Association for Children with a Disability
- Support Educate Influence
Submission from Association for Children with a Disability to the Joint Standing Committee on the NDIS
Regarding the General issues around the implementation and performance of the NDIS
Association for Children with a Disability
Our vision is that children with a disability and their families enjoy the same rights and opportunities as all children and families.
ACD is the leading advocacy service for families of children with disability in Victoria. We are a not-for-profit organisation led by and for families of children with a disability. For more than 35 years we have supported families across Victoria and advocated for children with all types of disabilities.
Over the past 12 months we have empowered more than 4,000 families with the knowledge, skills and confidence to advocate for their child and family.
This submission is inspired and informed by the experiences of families and their children. We have assisted thousands of families as their children have entered the NDIS, and the changes we are calling for come directly from their lived experience.
Recommendations:
1. Maximum wait times for each step of the NDIS process
For a child to access the NDIS or ECEI there are four major steps – gaining access, a planning meeting, plan approval and plan implementation. There are no maximum waiting times for each of these step, except for access which has increased from 21 days to 42 days.
The NDIS Act simply refers to “reasonable” waiting times. We believe “reasonable” needs to be defined, and that six weeks for each step of the process is a reasonable waiting time. For a child, this would still mean a wait of up to six months to receive necessary supports. A clearer triage process should be implemented for urgent situations.
2. Families able to preview plans prior to them being submitted for approval
Planning meetings generally run for between two and four hours. Mistakes are made and iceues [corrected to: issues] which have been discussed are left off plans. By giving families the opportunity to review a plan prior to it being submitted for approval, human error and items which have been overlooked can be quickly addressed; saving families and the NDIA time and reducing appeals.
3. Clear complaints process in relation to NDIS Partners
While the complaints and appeals process is clear in relation to the NDIA and NDIS service providers, the process for complaints against the NDIS Partners is very unclear. These are large organisations delivering a major Australian Government initiative and they should be accountable for their service provision.
4. Child development and family focused training for Planners and LACs
This is required of Planners and LACs for Early Childhood Early Intervention, however there are a number of documented situations where this is not occurring due to NDIA partners not fulfilling employment targets. It is specifically an issue in the Western and Brimbank Melton metropolitan regions. Child development qualifications and training are essential. We have heard disturbing accounts of LACs challenging parents’ statements on the basis of the development of their own child.
5. Support sustained capacity for families to care and work
The language around respite has a checkered history with the NDIA. While there are now questions asked at planning meetings about the families’ capacity to care and work, if families use the word respite and discuss their need for regular, planned respite, this does not fit with the plan structure or price guide. Respite, and care which enables parents to work, needs to be an upfront part of the planning conversation.
6. Stop using “parental responsibility” as a reason not to provide support
Planners and LACs regularly challenge parents around what is parental responsibility, not understanding childhood development and when parents are providing a much higher level of care and support for their child compared to a child of the same age without disability. This seems especially true for children under the age of 7.
7. All NDIS participant school leavers to access School Leavers Employment Support
Currently only NDIS participants who complete year 12 are eligible for the School Leavers Employment Supports (SLES). While not wanting to discourage school completion this support should be available to all school leavers whether they leave at year 10, 11 or 12.
8. Provide families support for plan implementation
Particularly for their child’s first NDIS or Early Childhood Early Intervention plan, the task of implementation is often overwhelming for families. All first-time plans should include Support Coordination as a standard item. This needs to continue into subsequent plans at the family’s request.
Plan management is currently a fixed line item. We have heard from families who can’t get Plan Management because of the size of their plan and it being cost prohibitive to the provider. Plan Management should be tiered based on the value of the plan.
T 03 9880 7000 or 1800 654 013 (regional)
W https://acd.org.au E mail@acd.org.au @acdvic ABN 39 835 407 788
9. Reduce the burden of plan administration
If a plan needs to be changed because there is an error, once the error is corrected this triggers a new plan on the NDIS Portal. Once the new plan goes up all Service Agreements have to be redone with the new plan. Every time you call the NDIS you should receive a call receipt, as you do when you call Centrelink.
10. Maximum wait times for approval of Assistive Technology
Assistive Technology can change children’s and families’ lives. Approval times through the NDIS need to be much quicker, and the advice of credentialed allied health and medical professionals needs to be accepted. Six weeks should be the maximum wait time for approval of plans with Assistive Technology.
Urgent repairs or replacements need to be approved within 48 hours. If a child cannot eat, sleep, toilet, communicate or leave the house without their Assistive Technology this would qualify as an urgent repair or replacement.
11. Adopt the State-Wide Equipment Program (SWEP) prescriber registration and credentialing framework
Families report Planners and LACs currently questioning the recommendations made by allied health and medical professionals for Assistive Technology for their child. The NDIA should adopt the Victorian SWEP Prescriber Registration and Credentialing Framework. This gives families clear guidance on who to get recommendations from and confidence this advice will be approved.
12. Ensure bulk purchasing and loan and recycle programs continue
Loan and recycle options can be particularly beneficial for children who need regular changes to their Assistive Technology as they grow. The NDIA should partner with state schemes to gain the benefit of lower prices, enabling families to hire their Assistive Technology rather than purchase it out of their child’s plan.
For more information about this submission please contact Karen Dimmock, CEO Association for Children with a Disability
T 03 9880 7000 or 1800 654 013 (regional)
W https://acd.org.au E mail@acd.org.au @acdvic ABN 39 835 407 788