Carolyn Fitzgibbon

Trellis Mental Health

27/08/2021

I am writing to you in my capacity as Occupational Therapist.

I have over 25 years’ experience of working with people with psychosocial and neurodevelopmental disabilities. I have completed functional assessments and also access reports for the NDIS.

I have had clients who are so stressed about meeting me (who they are coming to see because they wanted to get help) that they are unable to speak or are dissociated in the sessions. To think of these same clients meeting an independent assessor and then knowing that they will be making a decision about whether they can access the NDIS , is likely to send their anxiety sky high.

Many of my clients with Psychosocial disabilities and Neurodevelopmental Disabilities will require multiple sessions before they are able to be less anxious or dissociated in sessions and therefore are able to answer the questions that I ask of them in a detailed and accurate response.

So if I did an assessment on the first meeting and then on the fourth meeting, they would be very different assessments.

When I am completing an access or functional assessment, I observe the client and gather a lot of information from them and their other supports. Then when I am asking questions that are standardised, I am able to apply the information that I have generated to this particular individual and to ask further questions to clarify. For example one person said that she can shower (because she can do the steps involved with showering) however she hadn’t showered for over a month! Another client said that she was able to catch taxis independently however she did not think to mention that she always needed someone else in the car with her due to her anxiety. She often had men that she met at a local bar accompany her in the taxi so that she was not on her own. This situation was not safe but this additional information was only gained with further questioning.

On multiple occasions I have compared my scoring of the WHODAS with someone who did not know the individual and they were very very different scores. This was a result of the additional clarifying that I was able to do that extracted the information that there was a difficulty. Also I was asking the questions after calming the person’s anxiety whereas the NDIS planner may have been completing it when they first met the individual and the anxiety was high.

I have over 25 years’ experience with people with psychosocial and neurodevelopmental disabilities however I would refer to another OT if a client requested a functional assessment on people with other disabilities. This is because the knowledge of the disability is important to be able to ask additional questions. For example if I was asking someone with Motor Neurone Disease some questions, I would not know enough about the

Concerns Regarding NDIS Assessments

disability to identify that their answers did not make seem to make sense given their disability. I am therefore very concerned that the NDIS is employing general assessors who will be assessing people with a range of disabilities.

I am also particularly concerned with the use of the Vineland 3 to assess whether people with disabilities are able to access the NDIS. The next section of my submission is on the Vineland 3.

Not standardised for some of the populations that the Vineland 3 is proposed to be used for.

The Pearson Website (which sells the Vineland 3) has the following information on the Vineland:

All Vineland-3 forms aid in diagnosing and classifying intellectual and developmental disabilities and other disorders. With Vineland-3 you can measure adaptive behaviour of individuals with:

Intellectual and Developmental Disabilities
Autism spectrum disorders (ASDs)
ADHD
Post-traumatic brain injury
Hearing impairment
Dementia/Alzheimer’s disease

The NDIS is planning on using the Vineland 3 to determine access to the NDIS. Yet the Vineland is not stated to be standardised for this purpose. The NDIS plan on using the Vineland 3 for people with psychosocial disability but this is not one of the Pearson Vineland 3 listed disabilities.

Questions are difficult for people with low literacy, English as a second language,

The Vineland 3 contains questions that would be difficult to understand for someone with low literacy, English as a second language, or who is unfamiliar with overseas terms. Questions on the Vineland 3 that could be problematic in this way include:

Names a penny, nickel, dime, and quarter when asked; does not need to know the value of the coins.
Reads and understands material of a ninth-grade level or higher. Scoring Tip: Score 2 for Yes or 0 for No.
Fastens snaps.
Uses pronouns correctly; pronoun gender and grammar must be correct (for example, “I want,” “Their ball,” “Call her”).
Uses possessives in phrases or sentences; grammar need not be correct (for example, “This is mine,” “Your book,” “This is Carol’s desk”).
Starts small talk when he/she meets people he/she knows (for example, says “How are you?”; “What’s up?”).
Travels at least one mile to an unfamiliar destination when needed (using public transportation, walking, biking, driving, etc.).
Says the value of a penny (1 cent), nickel (5 cents), dime (10 cents), and quarter (25 cents) when asked.

Knows what phone number to call in an emergency and how to make the call (for example, knows how to call 911 or an emergency contact).
Transitions easily from one activity to another.
Finds a needed phone number (for example, uses a contact list, the Internet, a phone book, 411).

Scoring is compared to a child

In the report that is generated, the Vineland 3 3 compares the adult to the age equivalent eg the adult who scored 43 would have an age equivalent of 2.2 years old.

This is a disrespectful way to communicate this information to people with disabilities. Instead, the scoring could indicate that the adult needs support to function in this area.

The language in the Vineland 3 3 report is also about a child rather than an adult. This is an example:

Learning about the child’s adaptive behaviour and skills is part of a process that can help in planning for her education and for any special needs in the home or at school.

Some questions are not applicable to people on a low income

Few people on a low income has furniture polish and glass cleaner.

Uses household products correctly (for example, laundry detergent, furniture polish, glass cleaner).

Few adults on a low income will have these games:

Plays with others at two or more board, card, or electronic games requiring skill and decision making (for example, Monopoly™, poker, Scrabble®, interactive video games).

Not age appropriate questions

The Vineland 3 3 contains questions that are suitable for children but are inappropriate and demeaning to ask of an adult. In addition to this the common language used is “A parent or caregiver” and there is not respectful of Adults. A more generic term could be used easily.

The Vineland 3 3 has a statement after many questions: Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

The term “outgrown it’ is disrespectful language. It is also complicated to complete. For example someone with severe schizophrenia may have been able to do some things as a child but unable to do this as an adult. eg could have been able to play simple card or board games when a child but then be unable to play it now. This scoring tip could be Score 0 if the individual did this as a child but is now unable to do so.

Many adults with disability in poverty would not have card or board games so this question would also be even harder to answer.

Plays with others at simple card or board games based only on chance (for example, Candyland®, the card game “war”). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

TRf LLIS

MENTAL HEA L TH

The Vineland 3 3 uses the language of children rather than adult at times (even when you complete the electronic record at the beginning of the assessment stating they are 50 years old) For example,

Engages with other children in elaborate make-believe activities involving more than one role (for example, plays “school” or “restaurant,” enacts a TV show or movie). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

The Vineland 3 3 includes these questions for Adult Clients to determine their eligibility to the NDIS:

Copies the play of a child playing nearby with little or no interaction between the two. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it. Shares toys or possessions when told to do so. Tries to make friends with others his/her age (that is, shows particular interest in interacting with certain other children).
Remains within safe distance of caregiver when in public places; being carried, pushed in a stroller, etc. doesn’t count. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Chooses friends with good qualities: Friends who treat him/her with respect, are supportive, stay out of trouble, etc.
Imitates or tries to imitate parent’s or caregiver’s facial expressions (for example, when parent or caregiver makes a happy, sad, or surprised face). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Looks around from time to time to check that parent, caregiver, or other familiar person is nearby. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

What things does Individuals name do that show you that he/she is interested in people? Looks at the face of parent or caregiver. Shows interest in children the same age, other than brothers or sisters (for example, watches them, smiles at them). Plays with others at simple outdoor group games with no score (for example, tag, jump rope, catch). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it. Plays with others at simple card or board games based only on chance (for example, Candyland®, the card game “war”). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

Plays with others at two or more board, card, or electronic games requiring skill and decision making (for example, Monopoly™, poker, Scrabble®, interactive video games).
Plays with others at simple indoor or outdoor games where the players keep score (for example, tic- tac-toe, kickball, card games). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Takes turns when asked while playing games or sports.
Shares toys or possessions without having to be told to do so.

What kinds of make-believe activities does Individuals name play, or did he/she play when he/she was younger? Uses common household objects or other objects for make-believe activities (for example, pretends a block is a car or a box is a house). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

Plays simple make-believe activities with other children (for example, plays “dress-up,” pretends to be superheroes). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.

Plays interactively with one or more children for at least 5 minutes with someone older supervising. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Chooses to join other children who are playing rather than watching them or playing alone.
Plays interactively with one or more children for at least 30 minutes with someone older supervising. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Plays with other children with minimal supervision.
Seeks out others for play or companionship (for example, asks others to play or spend time together).
Protects self by moving away from those who try to hurt others or destroy things (those who bite, hit, throw things, smash things, etc.).
Tell me how Individuals name plays, or what he/she did when he/she was first starting to play as a baby.
Responds when parent or caregiver is playful (for example, smiles, laughs, claps hands).
Shows interest in surroundings (for example, looks or moves around, touches objects or people).
Plays simple interaction games with others (for example, peek-a-boo, patty-cake). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Plays near another child, each doing different things. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
If you tell Individuals name that he/she can only do something for so long or be away from home for so long, how often does he/she obey?
Follows time limits imposed by parent or caregiver (for example, amount of time allowed to watch TV, play a game, use the Internet, or play outside). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it. Obeys curfews (that is, comes home when he/she is told to, during the day or at night). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it.
Informs parent or caregiver about his/her plans when he/she goes out (for example, what time he/she is leaving and returning, where he/she is going). Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it. What are some ways in which Individuals name is respectful of others, like apologizing when needed, keeping promises, and so on?
Keeps promises.
Separates easily from parent or caregiver when left with another person (that is, does not have a temper tantrum, sulk, etc. when parent or caregiver leaves or attempts to leave). What usually happens when Individuals name gets upset about something?
Recovers quickly from a minor setback or disappointment (for example, doesn’t pout for long after losing a game or not getting something that he/she wants).
Looks or moves toward parent or caregiver when approached by an unfamiliar person. Scoring Tip: Score 2 if the individual did this when younger, but has now outgrown it. How does Individuals name usually react to everyday changes like when you have to leave him/her or when it’s time to change from doing something he/she is enjoying to doing something else?

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MENTAL HEALTH

Understands the concept of sexual consent.
Is able to communicate that they do not consent to sex.
Can use Mygov without support
Is aware of the importance of internet passwords and not sharing these.
Can fix basic computer difficulties.
Overstuffs mouth and is a swallowing risk
Is sensitive to bright light and avoids shops due to this.
Is sensitive to sounds and avoids situations with loud sounds.
Has flashbacks when they hear sirens when they are out.
Able to access charities when runs out of food.
Able to find their way home when lost.
Able to use a mobile phone to navigate when lost.
Able to use an ATM whilst protecting private information on card and pin.
Able to negotiate with the bank and replace a lost key card.
Able to contact a landlord if there are
Able to fix a tripped fuse.
Able to focus attention on food preparation and does not forget and leave the food on.
Able to respond to a fire alarm
Able to replace a smoke detection
Able to advocate for self in relation to support needs.
Able to say no to a person who wants them to loan money.
Able to read a legal document
Able to source a JP and sign legal documents.
Able to source legal aid if required.
Understands the process for replacing a lost script
Has increased vulnerability to being taken advantage of due to substance use.
Able to repair a relationship after conflict.

Questions regarding employment are not suited to adults who developed the disability after childhood.

If a person with a disability in their 40s had a job 20 years ago and has been unemployed since, then they would get a score of 2 = no problem.

Has held a job (10 hours or more a week) for at least one month. Scoring Tip: Score 2 for Yes or 0 for No.
Has held the same job (10 hours or more a week) for at least one year. Scoring Tip: Score 2 for Yes or 0 for No.

Traffic

This question does not necessarily assess a difficulty with crossing the road. I.e. you can look both ways when crossing streets and roads and then walk straight into traffic. (Particularly if you can’t judge the speed of oncoming cars) Also some people are ok to cross the road when they are calm but when upset just bolt into traffic.

Obeys traffic lights and Walk/Don’t Walk signs when crossing streets or roads.

Money management

Says the value of a penny (1 cent), nickel (5 cents), dime (10 cents), and quarter (25 cents) when asked. (no dollars)

As noted previously, the coins used are not relevant to the Australian context (we have no 1 cent and 25 cent coins) but for an Adult you would also want to know that they are able to tell the difference between Australian Bank Notes.

At shops you would also want to measure that the person is able to check the correct change and communicate that the change was incorrect.

Medical.

Goes to the doctor when needed (that is, when illness or injury requires professional care). Someone with a psychosocial disability may be able to go to the doctor but may need prompting in making the appointment, remembering when it is on. This question may not obtain that information.

Completion by a Parent or Caregiver

The Vineland 3 3 is designed to be completed by a parent or caregiver. Many adults with disabilities do not have someone who knows them in enough detail to be able to complete this form accurately. Many of the questions also would be only able to be answered if they lived with the individual eg

This is significant, when their eligibility to the NDIS scheme is dependent on their scoring on the Vineland 3 (and other assessments)

This is an example of a difficult question to answer:

Refrains from entering a group when verbal cues indicate that he/she is not welcome.

Some phrases are subjective and negative
\u2022 Is overly needy or dependent (for example, insists on help even when he/she does not need it, clings to parent or teacher).
\u2022 Keeps promises.

I hope that this information is useful and that the submissions that you receive provide enough information to be able to cease the Independent Assessment process.

Kind regards

Carolyn Fitzgibbon Occupational Therapist

Carolynfitzgibbon1@gmail.com 1/102 Kedron Brook Rd Trellismentalhealth.com F: 07 3036 6701 Wilston 4051