussed as a mandatory feature of NDIS planning and reviews.

The benefits of employment to the economy, community and individual are frequently documented. However, it is at the personal level that these benefits can be highlighted to promote more NDIS participants – and their NDIS planners – to include employment goals within their plans.

In ‘Achieving a ‘sense of purpose’: pathways to employment for NDIS participants with intellectual disability, on the autism spectrum and/with psychosocial disability’ (NDIS Research and Evaluation Branch August 2021)6, participants overwhelmingly reported that having a job increased their social connections and gave them a sense of purpose, as well as feeling proud, challenged and enthusiastic.

In WISE’s annual Customer Wellbeing Survey 2022, which uses the AUWI Personal Wellbeing Index survey, amongst its Disability Employment Services participants (sample of 1,652 responses), those who were engaged in paid employment recorded a personal wellbeing index score of 58.82, 11 points higher than those not in employment of 47.58 – a 20% difference in wellbeing. There were significant differences in the domains of sense of achievement, standard of living and future security [Table 1].

2 NDIS Participant Employment Strategy 2019-2022. 3 NDIS National Quarterly Performance Dashboard, 31 March 2023. 4 NDIS Participant goals data as at March 31 2023 https://data.ndis.gov.au/data-downloads#supportline 5 NDIS, Q3 2022-23 NDIS Quarterly report to disability ministers, 31 March 2023 6 NDIS, Achieving a ‘sense of purpose’: pathways to employment for NDIS participants with intellectual disability, on the autism spectrum and/with psychosocial disability. Research and Evaluation Branch – Policy, Advice and Research Division. August 2021

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Table 1: WISE DES Customers Personal Wellbeing Factors – Employed vs Seeking Employment 2022

Wellbeing Factor DES participants – In Employment DES participants – Seeking Employment Difference in score, Employed vs Seeking
Standard of living 62.80 50.08 12.72
Health 50.55 40.16 10.39
Achieving in life 56.22 40.51 15.71
Personal relationships 62.14 53.49 8.65
Personal safety 69.37 60.57 8.8
Community connectedness 58.02 48.05 9.97
Future security 52.67 40.18 12.49

This was further reinforced by a WISE-commissioned Centre of Research Excellence in Disability and Health study, ‘Impact of part time work for people with disability’, which quantified the benefits of part-time employment for people with disability (receiving DES services) with 676,000 fewer healthcare services used (including 108,000 fewer mental health services) and 212,000 fewer mental health scripts used7. In broad economic terms, this represents savings of $62.5 million per year in healthcare costs.

WISE participants in the above study noted the immediate impact of employment on their lives and which continued while they maintained their work.

“At one month of employment, they described the start of a sense of rediscovery, reinvention of self, and pride in having employment, or even a change in passion and values. At three months, this rediscovery extended as the mastery of skills in their new job developed, leading to a sense of, “I can do anything!” that in turn realised a psychological shift whereby they were more willing to get out and try new things in the rest of their lives - including study, moving to a new industry, taking on more hours or even full-time work.”8

To increase the employment participation rate of those customers in NDIS it is essential to increase the number of participants with employment as a goal in their plans. While government and economists understand the benefits of increased employment, this needs to be promoted more at participant and planner level.

7 Centre of Research Excellence in Disability and Health, Impact of part time work for people with disability. 2022 8 Centre of Research Excellence in Disability and Health, Impact of part time work for people with disability. 2022

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R’s Story

R is a young person who joined our WISE NDIS SLES program in Devonport after he left school in 2018. His mum had heard about the program from a friend. R is on the autism spectrum and sometimes struggles with mild depression and anxiety, which he often manages by removing himself from or avoiding situations.

WISE SLES Staff were sensitive to R’s needs and agreed that it would take time for him to ‘settle in’, so he started with 1-on-1 sessions a few times a week until he felt confident enough to join others in group sessions.

R’s goals included finding employment and being more independent. WISE SLES staff helped him set and develop strategies to achieve both of these. We focused on increasing his personal capacity (including communication skills and social confidence) and on employability skills (including food safety and warehouse employability skills training). When he was confident enough, R also volunteered for DES supports which provided more intensive assistance in job search and employment readiness skills, tailored job matching, access to employer wage subsidy and in-work supports.

Working together with his NDIS worker and DES consultant, R achieved his first goal in securing part time work (8 hrs per week) with local Devonport employer, Clarks Metal Fabrication.

In R’s words:

“When I first came to WISE I was extremely nervous, I was depressed and I was someone who didn’t want to open up about who I thought I was. Now I’m someone who likes to talk to new people and share my experiences. My confidence has grown since coming to WISE and I’m more self-assured.

When starting at WISE we worked on setting my goals, working on things such as memory, improving cognition, courses such as my white card, RSA, life skills and many differing work experiences and greater independence.

I’m proud to say I now have paid employment and have gained considerable independence. I still have a few goals I would like to achieve and look forward to continuing to work with WISE and my support workers.”

R continues to work, and while his NDIS staff help support to keep building his personal capacity and independence skills (including helping him recently get his drivers’ licence), DES supports help him maintain and further his employment.

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Pathways and Employment Outcomes

Recommendation 2

Among the employment outcomes considered in employment goals, part-time work should be strongly encouraged as a flexible option and a pathway to increasing employment capacity.

While supports delivered through NDIS are necessarily focused on capacity building for employment, tailored to participants’ needs and circumstances to support their vocational goals, WISE Employment believes these should have an outcome-driven focus recognising a broad range of employment options. In line with a participant’s goal and capacity, employment outcomes can include casual, part-time, full-time, across self-employment, gig employment, and from small to large employers and supported employment in social enterprises.

WISE highlights the advantages of part-time work both as an employment goal and as a pathway into further employment.

The benefits of part-time work as an employment outcome and pathway were demonstrated in the ‘Impact of part time work for people with disability’ study9, illustrating the impacts of part-time on personal wellbeing and the economy, and specifically highlighting the advantages for people with disability seeking to work part-time as a flexible employment choice and/or as a pathway to full-time work.

Participants in this study highlighted part-time work as an easier entry into work. Not least because they found it also allowed them to become physically accustomed to working:

“At the one month of part time work mark, a few workshop participants noted that work can be physically difficult because the body is not used to working. They noted a need to build resilience to generate energy from physical work, but towards the end of the month, they started to notice their fitness had increased.”10

Importantly, as a pathway into employment, part time work allowed people with disability a better chance of setting up the supports, technology and habits. As a staged approach to employment, they were able to use the allied health supports they required to set up the right supports and services as they adapted to work. In this aspect, NDIS participants would be able to utilise capacity building supports on their plans to specifically support them in employment.

Participants in the study that secured part-time work stated they were able to develop important work aspects of stability, balance, and organisational skills, which would increase their potential to sustain employment across the long term according to their goals and capacity.

“Part time work helps with self-esteem, self-worth, identity: knowing I’m using my time productively, having motivation every day. Having a routine helps you get motivated for other things

9 Centre of Research Excellence in Disability and Health, Impact of part time work for people with disability. 2022 10 Centre of Research Excellence in Disability and Health, Impact of part time work for people with disability. 2022

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which means other little goals can feel more achievable. It makes you want to be more organised with your time – make time for cooking, shopping, bills, medical appointments.” (Study Participant)11

For some people with disability part-time work could be a better option than full-time work, allowing them to work to their capacity while still offering social, economic and personal benefits, independence and greater well-being.

“I’m recovering from cancer and my friends say I’m not coping with part time work. I’m in bed by 7pm because I’m so fatigued, but I would be homeless otherwise. I’m hoping I’ll get my energy and stamina back. It’s hard after having time off work and then coming back to it. I’m just coping with part time, I wouldn’t cope with full time.” (Study Participant) 12

Part-time work was also highlighted by many of the young people in WISE SLES programs (run in Tasmania and Melbourne), as a flexible option and as a pathway. Participant ZL (Launceston) identified a clear goal in gaining qualifications as a barista or bar worker (supported by WISE in developing social skills and in completing RSA and hospitality training) in order to achieve part-time work “to maintain a work-life balance”. This was echoed by participant AN (Melbourne) for whom part-time work would better “suit her lifestyle” and capabilities. While for many of the participants part-time work was the next step in a pathway to reach their goals – E had been doing limited work experience for over three years and although not ready for full-time work, his next goal was to find part-time work in retail, and B who after volunteering at a local charity where she learnt register and decorating skills, now felt the confidence and motivation to find part-time work.

Part-time work also has the advantage of offering flexible hours to people with disability, accommodating the level of their work capacity and supports required. However, to further promote part-time work as an outcome, adjustments may need to be made to ensure they do not immediately lose supports they may be receiving (including such as through Disability Support Pension) and that supports on their NDIS plan remain focused on helping them not only within the job but in adjusting to employment.

WISE also reinforces the option of ADE / Supported Employment within Social Enterprises as an important employment outcome and pathway. As reflected in the 2022-23 NDIS Quarterly report13, 30% of NDIS participants in employment are in ADE/Supported Employment and previous findings show this participant group is more likely than others to feel supported in their job14. While for some this could be a successful outcome in itself, for others with a goal of open employment, this would also provide a pathway option to further develop their skills and capabilities to equip them for open employment.

This option is highlighted by C, an NDIS-supported employee of WISE Social Enterprise Clean Force Property Services (Melbourne):

“Growing up, I dealt with homelessness and mental illness. I was very anxious and scared about working, but when my Support Coordinator sent me a role at Clean Force, I was interested. On my

11 Centre of Research Excellence in Disability and Health, Impact of part time work for people with disability. 2022 12 Centre of Research Excellence in Disability and Health, Impact of part time work for people with disability. 2022 13 NDIS, Q3 2022-23 NDIS Quarterly report to disability ministers, 31 March 2023 14 NDIS, Employment outcomes for NDIS participants as at 31 December 2020.

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first day at Clean Force in the supported crew, I felt a little nervous, and it took me a while to get to know my crew, my role and everyone else, but I enjoyed it so much. I really love it. I work with amazing people at Clean Force, and I feel like I am part of the family.”

Understanding between NDIS & DES

Recommendation 3

Better education, understanding and promotion of how NDIS and DES services can complement each other be promoted amongst all stakeholders as well as adjusting existing systems to accommodate joint servicing to achieve outcomes and support a holistic service based on customer needs.

A further factor that will impact on helping NDIS participants achieve goals in employment is a better understanding between NDIS and DES providers and generally a greater understanding amongst all stakeholders (including NDIS participants and their families, plan co-ordinators and DES providers) about how these programs can complement each other.

The need for this was illustrated in the case of young person, S who was disengaged from both study and work when she joined the School Leaver Employment Support program with WISE in Devonport. Over the next twelve months, she attended one-on-one and group sessions (ranging from workshops, social groups, cooking sessions and local excursions) that were focused on building her day-to-day communication and social skills and developing confidence. Employment was a goal for S, and although she was far from employment-ready when she joined the SLES program, she was working towards building her capacity when she registered with a local DES provider. The DES provider could work on more job-matching activities and skillsets while her NDIS supports could continue to work on confidence and social skills. When S met with her local LAC for her NDIS Plan review, employment again featured as one of her goals and she advised the LAC that had registered for DES as part of that goal. However, as a result of this when she received her new NDIS plan, while it acknowledged her goals, no core funding had been allocated to assist her and she had received a zero-dollar plan. On querying this, she was advised that as she was now a DES participant, her DES provider would be able to deliver all the support she required, including meeting her non- employment related goals. The LAC had no understanding that while the DES provider could provide S with focused employment supports there were other essential supports that S required to meet and sustain her goals – such as skills in life development, social communication skills and independent living skills as well as other skills and capabilities that would also help her sustain her employment journey.

While supports through DES are specifically employment-focused, there are many other critical supports DES cannot provide that would support NDIS participants not only in preparing for employment but also in managing their lives in employment. This was emphasised by the participants in WISE SLES groups in Melbourne and Victoria when reflecting on the program:

E (Melbourne): “We’ve benefited by the support worker helping us – skills and knowledge and to get jobs and that … build confidence and life skills.”

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M (Melbourne): “I guess they helped me learn like what kind of skillset I had and they also helped with communication type stuff. How to write letters and resume. They also taught about financial stuff and managing finances like making your own lunch, going out and buying lunch potentially and general finance stuff. For making lunch, we went out to get ingredients too like wraps etc. Talked about all different aspects of team building and what makes an effective team.”

B (Tasmania): “… work placements, volunteering, life skills … cooking and budgeting … building confidence, planning and independence. Our parents are all getting older – we need to become more confident with what we’re learning so we have this in the future. I wasn’t this confident when I started ….I wouldn’t speak much.”

These comments highlight the more holistic focus of NDIS supports that can complement the employment-focused supports of a DES program – even in employment people NDIS participants can be supported through skills such as self-care and grooming, time management, managing finances, managing behaviour, cooking, social skills, ongoing personal development, managing relationships and other goals identified within their plans. These skills provide an ongoing foundation that will support sustainable employment.

Moreover, as outlined by one of WISE’s SLES Support Workers (Melbourne), “we identify supports the participant should engage in, OT, psychology, cooking classes, group activities, health and wellness, groups that the participant is interested in”. This support extends to being part of regular care team meetings and communication shared across support workers in regard to updates on the participant’s changes in care or needs.

The lack of knowledge about available employment supports was also highlighted in the aforementioned ‘Achieving a sense of purpose’ report15. Here both LACs and NDIS planners expressed their confusion about the role of the NDIS in supporting participants in employment, NDIS participants were unsure what employment-related supports were available under NDIS, and NDIS service delivery staff wanted more clarity on the role of the NDIS in supporting employment pathways.

Clarifying these roles would increase the significant potential for NDIS and DES to work together for the interests of people with disability. While the DES expertise and focus is on employment outcomes through job search preparedness, skills acquisition, tailored job matching and in-work support – as well as working with employers in accessing supports such as wage subsidies and reasonable adjustments and working with industry to meet skills needs – the flexibility of NDIS assistance could support employment capability and pathways through other life supports and provide further employment-related assistance including managing work-life balance, career progression or changing jobs.

WISE welcomes the anticipated initiative of the DES Pathways Pilot between the DSS and the NDIA as a way to improve the collaboration between and effectiveness of NDIS and DES in supporting participants to achieve employment goals. We also believe this understanding of how these

15 NDIS, Achieving a ‘sense of purpose’: pathways to employment for NDIS participants with intellectual disability, on the autism spectrum and/with psychosocial disability. Research and Evaluation Branch – Policy, Advice and Research Division. August 2021

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programs can together support participants needs to be better promoted across all stakeholders, including LACs, planners and support coordinators, DES providers and participants and their carers.

Accreditation processes

Recommendation 4

The NDIS Quality and Safeguards Commission support and lead a uniform national set of service standards for people with disability that would cover all disability programs across all government departments, states and territories.

The introduction of the NDIS Quality and Safeguards Commission to oversee the quality and safety of NDIS supports and services is an important mechanism for participants, services providers and workers. WISE acknowledges and appreciates the nationally consistent approach the Commission has given through the NDIS Quality and Safeguarding Framework. However, we also believe that the processes of demonstrating compliance with these safeguards have created excessive red tape and duplication for disability service providers.

The process of demonstrating compliance with the framework and maintaining NDIS registration involves reapplications every 3 years with a mid-term (18 month) interim audit. Overall, this involves an extensive self-assessment by the organisation against standards appropriate to the services being delivered – requiring 40+ detailed responses input through the NDIS Commission portal – followed by commissioning audits from external providers twice during the registration period. This can be a costly and time-consuming process. Furthermore, it does not take into account that most disability providers also have to demonstrate compliance with other disability and provider standards. For example, as WISE is also a provider of Disability Employment Services, it is also required to maintain certification with the National Standards for Disability Services (NSDS) as well as the DES Quality Framework and other quality certifications. Many of the standards and conditions and processes of each of these frameworks and certifications are the same.

To alleviate the red tape and duplication, WISE believes that through the NDIS there is an opportunity to align and develop a single national standard that disability organisations need to meet that would cover all programs across all departments and contracts and states. A single set of standards would ensure all disability programs meet the same consistent quality standards and in the process, streamline the certification and compliance process within the industry. This would save time and resources for all stakeholders that could otherwise be invested in the direct provision of supports to people with disability. Ultimately, it would ensure a consistent level of quality and engender greater trust from people with disability when engaging with these supports.

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