Submission to: Joint Standing Committee on the National Disability Insurance Scheme - Market Readiness
22 February 2018
Context
Cobaw Community Health (Cobaw) is a small Victorian registered community health service based in the Macedon Ranges in central Victoria and has been in operation for almost 32 years. In addition to a wide range of health and community services, for most of this time we have provided services for people with a disability. As supporters of the Every Australian Counts campaign, we regard the principles of the NDIS as fundamental to ensuring that people with a disability attain the supports to enable choice and opportunities to live an ordinary life.
Cobaw has been part of the Loddon area rollout that commenced on 1 May 2017. The exception to this was a small number of children supported by Early Childhood Intervention Service (ECIS) funds (and on the waiting list) from the Victorian Department of Education and Training that transitioned into the NDIS from September 2016.
Currently, Cobaw is providing Support Coordination, Specialist Support Coordination, group based community social and recreational activities, specialised individual therapy for early childhood, individual assessment, therapy and/or training (includes assistive technology) with registration for a number of other services in development.
In response to the Terms of Reference of the Enquiry, we make the following observations:
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The transition to a market based system for service providers
- Systems - internal capability Cobaw recognised early the work that needed to be done to prepare for the NDIS. We began the changes in terms of systems implementation, changes to culture around business operations and participant-centred practice approximately four years ago. In recognition of the need to transform our business systems to ensure that we could offer the most competitive and sustainable services, we have implemented new ICT systems (Finance, Human Resources, Payroll) to improve our business efficiencies and are well progressed with customer feedback, staff feedback and client management systems implementation.
Cobaw has invested in the systems to enable us to operate more efficiently
T: 03 5421 1666 E: admin@cobaw.org.au W: www.cobaw.org.au
ABN: 35 823 252 867 ACN: 136 366 722
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Staffing – internal capability The appointment of an NDIS Project Manager in 2017 was a key factor that has enabled us to make the advances required in transition to the NDIS from current funding models. This role, although essential, has not been able to be funded through the tight margins in the slow rollout of plans and the limitations of the NDIS Price Guide. It is without question, however, crucial to delivering on the internal and external business establishment for a small organisation. After a couple of months from the rollout date, we also needed to appoint an additional administrative role to manage the sheer volume of paperwork and monitoring of plans, invoicing, appointments, and reporting functions that we were not able to fully anticipate until our NDIS transition had begun. The funding model means this establishment and operational support that is so essential to a quality service is not covered in the pricing structure.
Cobaw has invested in people to enable us to operate more effectively for people
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NDIA causing increased investment burden on service providers In the 10 months since the rollout date, we have invested significant resources into a number of business areas that have not yet been able to drive a return on our investment. We have made improvements in systems and recruited new roles. However the poor quality of plans that have been received by staff means that we are required to spend our organisational time in liaising with relevant personnel to ensure that the plan meets the participants’ needs and is able to be actioned. Approximately 30% of plans received for Support Coordination have required immediate review. Some comprised of simple administrative errors – wrong phone numbers, date of birth, incorrect address - that have required time spent before contacting the participant. No information is provided with the plan in relation to the NDIA staff member who completed the plan with the participant. Subsequent phone or email attempts to address plan issues with the general NDIA contacts creates a time delay for the Support Coordinator to be able to begin working with the participant. We are not compensated for this essential work.
Cobaw has been forced to invest in necessary participant related work for which we are not eligible to invoice the NDIS to recoup costs
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Pace of rollout The slower than expected rollout of participant plans means that we have carried higher staffing costs without income to offset these. We have not yet captured the scale that will lead to a break-even or profit making point to enable us to recoup investment into service establishment. The complexity of the transition for some clients from existing funding to NDIS in some cases has resulted in a disruption to their services.
Cobaw has invested in people and systems to enable us to deliver on a government insurance model that is not proceeding in the timeframes or methods promised to participants
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T: 03 5421 1666 E: admin@cobaw.org.au W: www.cobaw.org.au
ABN: 35 823 252 867 ACN: 136 366 722
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Participant readiness to navigate new markets
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Participant skill in a consumer driven market place The readiness and skill to navigate the NDIS varies significantly within the current participants. We have identified a large percentage of participants that did not understand how they could advocate for their own needs in their Plan; were referred to a service that they had no existing relationship with; and had services listed but no travel funded which meant that they could not get to the service. The telephone-based planning has been disempowering and ineffective for many participants and their families. In other cases, we have participants who are able to explore the new opportunities and excel at living a great life unimpeded by a disability.
Participant readiness has sometimes compromised their ability to advocate for themselves
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Early community engagement Cobaw began delivering forums for the local community in partnership with a disability partner in 2015. The primary purpose of these forums was to engage with participants and their families and provide them access to information around the NDIS. These forums were regarded as our community and mission obligation, and an investment in supporting the promotion of the NDIS rollout, in effect marketing government strategies. Cobaw sponsored forums continued through 2016-2017.
Cobaw has engaged with the local community as a part of our moral obligation to support people with a disability in navigating a new system
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Interface between health and disability The lack of clarity between the health and disability interface continues to challenge participants especially those with complex needs. The impact on people is that decisions around specific support services, technology or aids become time delayed and can sometimes result in people not having the services that would make a critical difference. We have also observed a lack of clear information available by the NDIA for health practitioners to guide them through the changes and expectations they are required to comply with. This has resulted in a reluctance amongst practitioners to change their practices.
The interface between health and disability needs to support participant centred service provision.
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The development of the disability workforce to support the emerging market
- Price Guide The Price Guide does not reflect the financial burden on organisations involved in the recruitment, induction, training, and technology/portal on-boarding processes required to
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T: 03 5421 1666 E: admin@cobaw.org.au W: www.cobaw.org.au
ABN: 35 823 252 867 ACN: 136 366 722
support staff so that they are confident and ready to engage with participants. These costs have to be invested prior to any service delivery and the margins do not allow for this.
The NDIS work is new to the workforce, hence there is a cost in the development of staff that is not factored into the pricing structure.
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The impact of pricing on the development of the market
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Scale of the market Our proximity (1 ¼ hours’ drive) to the Melbourne CBD means we are not remote in comparison to some parts of the country; however, with a range of 825 to 1260 participants in the Macedon Ranges this makes the area small in comparison to larger regional cities in Victoria. With an absence of larger regional services, the rollout is largely left to smaller organisations without significant resources to support the scale-up required despite our willingness to provide NDIS services. In addition, there is a further trend around a reduction in the size of most packages for participants that in turn compromises their ability to live a full life in their community.
These factors combine to reduce the potential of the NDIS scale outside larger population cities and regional areas.
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The role of the NDIA as a market steward
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Inherent conflict The current arrangement means that the NDIA from our perspective fulfils conflicted roles that include:
- Policy lead/driver for an insurance system for government;
- At the same time the same agency sets the prices for the services;
- Then the same agency of government controls the payments of services that in many cases considerably lags the service delivery resulting in a negative cash flow for many organisations.
As a market steward the NDIA has a responsibility to ensure that civil society needs to support local place-based services which is amplified in some NDIA documents.
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Market intervention options to address thin markets, including in remote Indigenous communities
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Markets and quality The concept of thin markets will apply to all areas if the prices are not increased. There is an additional challenge for a small percentage of people that need a higher level of care that the market will possibly not respond to given the potential increased risk. There is a concern that this will drive down the service quality.
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Thin markets There is a risk that, without the security for organisations that block grant arrangements
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T: 03 5421 1666 E: admin@cobaw.org.au W: www.cobaw.org.au
ABN: 35 823 252 867 ACN: 136 366 722
provided, organisations will cease to deliver NDIS services if the markets become too thin. This will fundamentally change the notion of local place-based services. One way that we have identified possible efficiencies is to develop shared service models between collaborative partners.
There is a real risk that thin markets will develop in rural areas, even in states like Victoria, with a resulting volatility.
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The provision of housing options for people with disability, with particular reference to the impact of Specialist Disability Accommodation (SDA) supports on the disability housing market
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Affordable housing The lack of affordable and accessible housing options in the Macedon Ranges means that any participant with housing as a goal risks not being able to stay in their local community and close to formal or informal supports. There is an expectation on Support Coordinators to explore housing options when this is a specialist field. We are fortunate to have a Housing Support team at Cobaw and we are registered to provide Accommodation and Tenancy Support, although we are accepting plans to explore mainstream housing options without any funding attached to the goal in plans.
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SDA SDA applications are proving time consuming and with unclear processes. At this time, anyone who would be eligible for SDA and not currently in “group home” accommodation would be required to seek housing outside of Macedon Ranges unless eligible for a new build.
The lack of SDA or accessible housing options means participants who are eligible may need to look outside of their community and away from formal/informal supports for accommodation.
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The impact of the Quality and Safeguarding Framework on the development of the market
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Quality As an organisation that has a strong commitment and well established systems in quality assurance and risk management, the delay to the establishment of the National Quality and Safeguard Framework leaves the potential for participant service quality to be compromised by organisations or businesses that do not already have a quality assurance and accreditation systems in place.
There is a risk around participants choosing services based on price, without the assurance that all NDIS services are meeting a high level of quality and safety standards.
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Margaret McDonald Chief Executive Officer 22 February 2018
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