NDIA Accountability Project

Conflict of interest in Support Coordination and Supported Independent Living (SIL) environments

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Submission into the

Performance of the NDIS

Submission

Our submission will focus on the area of support coordination and in particular address the areas of:

  • Conflict of Interest
  • Which Participants Receive Support Coordination Funding
  • Support Coordination Focus on Outcomes

Conflict of interest

We believe that there is a conflict of interest that exists when an organisation provides Support Coordination and is also involved in the delivery of other supports.

As outlined in the NDIS Support Coordination Discussion Paper 2020 on average, just under half (41%) of participants currently receive their Support Coordination from a provider who also provides them with other supports.

As a provider of therapy supports, we experience this conflict of interest most frequently in the area of Supported Independent Living (SIL).

Closed Systems

It is our experience when an organisation provides support coordination and is the SIL provider there is a high risk that the participant has increased risk of vulnerability due to this closed system. A closed system is defined as when a participant live and spend each day in services that are closed from the outside environment, and all interaction and knowledge is transmitted from within the closed system

This situation was explored in the IAC 2016 paper, Building Capacity and Reducing vulnerability in closed systems.

This report referenced anecdotal evidence to contend that many people in closed systems do not receive capacity building support to enable them to experience new opportunities and increase their independence, self-management and community inclusion.

Removal of the Conflict of Interest in SIL environments

We lend our support to the recommendations provided in the Tune Review 2019 and IAC Advice 2019 which both point to the conflict of interest that exists when an organisation provides support coordination and other supports. They both encourage the NDIS to take steps to minimise this conflict.

It is our view that this conflict of interest presents a risk to the participant as they are unable to exercise choice and control in their acquisition of other funded supports. They are also unable to fully explore opportunities to build their capacity.

We can point to multiple examples where the conflict of interest has resulted in negative outcomes for the participant:

 -   Advice / recommendations from external therapists have been dismissed not based on the
   impact on the participant but based on the impact on the opereational model for the
    organisation, ie a recommendation to introduce strategies that will ultimately increase
   independence have been dismissed as it will have a net decrease on support worker hours
    provided.
 -   Provision of supports are often scheduled based on times and venues that suit the “closed
   system” and not based on what will build the capacity of the participant for example therapy
    only being provided at day program venues.
 -   Decisions relating to support providers for a participant being based on what is available
    within the “closed system” and not based on what skills are required for the participant.
 -   The quality of a participant’s assessment or plan is compromised due to the capacity /
     availability of the resources available in the “closed system”.
 -   Reporting about participants by external providers such as therapists is often scoped out
   based on the needs of the support coordinator and how it aggregates into their reporting
    obligations and not based on the needs of the participant and scheme.

The net effect of many of these examples is that the participant does not receive the diversity or quality of supports required to build their capacity and to provide opportunities for growth and development.

We recommend that the NDIS take steps to minimise the conflict of interest that exists when an organisation provides support coordination and other supports in particular within the SIL environment.

Which participants receive support co-ordination funding

There appears to be inconsistencies in funding allocation of support co-ordination in a person’s plan. This has a flow on effect to the inconsistency in quality of service delivery and the role of support co- coordination.

It is recommended that clear and transparent criteria is developed to inform decisions about the person’s need for support co-ordination in their NDIS plan.

Focus on Outcomes

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  • As outlined above, there is variability in service delivery within support coordination. Many SC’s are focused on “building a case” or supporting the participant to maximise the value of their current or next plan. One of the key strategies for the SC to maximise plan value/budget is to request a range of therapy assessments and reports, which are often both unnecessary and the funding could be better used towards capacity building activities. For example, a person may have 10 hours of Occupational Therapy in their plan to achieve an outcome related to community life and the SC will request and assessment and report (6 hours), which leaves insufficient hours to achieve a functional outcome. There have been examples of support coordination agencies marketing their services as an agency which will maximise your plan budget, as a Unique Value Proposition. We believe the focus should be on support a person to achieve outcomes that will change life trajectory.

It is recommended that guidelines be developed to shift support co-ordination to an outcome focussed service, with a fade out strategy when the person and their informal supports have achieved specific outcomes related to interdependence, sector/scheme knowledge, established relationship with providers, self-advocacy.