29 June 2020
Joint Standing Committee on the National Disability Insurance Scheme
PO Box 6100
Parliament House
Canberra ACT 2600
By email to ndis.sen@aph.gov.au
Dear Committee Members
Mind Australia Ltd (Mind) appreciates the opportunity to provide a submission to the
Committee in lieu of our appearance at the public hearing on 23 June 2020.
Mind is one of the country's leading community-managed specialised mental health service
providers. We have been supporting people dealing with the day-to-day impacts of mental
illness, as well as their families, friends and carers for over 40 years.
Mind is a registered NDIS provider and in the past financial year we provided a service to 1,386
NDIS participants. We are registered to provide:
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Supports to approximately 1700 NDIS participants including support coordination, Allied Health specialised assessment and behaviour support, and community engagement and capacity building support with a workforce of over 100 FTE community mental health practitioners and mobile allied health.
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Supported Independent Living (SIL) to 170 NDIS participants across Victoria, Queensland and South Australia. SIL is delivered in to Specialist Disability Accommodation (SDA), community housing, private rental and some state government owned properties.
In addition to our service delivery, Mind significantly invests in research about mental health recovery and psychosocial disability, including in relation to the NDIS. Mind is a strong supporter of the NDIS and the inclusion of people with psychosocial disability in the scheme. It is clear that since the scheme came into operation it has already improved the lives of many people with a psychosocial disability, particularly those in supported independent living. However, as has been well-documented, accessing and using the NDIS is difficult for people with psychosocial disability, and its introduction has severely disrupted the provision of services for this cohort. Central Office
Mind Connect 86-92 Mount Street | PO Box 592 1300 286 463 Heidelberg VIC 3084 Carer Helpline 1300 554 660
w mindaustralia.org.au
Mind provides this information to the Committee to assist with its deliberations in regard to its three inquiries which are currently being held:
1. General issues around the implementation and performance of the NDIS
2. NDIS Planning
3. NDIS Workforce
Transactional nature of service delivery
Mind primarily delivers psychosocial support to people who experience complex and severe mental health issues. For some people, this means providing a level of support that helps an individual to maintain their current level of independence across a range of social interventions. This commonly means that workers complete and support specific tasks with and for the consumer when that person is unable to complete the tasks themselves. For others, after a period of mental ill-health, they may require assistance to develop skills to manage everyday life. They may have impairments in terms of emotional, cognitive, practical and social skills that require supports to mend and rebuild.
Like Mind, many providers are unable to deliver core supports without cross subsidisation from cash reserves. This is due to the NDIS pricing model, which charges per transaction and does not take into account the full cost of providing a service, including the skills of the workforce required to deliver it.
The transactional nature of service delivery and low price points in the NDIS effectively means that an organisation has to make a decision whether to provide a much-needed service to a person at a financial loss to the organisation or not provide the service at all.
For example, the 2020-21 Price Guide in relation to Group Activities, has made the delivery of this vital service unsustainable. The NDIS now requires Group Activities to be delivered at a cost of $56.81 per group (i.e. if there are 10 people in a group, they would be charged $5.68 each). Mind estimates the actual cost of providing this service is approximately a loss of $150 per hour to the organisation, due to the administration of the pricing and the changes required to service agreements, effectively making the provision of this support unviable. The loss of this services is of significant concern for Mind as we know the benefits that clients gain from talking and spending time among their peers in a safe space. Feedback from participants and carers is that they feel that relationships are monetised, rather than therapeutic.
The reduced service offering not only affects the NDIS participant, and carers but also staff. When staff are only able to provide the service for which we are funded, rather than the support they know will benefit the participant, there’s little job satisfaction.
Supportive accommodation
This Committee’s inquiry into SIL acknowledged that there may not be sufficient trained staff in SIL settings to ensure that participants with SIL funding receive the supports that they require. The Committee also acknowledged that the SCHADS award is not sufficient to attract and retain support workers with the skills and expertise necessary to deliver SIL supports. Participants in SIL often have higher or more complex support needs, and that support workers may not receive higher pay for delivering supports to this cohort. Mind welcomed the recommendation that the NDIA review the price guide to “ensure that the costs associated
with attracting, training and retaining staff to deliver supports to people with severe or complex disability, including in Supported Independent Living settings, are adequately captured.”
Since this inquiry, the 2020-21 Price Guide has now been published and the categories for pricing have changed to Standard and High Intensity. The subsequent removal of ‘Complex rate’ and default to ‘High Intensity’ has resulted in a 4.8% reduction in price for SIL providers. This will place even further pressure on providers to fund SIL services and pay appropriately qualified staff.
Recovery Coach
While Mind welcomes the introduction of the Psychosocial Recovery Coach to support the unique needs of participants with psychosocial disability, we are concerned at the low pricing of this support given the specialist nature of the support. We are pleased that the NDIA have recognised the importance of lived experience and enabled this support to be delivered by people with a Certificate IV in Peer Work.
The implementation of this item is problematic. It has been priced too low in the 2020-21 Price Guide at only $78.17 base rate an hour, in comparison to the price for the equivalent support coordination which is $98.06 and the NDIA has stated that they will not generally be funding both in a participants plan. The qualifications and expertise are higher than required for support coordination and organisations such as Mind will have immense difficulty to be able to provide this service at this cost, when you take into the account of employing a suitable qualified worker, with associated on-costs.
Planning
Mind provided a detailed submission to the Review of the NDIS Act and the new NDIS Participant Service Guarantee (otherwise known as the Tune Review) on issues associated with planning. This submission may be of interest to the Committee and can be accessed here: https://www.mindaustralia.org.au/sites/default/files/Response_to_the_Review_of_the_NDIS_Act.pdf
Our experience shows that planners generally have limited understanding of psychosocial disability. Planning meetings are fraught for people with psychosocial disability. Due to the episodic nature of mental ill-health, the timing of planning meetings can significantly impact on the plan which is created for the participant. Participant’s answers may change based on how well or unwell they are at the time of the meeting. If a participant is unwell at the time of the meeting, they may have difficulty responding to the questions being asked by the planner. Conversely, if a participant is experiencing a period of being well, they may convey that they are able to undertake tasks which they would ordinarily have difficulty undertaking during periods of being unwell. Planners need to understand this and be able to adapt their meetings to address these needs. It is also crucial that planners have in-depth knowledge of psychosocial disability to be able to prompt and probe responses.
Thank you once again for the opportunity to provide this information to the Committee. If there are any further questions, please contact Manager, Policy and Campaigns, on
Yours sincerely
Sarah Pollock Executive Director, Research and Advocacy