NDIA Accountability Project

Independent assessments and trauma-informed care for NDIS participants with psychosocial disability

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To the Joint Standing Committee on the National Disability Insurance Scheme,

I write this submission in my position as an occupational therapist providing community support to NDIS participants living with psychosocial disability. I operate as a sole trader in regional and rural areas in Victoria. I work with clients with varying mental health diagnoses, including complex trauma.

Term of reference addressed;

k. the appropriateness of independent assessments for people with particular disability types, including psychosocial disability

The proposed Independent Assessment (IA) approach neglects trauma-informed care principles; safety, trustworthiness, choice, collaboration and empowerment (Blue Knot Foundation, 2020). The expectation that a person who lives with trauma should meet with an unknown assessor, a stranger, is in violation to their emotional safety. As the participant is unable to choose who their assessor is, it is reasonable to say that participants will not have access to a safe, predictable environment. Predictable and consistent environments are vital in the provision of service delivery when working with individuals who live with complex trauma. Many people who live with complex trauma have difficulty building trust with health care providers, and have been re-traumatised by services who lack trauma- informed approaches. There can be common reported experiences of being let down or failed by the mental health system. I have concern that these experiences will be replicated within the NDIS system, should the NDIA choose to overlook careful consideration of how to incorporate trauma-informed care principle.

Clear lack of choice and collaboration within the proposed IA approach reduces the likelihood of empowerment, and therefore recovery. It is observed that the IA approach fits within a certain power dynamic, by which the assessor holds the power, demonstrated by; The assessor knowing who they are assessing prior to the appointment, the assessor conducting the assessment with standardised tools that are pre-determined, the participant being unable to utilise reports/assessments from health providers of their choice when accessing the scheme or submitting a plan review, and the participants having to ‘prove’ his level of disability to a stranger to gain access to needed supports.

The principle of trustworthiness has been neglected, and can be demonstrated by the NDIA’s inconsistent messaging related to NDIS pathway reform (see Appendix 1). It is clearly stated that people living with psychosocial disability and complex needs, to be interpreted as including those living with complex trauma, will have access to a ‘psychosocial disability stream’, which is contradictory to the proposed ‘disability neutral approach’. It is unclear when the Government and NDIA changed their mind on this approach. It is observed that inconsistency with reforms for access and planning processes, lack of clear messaging and contradictory approaches is likely to impact trauma survivors ability to develop trust with the NDIA. Failure to build trust with trauma survivors may have serious implications, such as; risk of disengagement, further isolation from needed support, and therefore, reduced quality of life. It is obvious that messaging/ processes within the NDIA are subject to change, which offers the questions; Have consumers living with trauma (or advocacy organisations, mental health clinicians specialising in trauma) been involved in the development of the IA approach? How can the NDIA address the principle of ‘collaboration’, if appropriate consumer consultation has not been completed?

Reference

According to the Blue Knot Foundation (p. 9, 2020) ’a trauma-informed approach is an important paradigm for engaging with all clients because it emphasises the principle of ‘do no harm’. In prioritising the values of safety, trustworthiness and empowerment, the principles of trauma-informed care also foster optimal service-delivery more broadly’. The NDIA is strongly encouraged to re-consider the IA approach, and review the framework to ensure a trauma-informed approach, which may have benefit for all NDIS participants.

The efforts of the Joint Standing Committee in reviewing the NDIA’s proposed Independent Assessment approach is acknowledged.

Appendix 1 - NDIS pathway reform

The NDIS pathway reform report published by the NDIA in February 2018 provides a strong critique of the proposed IA reforms.

The NDIA website described how the reform work was initiated as:

“The NDIA initiated a ‘Pathway Review’ in April 2017 to address feedback about people’s interactions with the NDIS. We worked with more than 300 stakeholders from all states and territories to identify areas for improvement to ensure people have consistent and positive NDIS experience. Feedback was captured in the ‘Improving the NDIS Participant and Provider Experience’ report, released in February 2018.”(https://www.ndis.gov.au/news/1215-ndis-pathway-reform accessed 28.03.2021)

The Tune review took considered this report and states:

“2.32. This review also acknowledges the NDIA has developed a number of strategies to address these issues and improve the participant experience. Much of this work was generated following a 2017 review of the participant and provider pathways, which the NDIA initiated to address people’s feedback about their experience with the NDIS and to identify areas for improvement. Some of the improvements rolled out following the pathways review have included:

a. specific pathways for participants with complex needs, or who enter under the ECEI gateway

b. specific service streams for people with psychosocial disability and hearing loss, to deliver targeted support that provides those participants with an experience more suited to their specific disability needs

c. service enhancements to meet the communication and engagement needs of people from different backgrounds or regions, including Aboriginal and Torres Strait Islander peoples, people from CALD backgrounds, people living in remote and very remote communities, and people who identify as LGBTIQA+.” (Tune review p.31)

The Improving the NDIS Participant and Provider Experience report that detailed that NDIS pathway reform contradicts the proposed IA reforms.

The report states:

“Since early April 2017, the NDIA has been working with individuals and in workshops with more than 300 stakeholders from all states and territories to identify what needs to improve and how that might occur. From that process, 400 specific improvement ideas and 200 solution opportunities were identified. The Pathway Review also considered Productivity Commission submissions outlining improvement opportunities, feedback from the Independent Advisory Council and views expressed at the Joint Standing Committee.”(P. 8)

The same NDIA that is currently proposing disability-neutral assessment tolls and state that all assessors can complete these tools have previously acknowledged that a disability neutral and cohort neutral approach is not appropriate.

This is expressed in the Improving the NDIS Participant and Provider Experience report that states:

“The NDIS recognises that every participant is unique, and that a one-size-fits-all approach is not appropriate. The Agency is working to tailor the participant pathway to meet the needs of specific population groups. Tailored pathways are being designed in close collaboration with participants and other stakeholders.

The six tailored pathways to be designed or enhanced are for:

  • Early Childhood Early Intervention (ECEI)
  • People with complex needs
  • People with psychosocial disability
  • People within Aboriginal and Torres Strait Islander communities
  • People within remote and very remote communities
  • People within culturally and linguistically diverse communities.

Once the design of the tailored pathways is completed, they will be piloted and rolled out nationally. The Agency will continue to engage closely with participants and other stakeholders as they are pilotted and through implementation.“ P.26)

The full report released by the NDIA, and still available on the NDIA website, reads as a rebuttal of the proposes IA process. (Read the full report (PDF 836KB)

The joint announcement by then Minister for Families and Social Services, Paul Fletcher, and Assistant Minister for Disability Services, Sarah Henderson in October 2018 on a new “psychosocial disability stream” for the landmark scheme during World Mental Health Day also contradicts the disability neutral assessment approach.

The announcement, still available on the NDIA website states:

Pathway reform

Media release from the Minister, Media release from the Assistant Minister

1 O October 2018

People with severe and persistent mental health issues will have improved access and support in the National Disability Insurance Scheme {NDIS), the Federal Government has announced today.

Minister for Families and Social Services, Paul Fletcher, and Assistant Minister for Disability Services, Sarah Henderson, jointly announced a new ‘psychosocial disability stream’ for the landmark scheme during World Mental Health Day.

Psychosocial disabilities are those that may arise from severe and persistent mental health issues.

Mr Fletcher said the new stream is a critical step for the NDIS in providing a better pathway and support to about 64,000 Australians with psychosocial disability, as well as their families and carers.

The new stream will be implemented progressively and includes:

  • the employment of specialised planners and Local Area Coordinators;
  • better Linkages between mental health services and National Disability Insurance Agency (NOIA) staH, partners and;
  • a focus on recovery-based planning and episodic needs.

“This reform follows recommendations by the national peak organisation, Mental Health Australia in its National Disability Insurance Scheme Psychosocial Disability Stream Report’ Mr Fletcher said.

Assistant Minister Henderson thanked Mental Health Australia and the many sta keholders, including NDIS participants, families and carers, mental health professionals, advocates and partner agencies who informed the report’s decommendations.

“The Government is Listening to the sector and acting on its recommendations, as we see today with establishment of the new NDIS stream· Ms Henderson said.

Mental Health Australia CEO Frank Quinlan welcomed the Government’s announcement and the NDIA’s support of the majority of the report’s grecommendations on World Mental Health Day.

“We’re pleased the NOIA and Govern ment is Listen ing to the concerns of NDIS participants and their carers, and will be investing in improving the experience of people with mental health issues under the NDIS. We look forward to working with the NOIA in the further design and implementation of the new psychosocial disability strea m” Mr Quinlan said.

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It is unclear when the Government and the NDIA changed their mind on this approach. Instead of the announced pathway, people with psychosocial disability, including people living with complex trauma, will be exposed to the harm of the current process with assessment tools that are unsuitable for their needs.