NDIS Joint Standing Committee Submission June 2024

Care Connector Pty Ltd Shed 1, 7-9 Dover Drive Burleigh Heads QLD 4220

Committee Secretary NDIS Department of the Senate PO Box 6100 Parliament House CANBERRA ACT 2600 AUSTRALIA

17 June 2024

Dear Committee Secretary

RE: NDIS Joint Standing Committee Submission June 2024

Thank you for the opportunity to contribute our experiences as a registered NDIS provider for the General Issues - Annual Report No. 2 of the 47th Parliament.

Our submission aims to highlight a number of current serious challenges that are facing SME providers, like us. With an intent to be solution-focused, we also suggest a number of proposed solutions to each.

Who are we?

Care Connector Pty Ltd is an innovative Australian SME that was founded 10-years ago to address a significant service gap for people with acquired disabilities, in particular those with spinal cord injury (SCI) and traumatic brain injury (TBI). The gap we addressed was the high inconvenience, stress and economic burden of requiring people with serious injury and acquired disability to attend hospital (often in major cities far away from their homes), for their ongoing health management and care.

Since 2014, on a daily basis our founder and leadership team have applied their expertise in spinal cord injury, wound care and bowel and continence care to guide the work of our two highly-skilled teams; Holistic Nursing Solutions and Holistic Care Solutions. Together these teams provide a range of specialist nursing and attendant care services to participants primarily classified as needing ‘high-intensity’ care.

Quite simply, we are leaders in the Australian acquired disability space and have always had the ability and foresight to find solutions ahead of our time. We were the first company in Australia to innovate to provide individualised community-based care solutions to this group so that they can leave hospital following their injury and return to their home and community of choice. Today, 10 years on, we remain committed to innovation as we work collaboratively with the government

Holistic Care Solutions (HCS) and Holistic Nursing Solutions (HNS) are registered business entities of Care Connector House Pty Ltd. ABN 37 605 658 893

(federal, state and territory) and their agencies to develop strong economical and social solutions that are both viable and effective.

Our commitment and expertise has been recognised through our participation on a number of committees, research projects and practice-standard groups such as The first International Consensus Guidelines for Pressure Injuries - Special Working Party SCI, Wounds Australia Committee, Agency of Clinical Innovation (ACI) NSW Model of Care for SCI, Co-Chair Of State Spinal Cord Injury Service ACI, National Guideline Initiatives for SCI resources, Randomised Control Trial on Bowel Care Routine Within SCI Research & Publication, Series of Case Studies for adverse reactions with Catheter Products and Senior Lecturers for Post Graduate Nursing UTS and Griffith University. Scientific Committee member and presenting our innovation at national and international conferences.

The NDIS participants we represent

Whilst our cohort of NDIS participants is niche and represent around just 1% of the enrolled NDIS population, they are in fact the most expensive and often complex group. In order for someone living with a catastrophic injury to complete daily living tasks and participate in community inclusion opportunities they require a range of prescribed equipment, and continence consumables along with a holistic team of professionals. The support of professionals such as attendant carers, nurses, occupational therapists, physiotherapists, psychologists and nutritionists help achieve participant goals and also prevent complications that risk placing significant burden on the health sector such as autonomic dysreflexia (with injuries at or above T6, the sixth thoracic spinal nerve), spinal (neurogenic) shock, nerve pain (neuropathic pain), pneumonia, urinary tract infections, blood clots, pressure injuries and sepsis.

Maintaining a high-standard of care and remaining viable is becoming increasingly challenging

Over the past 4 years we have increasingly experienced and witnessed a number of challenges that we believe threaten the viability of community impact-driven SMEs like ours and the wider sector. As a solution-focused company, we have outlined these serious challenges and their potential solutions below.

Committee Secretary, we welcome your review and consideration of these issues and hope that you will find merit in the experience-informed solutions outlined below:

TOR Item ‘h. Any other matters’

1. Disparity in provider certification quality offering

We are proudly dual certified with both the NDIS and ACIS and committed to maintaining both. However, the cost and effort of achieving this is immense. This is due not only to the significant direct audit fees ($20k this year alone) but also considerable indirect costs of multiple staff members’ time, policy and template resources and mandatory training requirements. Our budget estimates see these combined costs totalling around $150-200k per annum.

The stringent requirements and complex processes involved in accreditation often pose overwhelming obstacles for these businesses, leading to delays, increased costs, and in some cases, The inability to continue providing essential services to NDS participants whilst addressing accreditation requirements. Small nursing and attendant care businesses are integral to the diverse and responsive ecosystem of care providers within the NDIS framework. They offer personalised, community-based support that complements the services provided by larger organisations. Yet, the current accreditation system disproportionately burdens these smaller entities, stifling innovation and limiting choice for NDIS participants.

Despite this, there is no difference in the fees paid to registered and non-registered providers or the potential attractiveness to participants of one versus the other. However, increasing the fees payable to registered providers would not help but would likely further disadvantage them as participants

Proposed solutions

may be more likely to select providers on a cost versus quality basis. We believe that the below proposed solutions are worth considering as a viable solution to the current uneven playing field:

Proposed solutions

a) Streamlining Accreditation Processes: simplify and streamline the accreditation process for SMEs, ensuring that it is transparent, accessible, and proportionate to their size and scope of operations. b) Support and Resources: Provide dedicated support and resources to assist SMEs in navigating the accreditation process, including access to free templates e.g. policies and procedures (there are companies out there making thousands on selling these and many organisations wasting precious time and resources reinventing the wheel), guidance on compliance requirements, training programs, and financial assistance where feasible. c) Flexibility and Recognition: Recognise the unique contributions of SMEs within the NDIS ecosystem and adopt flexible approaches to accreditation that acknowledge their expertise, experience, and commitment to delivering high-quality care. d) Consultation and Feedback: Engage directly with registered SME providers to better understand their challenges and concerns regarding NDIS accreditation, and collaborate with stakeholders to co-design solutions that meet the needs of all parties involved. By addressing these issues, we can foster a more inclusive and sustainable environment for small nursing businesses within the NDIS, ensuring that they can continue to play a vital role in supporting the health and well-being of NDIS participants. We appreciate your particular attention to this matter. e) Rather than charge participants higher fees for one provider versus the other, advocate for the governamnety to rovide tax breaks to high-quality registered providers.

2. Quality of staff

Recruiting and retaining strong, reliable talent is becoming increasingly challenging, particularly since the COVID pandemic. We believe this is due to a number of factors including; the mass departure of talent from the sector caused by burnout, reduced immigration, high cost of living and the motivation of staff to seek high hourly rates versus job security and retention.

Increasingly, for example, support workers are expecting hourly salary rates of up to $20 per hour above the award and in some cases are so in demand they are being paid more than their more highly qualified enrolled nursing peers. For example, we have had support workers requesting up to $60 ph, for roles that according to the SCHADs Award should be remunerated between $32-40.26 per hour.

Enhanced salary demands, as a result of the current market, create conflict between roles and adversely affects pricing within the market. With regards to our nursing staff, our salary matrix pays up to 69% above the Federal Nursing Award rates. Despite our enhanced rates, just this week we interviewed an RN Level 1.5 who was being paid $7 above our already enhanced rate by two other not-for-profit organisations. Unable to attract the same salary, sacrifice benefits and grants, we simply cannot compete and were unable to progress our employment offer with her.

The introduction of matching platforms such as Mable that offer staff the opportunity to secure high hourly rates with no minimal requirement for qualifications, certifications and accreditations or insurances, has no doubt helped fuel this issue. We believe that these platforms leave not only vulnerable participants open to unnecessary risk, but do the same to the sector; unfairly imbalancing the job market playing field. For example, at last check Mable boasts that just, “23% of independent support workers have a Certificate 3 qualification or above”’. This is extremely low compared to our Holistic Care Solutions staff, of which around 80% at any time hold this minimum qualification.

Additionally, to comply with our NDIS registration and ACIA accreditation requires that we must obtain a continually growing list of documents from candidates considering us as an employer e.g. police checks, completion of infection control, hand hygiene, emergency concept training, driving license and registration details. This growing list of requirements makes us an arduous option, when comparing us to non-registered providers as an employment option.

Proposed solution

a) Reconsider the registered versus non-registered provider rules and provisions for NDIS funded participants.

b) Introduce a requirement that the staff of all NDIS providers must have a minimum level of qualification, experience and insurance e.g. a CERT III in disability or individual support and that these must be maintained in line with accreditation requirements.

c) Provide free training to staff joining registered providers on the mandatory training requirements or introduce an annual per-staff member non-participant training budget to the NDIS pricing schedule on receipt of training evidence.

d) Seek to regulate the care industry employment environment (as has been done with Uber and the taxi industry) to ensure a high safe standard of staffing and an equal playing field. e) Invest in training and graduate programs that provide care companies with funded staff placements for people studying in the care and nursing space.

TOR ‘g The ongoing measures to reform the scheme’. ii - planning policy for persoanlised budgets and plan felxibity

1. Scheme shortfalls for participants with chronic and complex health needs

The NDIS acknowledges that individuals living with an acquired disability often have chronic and complex health needs, and that there will always be an intersection between Health and the NDIS.

For over ten years the HNS team has provided gold standard nursing care for complex clients in particular those with spinal cord injury and traumatic brain injury. The health needs and potential complications require highly specialised, timely care to avoid serious conditions such as:

• Autonomic dysreflexia (with injuries at or above T6, the sixth thoracic spinal nerve)
• Chronic nerve pain (neuropathic pain)
• Pressure injuries (resulting in stage 1-4 wounds frequently taking up to 2 years to heal).
• Pneumonia
• Urinary tract infections
• Bowel obstruction
• Blood clots in the legs and lungs
• Sepsis
• Osteoporotic fractures

Since the formation of the NDIS we have regularly experienced a number of challenges that we believe represent scheme shortfalls and which put participants at unnecessary risk. These include:

• Sudden physical deterioration and/or physical deconditioning following illness/hospitalisation or development of a wound, requiring immediate additional support. Frequently, there is no provision in the participant’s plan to accommodate this. There is often a misunderstanding amongst support coordinators who believe that, “there’s no money for that” or this is not an option. This results in delays getting ‘change of circumstance’ requests submitted and the risk of further unnecessary deterioration.
• When change of circumstance forms are submitted, there are lengthy wait lists (sometimes over 3 months wait) for their review. Participants requiring wound care or other support face a very real risk of physical and medical deterioration whilst awaiting reviews.
• Disparity between registered and non-registered providers with regards to clinical and care education and knowledge, compliance, safety and quality, creates issues when different providers are required to collaborate to provide care to a participant. Often, due to our skills

Proposed Solutions

We believe the following proposed solutions will secure the viability and safeguards of registered NDIS providers whilst guaranteeing participants retain choice and control:

• More education to support coordinators that requests for wound care are covered under rule 7.4 of the NDIS supports legislation and is explicitly outlined in the NDIS practice standards: Complex Wound Management – Outcome: Each participant requiring complex wound management receives appropriate support relevant and proportionate to their individual needs. Pg 22
• NDIS work with SME providers to develop a triage system for change of circumstance review, ensuring that participants with wounds, recent discharge from hospital, post surgery etc have a 2-4 week turnaround
• Consider time based Travel Labour costs for capital cities (as a separate zone) in 15 minute increments (eg. 0-15, 15,30, 30-45, 45-60) mins.
• All complex, hi-intensity clients with spinal cord injury must have RN oversight for their programs and care and require and fund that all attendant care providers must engage Registered Nurses for training, competency sign off and ongoing oversight of care.

Thank you for your time and consideration.

We remain 100% committed to the NDIS and to assisting Australians’ with acquired disability to fulfil their potential. We are also committed to working in partnership with you and the government to be part of a solution that benefits these people and the wider community. We welcome an opportunity to discuss these challenges and our proposed solutions.

Yours faithfully

Amy Darvall, Clinical Nurse Consultant/Care Connector Pty Ltd Founder and Non-Executable Director

Kim Sutton, Chief Executive Officer

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