Issues relating to NDIS implementation in regional, rural, and remote areas of NSW

[ABN: 9398 4383 421]

Submission to the National Disability Insurance Scheme (NDIS) Joint Standing Committee

NDIS Performance and Implementation

[ABN: 9398 4383 421]

About Disability Advocacy NSW (DANSW)

DANSW has over 35 years of experience providing individual advocacy to all people with disability (PWD) of any age. The organisation services over two thirds of NSW, making it the largest individual advocacy disability organisation within NSW.

While DANSW has a presence in Sydney, it has a strong commitment to regional, rural and remote (RRR) areas in NSW. With local disability advocates – on the ground - in Armidale, Bathurst, Broken Hill, the Blue Mountains, Coffs Harbour, Dubbo, Newcastle, Port Macquarie, Tamworth and Taree – DANSW has firsthand insights and observations of the lived experiences of PWD and their families living in these areas.

DANSW’s systemic advocacy draws on coalface information from clients, disability advocates, and the disability sector more broadly to identify and address emerging policy issues. In this submission, we focus on issues relating the implementation and performance of the NDIS with a focus on RRR areas in NSW. In addition to this submission, we invite members of the NDIS Joint Standing Committee to conduct site visits to our RRR offices alongside our policy officer (contact details below) to hear more about the experiences of PWD living in RRR areas.

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Introduction

DANSW welcomes the opportunity to make this submission regarding the performance and implementation of the NDIS. To contribute to this inquiry, this submission discusses issues concerning PWD living in RRR areas identified through research undertaken by DANSW. We contrast these to the goals of the National Disability Insurance Agency (NDIA) Rural and Remote Strategy 2016 – 2019 [1] to highlight some of the inadequacies of the NDIS.

Overall, the findings in this submission demonstrate that PWD living in RRR areas continue to remain what Gething [2] describes as ‘double disadvantaged’. They have a higher incidence of disability than in metropolitan areas [3]. Yet, they are more likely to experience difficulties accessing reasonable and necessary supports and services due to a scarcity of disability services and health professionals located across vast geographical distances, and poor surrounding infrastructure (e.g., transport, footpaths, handrails, information technologies). These issues have been widely documented [e.g., 4, 5-7] and are addressed in the NDIA Rural and Remote Strategy (referred to as the Rural and Remote Strategy henceforth). While this strategy was a welcoming step in the right direction, the evidence in this submission argues that the strategy’s objectives are still yet to be realised.

If as Cary et al., describes [8] ‘a policy is only as good as its implementation’, then the NDIS’ implementation and performance in many RRR communities can be best described as complex, challenged and even problematic. It is plagued with issues concerning thin and absent markets. These market deficiencies run counter to the NDIS’ objective of more choice and control [9-11]. This can be partly attributed to the implementation of the NDIS, which saw many pre-existing disability support arrangements discontinued, defunded and or absorbed into larger service providers. Not only has this led to lack of diversity of services in many RRR communities, but it has also contributed to service gaps, as well as confusion among PWD and their families about how different service systems interact [6, 8, 12]. Worryingly, in our advocacy work at DANSW, we are seeing people fall through gaps, with ‘pass the buck’ tendencies occurring between service systems.

There have been a number of efforts and reviews in an attempt to combat these issues among key national bodies. In this, the NDIS Joint Standing Committee report on market readiness, released late 2018, called for more government intervention in the form of seed and block funding [13]. Similarly, the Productivity Commission’s 2017 NDIS cost study report

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recommended the reintroduction of block funding [14]. Both these recommendations share a commonalty where they called for more government intervention in thin markets.

However, under the scheme’s structure, the NDIA can only intervene - as a last resort – in thin and absent markets [9]. Here, changes to the pricing guide in regional and rural areas was one attempt of the NDIA to help stimulate markets. In addition to this, the Rural and Remote strategy [1] claimed that it would ‘support and strengthen local capacity of rural and remote communities’ as well as ‘harness collaborative partnerships to achieve results’ (p. 6). As a central tenet, this strategy also promised, ‘to listen, learn, build and deliver’ (p. 2). These were ambitious goals and visions. However, they have rarely been felt on the ground with many PWD and their families in RRR areas having difficulties accessing both the scheme and other service systems.

Recently, within the disability sector there have been discussions concerning the proposed changes to NDIS that involve independent assessments and personalised budgets. While these have now been abandoned after widespread community backlash, there are concerns about the implementation of algorithms that will be used to determine people’s plans. Underpinning this, is the framing of the NDIS as unsustainable, and in need of change to ensure its longevity. Minister Reynolds claims that there is a need to move toward a fairer, more equitable and sustainable NDIS, particularly for people in RRR areas. However, this focus on participants’ budgets, does not adequately address deficiencies in market supply, and it deflects attention away from the NDIA’s responsibility to engage in stewardship where markets and other service systems have failed. Ultimately, it is not clear how the move to ‘fair and reasonable budgets’ and a focus on plans will provide access to services and supports in RRR areas where there are severe shortages of services.

Considering these issues outlined in this introduction, this submission lists four recommendations below, which revolve around developing sustainable quasi-markets in RRR communities. These are then explained in further detail in the remainder of this document in relation to evidence gathered from PWD and their families.

Recommendations

1. NDIA and Department of Social Services (DSS) commits to supporting and strengthening local capacity of rural and remote communities through greater investments in seed funding that has a specific focus on establishing and

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[ABN: 9398 4383 421]

stimulating markets in RRR. This may help to attract service providers and stimulate market growth, thereby providing greater choice and control. Once a viable and self-sustaining market is established financial support can be slowly and periodically withdrawn. 2. The government reintroduces block funding for services of last resort where there is market failure to guarantee that PWD and their families have access to necessary services and support and do not have to go without. However, ‘market failure’ needs to be clearly defined in a way that captures absent/thin markets as there may be numerous services in one area. However, there are hidden deficiencies due to lengthy waitlist, distance, and costs that can make services inaccessible. 3. Local area coordinators (LACs) and NDIA staff have a clear and consistent framework to interact and communicate with participants to ensure a high standard of professionalism. Here, staff must engage with PWD and their families regularly and provide them with information and knowledge, assisting them to understand how to navigate the NDIS and other service systems. Importantly, the NDIS Safeguards Commission must hold workers accountable for failing to comply with frameworks. 4. NDIA works collaboratively with other service systems to identify and understand the unique service demands and gaps within individual communities. It must then work in a complementary way with other service systems to ensure that PWD and their families have access to services, particularly if they are deemed ineligible of the NDIS. This may prevent people from falling through service gaps.

Research process

The recommendations made in this submission are based on research that explored recurring advocacy issues reported by DANSW staff. This involved site visits conducted by Baylosis, who met and spoke with advocates (N = 24) across the ten DANSW offices. The recurring advocacy issues that were identified were then used to inform the development of a survey for PWD and their families living in NSW that examined experiences of NDIS services access and general service access, the Disability Royal Commission and inclusion within their local areas. This submission presents findings in relation to NDIS service access and general service access.

There were 317 survey respondents. Of these, 78% were PWD (n = 242) and 22% were carers (n = 75). Of the total sample, 18% reported that they lived in metropolitan areas (n = 58), 57%

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in regional areas (n = 181%), 23% in rural areas (n = 74), and 1% were outside of NSW (n = 4) but had previously resided in the state. Note for this survey, we used three geographical categories of metropolitan, regional and rural for ease of comprehension for the participants. To analyse the survey data, the responses were split into three groups based on the three geographical categories to understand the experiences of PWD and their families living in rural and regional areas compared to those who live in metropolitan areas.

Limitations

This survey, as mentioned above, was developed in relation to recurring advocacy issues identified by DANSW staff. This survey was then sent out to an email list of previous DANSW clients and was posted on DANSW’s social media sites (Facebook, Instagram and Twitter) with subsequent snowballing through the organisation’s networks. It is highly likely then, that a vast majority of survey respondents were previous clients of DANSW. Thus, this submission makes no claims of generalisability to the general population of PWD and carers in NSW, and acknowledges that the findings may be specific to NDIS advocacy trends among DANSW clients. Nonetheless, these findings are consistent with previous research, extending evidence to highlight the enduring disadvantage that PWD and their families living in RRR areas experience. Moreover, they reflect trends in DANSW individual advocacy, where the majority of advocacy work revolves around the NDIS.

Findings

The respondents were asked to rate their access to NDIS service providers from a scale of 1 to 5 (1 = very poor, 2 = poor, 3 = average, 4 = good, and 5 = very good).

Unsurprisingly, respondents in metropolitan areas reported higher ratings for access to NDIS service providers in comparison to rural-regional respondents. Specifically, respondents living in regional and rural areas rated their access to NDIS services respectively lower as reflected in Figure 1 (next page).

Respondents were provided with an optional survey question to explain reasons for their ratings. Core themes that emerged among those who rated their access as poor and very poor were inadequate service delivery, worker issues, and service access problems. These are discussed in further detail next.

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Disability

DA

Advocacy [ABN: 9398 4383 421]

Service access issues

The system is there to support participants, but its implementation is poor in that the level of service is poor” (metro participant).

Figure 1.

NDIS access service rating

Metro Regional Rural

Very poor Poor MAverage Good Very good

Poor service delivery The quote above aptly describes a common concern raised by the survey participants. As this section will discuss, the participants often reported that the NDIS had poor service provision. In this, many participants indicated that they had experienced a lack of understanding, poor communication and slow response times in their dealings with the NDIS. This is reflected in the following quotes:

|! dont know if the problem is due to the staff being lazy or just over worked. All i know is that when i need to contact my local area coordinator, im lucky to ever get a call back within a 3 week period. Matter of fact i have recently called 3 times a month or so ago, left messages and im still waiting for someone to call me and its been almost 2 months and still no contact. So the staff are either swamped with work, or the managers just dont know how to train their staff to be proficient in the work. OR, the whole business structure/plan is just pathetic and no one wants to take responsibility or ownership on fixing it (rural participant)

[ABN: 9398 4383 421]

It is very poor having NDIIS or lack of ability to have decent people to help us disabled persons in our region. We may have a shop front but trying to access them if you cannot get about alot is difficult PLUS they do NOT help, they are only seat warmers and classed as “Senior” to get the higher pay packets of tax payers when they are not even worth what they get! (regional participant).

As evidenced in the above quotes, many participants had difficulties accessing and communicating with NDIS staff. In particular, LACs were commonly reported as inaccessible and unprofessional:

Our dealing with NDIS has been very frustrating. We have had problems accessing our LAC who disappear from time to time! (metropolitan participant).

However, it seemed that experiences with LACs varied as if it was a ‘luck of the draw’, with some participants offering positive appraisals of their LACs. This is reflected in the next quote where a participant contrasts experiences that they had with different LACs.

The first three years were hell on earth. The LACs were very dismissive of my needs and were patronising. My current LAC has been amazing. He wants to learn about my disabilities so he can help me get the supports and equipment I need (regional participant).

Such inconsistences in service provision can place some PWD and their families at an unfair disadvantage, creating barriers around accessing services in addition to geographical issues, costs, and scarce resources. Not only does poor professionalism impact negatively on well- being but it can limit access to important support and services.

Additionally, financial exploitation was a common issue discussed among the participants. As one stated, it felt like ‘every last dollar is squeezed’, out of them by their LAC. Here, participants frequently described instances where LACs charged hefty fees for services without producing expected outcomes:

[C]oordination of support. Meant to resolve access issues. In reality they take all the money with meetings that produce no actual work or outcomes except to schedule more meetings. It is a waste of ndis resources, their time, my time. It leads to needing a disability advocate to

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advocate to the coordinator of supports. Useless waste. Services are vultures, they take the money and don’t abide by the law (regional participant).

Similarly, the following participants described being treated as a commodity, rather than being treated as a person:

[T]he ndis planner dont listen to what my needs are. They think of money so they dont think me as a person (regional participant).

The NDIS was supposed to have been created in response to Australia’s responsibilities as a signatory to the UN Convention on the Rights of Persons with Disabilities. The NDIS has failed to achieve its purpose. The plethora of disability services that have been created in response to the NDIS have turned people with a disability into a commercial commodity aimed at profit and not the provision of quality or skilled services (regional participant).

The quote above echoes similar concerns among the broader disability community that denounce the NDIS for increasingly moving away from its original values. It also highlights some issues with relying on a model predicated upon market-values. Namely, that service providers must rely on generating profit. While this is necessary to ensure their economic sustainability, the evidence suggests that this model – without appropriate safeguards - may come at the expense of jeopardising quality [see 15]. Cortis et al., explains current interventions that focus on regulating price, do not ‘account for what is required to deliver high quality services that are ‘personalised, co-ordinated, responses or safe’ (p.1).

Moreover, the NDIS’ quasi-market model, with its minimal government intervention, can create opportunities for exploitation:

[T]he system is open for fraudulent purposes and has no safeguards to protect the client thus rendering us without a voice and leaving us in highly vulnerable situations. The NDIS is like a negligent controlling parent that does not meet the needs of the child nor listen (regional participant).

This quote contains a paradox where there is simultaneously a lack of regulation within the market alongside paternalistic service provision. That is, services appear to have a lack of accountability and regulation, while participants feel controlled, and misheard by the NDIA.

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This can be exacerbated for people living in RRR areas where there is often little choice and control because there are minimal, or no, other services to choose from. If they are unhappy or unsatisfied with service provision, they are disempowered to look elsewhere and can remain at risk of exploitation.

These findings stand in stark opposition to the NDIA’s mission to ‘listen, learn and build and deliver’. Moreover, it does not reflect their objectives of ‘easy access and contact’ and ‘effective appropriate supports that are available wherever people live’ (p.3) as described in the Rural and Remote Strategy. Such poor service delivery, as reflected in these results, impedes upon people’s ability to access support and services, limiting their choice and control.

There is a need for professional frameworks and standards among LACs (recommendation 3). Here, the NDIS Safeguards Commission must play more of an active role in ensuring that professional practice is maintained. Accessing professional staff who treat PWD with respect and dignity must be the expectation and not the exception. The NDIA must hold NDIS staff and NDIS partners accountable for their work practices and service delivery.

Worker and service access issues

The previous section discussed issues related to NDIS’ service provision. In this section, we turn our attention to NDIS service providers, discussing commonly reported issues with disability workers and accessing services.

Here, poorly trained and unqualified workers and staff shortages were frequently reported as a concern among participants who gave low ratings for NDIS access. For many, this was heightened by their geographical location, which contributed to a shortage of service providers that were dispersed across large distances. In turn, this minimised participants’ ability to exercise choice and control:

It’s hard to find carers. Difficult to get to & poor service by unqualified staff (metro participant).

Another similarly said:

Poorly trained staff lacking working experience in the area. Low staffing levels (regional participant).

Such shortages contributed to an underutilisation of NDIS funding:

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There are limited service providers, poor quality providers and even with funding for services, accessing reliable and continued support is hard. Funding is only part of the challenge. If support is unwell or moves to a new role/location, the pwd are left without support and carers are over used (regional participant).

There is a shortage of service providers. Despite funding in NDIS plans, there are often not enough available services and supports in many RRR areas. This results in a need to travel that can be difficult for participants due to issues of mobility and financial constraints:

[I] have to access services from other cities or states because local services are over capacity. Waiting periods are so long that a plan would run out if you tried to stay with local services (regional participant).

The regional city we reside in is large enough to have a number of services available. However, it can sometimes be very difficult to get the service when required, or as often as needed, hence there is usually NDIS money left in the budget that could have been used if services were more readily available (regional participant).

The above quotes indicate that even when there are local services, they are often at capacity, making them difficult to access. This is an important consideration for NDIS planners where services providers in rural-regional areas may be ‘present’ but not readily accessible. Consequently, market deficiencies and failures may not be immediately apparent.

The time and costs associated with travel also impacts on the supply of workers, which may mask market deficiencies. While service providers may cover RRR areas, many are unable to regularly attend some regional and rural areas and/or charging costly fees.

The area I am in is classified as regional but I am 35 kms from the nearest small town. I have to find support people willing to travel to my home and paraprofessionals will only visit when they can cluster other appointments in the area which means once or sometimes twice a year. All other disability services or mainstream service, I have to arrange support and transport to, which ends up costing a lot of money from my limited NDIS funds (regional participant).

Another participant wrote:

NDIS is great, actually a great help, problem is in rural areas is getting someone to travel on a regular basis to help with daily living tasks (rural participant).

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As reflected in the above quotes, the perspectives and experiences varied regarding the efficiency of NDIS plans to fund workers and travel. However, the one key commonality here is that there is a shortage of service providers. Again, this points to issues with thin markets where distance and geographical location impact on service availability and the participants’ funds. These experiences do not reflect the NDIA’s goal of having effective and appropriate supports wherever people live. Conversely, the evidence in this report, corroborates previous research [2, 5, 10, 16], that indicate that PWD and their families who live in rural-regional areas have greater difficulties with accessing necessary and reasonable services compared to those who live in metropolitan areas. These findings present support for our recommendations for the reintroduction of block funding to ensure PWD and their families have access to services (recommendation 2), and for the NDIA and DSS to support and strengthen the local capacities of RRR areas through investing in seed funding that focuses on establishing markets in RRR areas (recommendation 1.)

As Carey et al., describes, the NDIS is not one national market, but multiple diverse markets that need to be developed over time [8]. In this, thin and absent markets in regional-rural areas require government stewardship to stimulate and support the growth of services overtime. This can be done through investing resources to engage both users and service providers of local communities, and to understand the unique objectives and enablers of successfully delivery within individual communities. The NDIA must then allow providers and participants to respond to incentives, and it needs to constantly monitor the ways in which markets are developing. Lastly, the agency must respond and make necessary adjustments accordingly with the input of providers and participants [8].

Relying on other service systems: Accessing generalist services

This final section briefly discusses access to general services associated with disability (e.g., allied health services, primary health services, primary mental health services). While this is not directly addressing the implementation and performance of the NDIS, it is raised here because, as Only and Dickenson (p.276) put it, the scheme’s success hinges upon access to universal and mainstream public services’ [17]. Here, service systems must interact in complementary ways to ensure that PWD can access necessary services.

The NDIS’ remit is to provide Australians ‘with a permanent and significant disability under 65 years of age with reasonable and necessary support they need to live an ordinary life’. In practice, these criteria are fraught with inaccessibility issues due to inconsistencies in how

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[ABN: 9398 4383 421] concepts of permanence, significance, and reasonable and necessary support are defined. For those who cannot access the NDIS, there is often an assumption that there are other service systems available to meet people’s needs. However, many people fall through service gaps unable to access general supports and services. The survey results revealed that across the three groups, the percentage of NDIS participants was lower in the regional (63%) and rural groups (58%) in comparison to the metropolitan (70%) group. Thus, indicating that the further people are from major cities the less likely they are to be on the scheme. Alongside this, participants in the regional and rural groups reported lower access rating for general services as shown in Figure 2 below. This suggests that, despite regional and rural areas having higher rates of PWD [3], there is lower access to services for PWD. This points to cracks in service systems — if a person is not able to access the NDIS, it is unlikely that there will be other mainstream and universal public services that will sufficiently address their needs.

Figure 2. General service access Metro Regional Rural Very poor Poor ™ Average Good Very good There are barriers preventing people from accessing general services. When asked to describe reasons for their ratings, the survey respondents commonly described barriers that were related to distance and cost, long waitlists and a lack of clarity around what is available. The following two quotes exemplify these issues, and are from participants in regional areas, who are unable to access this NDIS: 13

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The wait list in regional areas is 2+ years which is forcing people to travel hours away for their appointments (regional and non-NDIS participant).

It is too hard to get support In all areas from gathering new information to financial support and navigating changing health problems and people with progressive health issues to get recognised the whole thing is not fair (regional participant/non-NDIS participant).

Similarly, another non-NDIS participant in a rural area wrote:

Rural areas don’t have all the specialists available to them. e.g. In my area there are private neurologists but only one public one part time and the wait time for appointments is at least a year. I can only phone my doctor as they are in the city and I can’t travel there, as a result I cannot claim my appointments on medicare, so it costs me a lot of money I actually can’t afford financially but have to have medically… It also so hard when you have to go to so many different places to get support… So where do you go then and how do you find out about other support services. In relation to NDIS I would not put myself willingly into the hands of the NDIS (rural participant).

Unlike the previous two participants who could not access the NDIS, it was unclear as to why this participant was not on the scheme. Their quote suggests it was by choice, and their perception of the NDIS was negative. This aligns with overall trend in the survey results that indicate that participants living in regional and rural rate their access to NDIS services as lower than those in metropolitan areas for reasons associated with poor service provision (discussed above). Such negative appraisals may create an additional hurdle for potential NDIS participants. This is because negative community attitudes and experiences of the NDIS can potentially deter other people from attempting to access the scheme as they may wish to avoid negative interactions with the agency, and place undue stress unto themselves.

Overall, these results reveal that there are continuing issues with accessing both the NDIS and other necessary general services where service systems are failing to interact. There is supposed to be a shared responsibility between the NDIA, the state, territory and Commonwealth government services to ensure that service delivery systems work together to improve the lives of PWD [18]. In this, the interaction of the NDIS with other service systems plays a significant role, funding personalised supports, unless those supports are a part of another service system’s universal obligation or considered a reasonable adjustment. Yet, as results of this research suggest, these visions are often not the lived experiences of

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PWD and their families, particularly for those living in RRR areas. This provides the basis for our fourth recommendation; that the NDIA works collaboratively with service systems to identify the service gaps and to ensure that it not only offers stewardship to stimulate the growth of services, but to ensure that people have access to support, particularly for those that are deemed ineligible for the scheme.

Essentially, this is not a recommendation per se, but a drawing of attention to the NDIAs mandate and holding the agency accountable for its shortcomings in areas where PWD and their families are experiencing access issues. This is not to suggest that other service systems do not have a part in this. However, the focus of this discussion is on the NDIS and the ways in which it can improve.

Conclusion

This submission highlighted common access issues for PWD and their families, with a particular attention to regional-rural areas, bringing to the fore some of the lived experiences of people who live in these areas. In doing this, it presented evidence to suggest that the implementation and performance of the NDIS quasi-market model is failing in many regional- rural areas. Under the current market structure there are gaps that limit alternative and meaningful choice and control. A limited number of services, a scarcity of professional workers and poor service provision were among some of the access issues discussed. As others have argued, there is a need for more government stewardship to ameliorate these issues [9, 13, 14]. The current interventions have not yet yielded much success. Therefore, at its core, the recommendations in this submission (listed on page 4-5) call for a shift in focus from individuals’ plans to the NDIAs responsibility for stewardship where there are market deficiencies.

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Reference list

1. Agency, N.D.I., NDIA Rural and Remote Strategy 2016 - 2019. 2016.

2. Gething, L., Sources of Double Disadvantage for People with Disabilities Living in Remote and Rural Areas of New South Wales, Australia. Disability & Society, 2010. 12(4): p. 513-531.

3. Statistics, A.B.o., Disability, ageing and carers, Australia: summary of findings 2015, Australian Bureau of Statistics: Canberra.

4. Bostock, L., Access and equity for people with a double disadvantage. Australian Disability Review, 1991. 2: p. 3 - 8.

5. Brentall, B. and M. Dunlop, Distance and Disability: a Survey of Children with Disabilities in Isolated Areas of Australia. Sydney, Uniting Chruch National Mission Fronteir Services, 1985.

6. Cortese, C., et al., Hard-to-reach: the NDIS, disability, and socio-economic disadvantage. Disability & Society, 2020: p. 1-21.

7. Fanning, P.p.p.a.t. Issues in the provision of mental health services in remote and rural areas. in Rural Health Forum: new networks- new directions. 1993. Bowral.

8. Carey, G., et al., Redressing or entrenching social and health inequities through policy implementation? Examining personalised budgets through the Australian National Disability Insurance Scheme. Int J Equity Health, 2017. 16(1): p. 192.

9. Carey, G., et al., NDIS Markets: Market stewardship actions for the NDIS. 2018, Centre for Social Impact

10. Howard, A., et al., ‘I’m not really sure but I hope it’s better’: early thoughts of parents and carers in a regional trial site for the Australian National Disability Insurance Scheme. Disability & Society, 2015. 30(9): p. 1365-1381.

11. Johnson, E., M. Lincoln, and S. Cumming, Principles of disability support in rural and remote Australia: Lessons from parents and carers. Health Soc Care Community, 2020. 28(6): p. 2208-2217.

12. Loadsman, J.J. and M. Donelly, Exploring the wellbeing of Australian families engaging with the National Disability Insurance Scheme in rural and regional areas. Disability & Society, 2020.

13. NDIS, J.S.C.o.t., Joint Standing Committee on the National Disability Insurance Scheme Public Inquiry. 2018, Commonwealth Government of Australia;: Hansard.

14. Costs, P.C.N., NDIS Costs. 2017, Commonwealth Government of Australia: Canberra

15. Cortis, N., et al., Reasonable, and valued: Pricing disability services for quality support and decent jobs in SPRC Report 10/17. 2017, UNSW Sydney: Socialy Policy Research Centre, Sydney.

16. Trounson, J.S., et al., A systematic literature review of Aboriginal and Torres Strait Islander engagement with disability services. Disability & Society, 2020: p. 1-25.

17. Olney, S. and H. Dickinson, Australia’s New National Disability Insurance Scheme: Implications for Policy and Practice. Policy Design and Practice, 2019. 2(3): p. 275-290.

18. ., C.O.A.G. Principles to determine the responsibilities of the NDIS and other service systems. 2015; Available from: https://www.coag.gov.au/sites/default/files/communique/NDIS- Principles-to-Determine-Responsibilities-NDIS-and-Other-Service.pdf.

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