Concerns about rationale and impact of Independent Assessments under the NDIS

14 April 2021

The Chair Joint Standing Committee on the NDIS Australian Parliament GPO Box 9820 CANBERRA ACT 2601

Dear Sir/Madam

Submission to the 2021 Joint Standing Committee on the NDIS of the Australian Parliament (JSC) Inquiry on Independent Assessments under the NDIS

The Australian Psychological Society (APS) welcomes the opportunity to provide a submission to the 2021 Joint Standing Committee on the NDIS of the Australian Parliament (JSC) Inquiry on Independent Assessments under the NDIS.

The APS is the peak professional body for psychology in Australia, representing over 27,000 members nationally, many of whom work in the disability sector. For the past 77 years, the APS has played a central role in establishing standards to ensure the quality and safety of mental health care in Australia.

In this role, the APS is responsible for promoting excellence and ethical practice in the science, education and practise of psychology as the key discipline for the reducing the burden of mental ill-health and increasing the wellbeing of all Australians. It sees the importance of ensuring people with a disability receive high quality and effective psychological services to support their mental health and enable them to live active and fulfilling lives as valued members of the community.

The submission that follows is based on feedback sought from those members. It addresses the Inquiry’s Terms of Reference questions where relevant to psychology and member feedback.

Yours sincerely

Dr Zena Burgess FAPS FAICD Chief Executive Officer

Australian Psychological Society Submission to the 2021 JSC Inquiry into Independent Assessments under the NDIS

The APS provides the following response to the Inquiry’s Terms of Reference (ToR).

Term of Reference a. development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS

The APS has considerable concern around the rationale for the introduction of independent assessments into the NDIS. It notes the JCS’s observation that the NDIA has defined an independent assessment (IA) as “an assessment of a person’s functional capacity, which will be used to inform decisions about eligibility for the NDIS and about funding in a participant’s plan”.

Notwithstanding this definition, the purpose of IAs continues to be questioned in the field by applicants, participants, health and disability professionals and practitioners and advocates (hereafter referred to as key stakeholders). The APS notes the importance, for participants and providers alike, of transparency and integrity around ensuring the Scheme continues to support equitable access for participants to high quality services and supports. It is concerned that the rationale for the introduction of the IA process and intended outcomes remain unclear.

The APS has identified the need for the NDIA to explain the IA process more adequately to applicants and participants, their families, carers and guardians, provider organisations, workers and health professionals and the peak bodies representing them and consult with them about the same. The current lack of clarity about the IA process and its purpose, has created uncertainty and fear in the field and for some applicants, their families, carers and guardians. If the IA process is to benefit applicants and participants, this lack of understanding and fear must be addressed through bottom up consultation and communication with all stakeholders.

As part of this, the APS proposes there is a need for the NDIA to articulate how the IA process will:

be compatible with other NDIS aims, such as increasing the “voice” of participants
set the scene for best quality engagement with key stakeholders
disseminate information about the process to the range of stakeholders involved
work with stakeholders to develop confidence that thorough and person-centred psychological disability assessments will be the norm and
incorporate review processes, while describing the time points at which they will occur and what will trigger them.

Term of Reference b. the impact of similar policies in other jurisdictions and in the provision of other government services

The APS is not aware of any directly analogous independent assessment policies or protocols in other jurisdictions or comparable schemes related to the delivery of government-auspiced or supported services in Australia. In some compensation schemes (e.g., NSW Victims of Crime), an independent assessor is used to determine the nature and scope of the impact of a crime, in order to determine whether compensation payments can be made. Perhaps the closet “independent” assessment process is that related to the operation of independent medical examiners (IMEs) and panels of review (e.g., Medical Panels Australia) in transport accident and workers compensation schemes (e.g., as apply to the TAC and WorkSafe Schemes in Victoria).

Importantly, significant problems have been identified in those schemes. For example, the 2016 and 2019 reviews by the Victorian Ombudsman of the WSV Scheme found the operation of the IMEs to be partisan, focused on the needs of Schemes rather than claimants and subject to ‘gaming’ that promotes the interests of insurers.

As far as the APS is aware, no other disability system in the world uses the proposed approach to IAs. That approach is, therefore, untested and the most notable existing variant on it (i.e., the use of IMEs in compensable schemes) has been shown to be flawed. The APS contends that great care is required in introducing any IA process, with a model that satisfies the need to assess a claimant’s capacities according to social determinants, not just their level of impairment.

Term of Reference c. the human and financial resources needed to effectively implement

The APS is strongly of the view that any IA process introduced will fail unless it is properly resourced. That resourcing must ensure any IA under the NDIS is undertaken by appropriately qualified, well trained and experienced professionals with whom applicants are comfortable.

For mental health conditions, the APS notes that psychologists with an Area of Practice Endorsement (AoPE) - for example, clinical psychologists, counselling psychologists, clinical neuropsychologists, educational and developmental psychologists, health psychologists and forensic psychologists - are recognised by the Psychology Board of Australia as having additional skills in diagnosis and assessment under the psychiatric diagnostic framework typically used in medical and disability settings.

Independent assessments under the NDIS are best to occur by matching the assessor to the presenting condition/disability. This may be facilitated by using a practitioner with an AoPE relevant to that disability - for example, the assessment of the needs of applicants with developmental disabilities by an educational and developmental psychologist or the assessment of cognitive disability by a clinical neuropsychologist. Equally, it may be best undertaken by using a psychologist with industry-recognised qualifications, skills and experience (e.g., significant experience in the field, holding senior/supervisory roles within disability services). This matching of clinician-to-individual will require that the NDIS appoints a diverse pool of psychologist assessors to the IA assessor pool.

Scheme participants typically have complex and diverse assessment needs, which, if they are to be best addressed, require increased access to the diverse skills available within the psychology profession. There is little guarantee this will ensue under the proposed IA process.

The APS is strongly of the view that the practitioners undertaking IAs will require significant orientation and training. This needs to involve much more than orientation to the proposed IA process and must cover the values, principles and processes underlying the NDIS. Additionally, it must include evidence of a deep, specific knowledge of types of disabilities and their implications (see the response to ToR g for associated comment).

The IA process, as outlined by the NDIA thus far, runs the risk of developing a pool of ill-equipped and inexperienced clinicians making critical decisions regarding the welfare of NDIS participants. As per the response to ToR a, there is community criticism that the current model may create situations where inappropriately qualified assessors will conduct IAs. Illustrative of this, the fear has been expressed that non- psychologists employed as assessors will be required to conduct IAs related to psycho-social disability. That possibility is not appropriate.

It is public knowledge that the contracts for the conduct of IAs have been filled. As commercial-in-confidence matters, the APS has no way of knowing, whether the contractual arrangements involved will address its concerns. It advises in the strongest terms, that AIs must not be undertaken:

by professionals who, for whatever reason, are unable to demonstrate significant experience, expertise and recognition of qualifications (including professional memberships, references, qualifications or endorsements) or are at entry or near-entry level in their professional career and/or

where there is a potential conflict of interest for this vulnerable group of Australians (e.g., should the provider stand to financially benefit if such services are approved for a participant to whom that provider deliver such services or declined on the basis of incentives).

Either scenario would represent a grave disservice to applicants. This, however, remains a risk and needs to be addressed in the service agreements, program descriptions and position documentation of workers and provider managers who will be involved in the conduct and oversight of IAs.

Given the nature and extent of dissatisfaction that has been expressed about the proposed IA model, the APS suggests a range of other quality assurance options be investigated (e.g., the use of field-endorsed, evidence-supported standardised measures, a requirement for independent oversight, satisfaction measures and outcome analysis) for their capacity to militate against potential problems, and better facilitate client centred outcomes, under the proposed IA model.

Term of Reference d. the independence, qualifications, training, expertise and quality assurance of assessors

As stated immediately above, it is critical that any IAs under the NDIS are undertaken by well trained, appropriately qualified and experienced professionals with whom applicants are comfortable.

The APS was involved, as one of six peak bodies in the IA planning project, which the NDIA funded and was auspiced through Allied Health Professions Australia (AHPA). The APS along with the other peak professional bodies involved in the project1, provided a report which argued that assessors must have:

demonstrable knowledge and a mandatory minimum level (e.g., 3 years) of experience
experience and qualifications relevant to the disability for which the applicant is seeking NDIS assistance
capacity to operate with independence of decision-making and no conflicts of interest (e.g., as can occur from avaricious behaviour by providers who are awarded government contracts and whose workers may engage sub-optimal practice based on the organisation’s business model)
adequate discipline-specific supervision (this was seen as is obligatory)
detailed training - train the trainer was seen as an inappropriate means for training assessors as it puts continuous improvement at risk when independence is not embedded in the process
appropriate use of instruments/metrics by health professionals who are by experience and qualification equipped to use them and
the empathy, understanding, knowledge and skill to look beyond scores on metrics to the underlying client story.

The APS is concerned the NDIA is yet to endorse these minimum requirements and that there is a high risk that it will not do so and best practice will, accordingly, not be implemented by the NDIS.

From a governance perspective, the APS notes that there should be transparency in commercial dealings between IA-appointed providers and their workers, subsidiaries, group companies or other companies with whom they have strong financial ties. Media reports about strong financial ties between companies providing IAs, and wholly-owned subsidiary companies providing services within the Scheme, will undermine stakeholder and public confidence in the independence of the IA process.

Illustrative of the APS’s concern, the failure to consult or report back about the two IA pilots conducted thus far is disappointing and looms as an opportunity lost. Critically, it has been reported to the APS that IAs under the pilot projects have been undertaken by inexperienced practitioners with little or no experience of

1 The Australian Physiotherapy Association, The Australian Association of Social Workers, Occupational Therapy Australia, Speech Pathology Australia and The Association of Rehabilitation Counsellors

disability. Thus, it has been asserted that questions are asked without context and the IA has failed to elicit good insight into people’s lives, goals and priorities.

From the APS’s perspective, before the NDIA commences the IA process, it needs to transparently and thoroughly clarify what it actually intends through the IA process. This includes details around a range of other important assessment issues; for example, the need for:

appropriately developed measures of participation and adaptive skill
authentic, comprehensive assessment of the individual, their environments and support systems and
clear communication about the relationship between diagnosis and Scheme eligibility and the difference between assessments for screening and surveillance/monitoring, progress and outcome purposes.

Term of Reference e. the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding

The APS has repeatedly made its concerns known to the NDIA regarding the assessment tools proposed for use in IAs. The APS questions the suitability of the prescribed tools for diverse populations, especially First Nations peoples and children with disability.

The APS notes that some of the tools proposed for use are culturally inappropriate for some populations (e.g., asking cultures that eat using hands whether their child can use cutlery). It also observes that some tools are simply psychometrically invalid or poor tools that are not fit for purpose. There is substantial difference between a screening instrument and an assessment tool. APS members have queried whether it is necessary for the NDIS to clarify the difference between questionnaires (such as ABAS-III) and tests of capacity (such as those used in neuropsychological assessment) and their relevance in context of IAs.

Members have observed that the IA proposes the use of an assessment framework without an adequate rationale for and defined framework for the assessment overall. Finally, they have argued that, although diagnoses under the NDIS can be problematic, their strength is to have provided families and practitioners with information about the type, focus, intensity, rate of learning and pace of intervention needed. Of crucial importance, members have observed that the measures included thus far are not designed to provide an indication of appropriate funding levels required, but will be used for that purpose.

Consequently, the APS contends that there needs to be a careful, evidence-based review of the assessment tools to be used. To ensure this, the APS proposes that all proposed metrics need to be specifically and independently reviewed by field recognised experts in conjunction with peak bodies (e.g., the APS test and testing committee for cognitive, sensory and behavioural tools) to determine their adequacy, sensitivity - it is important that the NDIA does not set up the conditions for the implementation of an inappropriate one-size- fits-all approach - and gaps requiring attention. These concerns were first raised by the APS with the NDIA in February 20202. The APS seeks assurance that its concerns will be addressed to ensure that the proposed IA process is considered and decisions are in line with the stated objective(s) of the NDIS.

2 These concerns were described in some detail in the APS’s submission to the NDIS 2021 consultation on supporting young children and their families early, to reach their full potential” - https://www.psychology.org.au/About-Us/What-we- do/advocacy/Submissions/Professional-Practice/2021/Submission-to-NDIS-Early-Childhood-Support

Term of Reference f. the implications of independent assessments for access to and eligibility for the NDIS

[and]

As noted, the NDIA has indicated the IA process is necessary to address barriers to Scheme entry. According to it, these barriers have resulted in the acceptance of markedly fewer Scheme participants than forecast and an inequity of access based on relative disadvantage.

It has, thus, proposed that the IA process is necessary to reduce waiting times for Scheme acceptance, restore the Scheme’s universality by rebuilding its equity of access and better informing decision-making by Scheme planners. These objectives were identified by the Australian Disability Council in response to the Tune Report commissioned by the NDIA in 20193.

The APS notes that there are significant Scheme entry problems which need to be addressed promptly. For example, one member has indicated having six current clients under a range of other compensable funding schemes who appear to well-meet the criteria for NDIS participation on account of intellectual disability or acquired or ABI, but who have an impaired capacity to successfully navigate entry to the NDIS and little support to do so.

Members are, accordingly, concerned that the Scheme’s all-too-common failure to understand the needs of applicants and participants may be exacerbated by the introduction of IAs. They have emphasised the need for clear, well-co-ordinated client-centred plans that ensure the IA process does not become another barrier for these vulnerable groups.

There is potential duress related to an assessment for the Scheme. It is important that this is reduced, not increased, by the implementation of the proposed IA process. The NDIA needs to publicly acknowledge that IAs are typically a potentially stressful and unpleasant process for participants and their families, and many participants are reticent with unfamiliar professionals whose role it is to assess them. Illustrative of this, the parent of a participant known to an APS member indicated that their daughter with Down syndrome and verbal dyspraxia (and hence very limited spoken communication skills), is quite aware of when she is being assessed, does not enjoy it at all and whatever the type of “required task”, will decline to participate. The mother of the young woman has, accordingly, questioned the quality of the information that will be obtained from a single session assessment with participants (likely to be report only) including those with an intellectual disability, in particular.

The APS is concerned that it is unclear how the proposed IA process will actually serve the needs of applicants and participants, rather than those of the NDIS. Based on the declared intentions of the NDIA, involvement in an IA will not be elective. Because IAs will be mandatory, it is critical that the NDIA demonstrates how it will address consent issues for potential participants, from whom consent for the IA will be sought and obtained and how it will be recorded. Members have illustrated this problem by reference to non-verbal, children and children in out of home care or where a government department or agency is the child’s guardian. Members have also indicated to the APS their concerns that the process may lack cultural safety for culturally or linguistically diverse, LGBTIQ and First Nations population groups. Disability advocates indicate that these groups require assessors with specialised expertise.

The problems of the proposed IA process require lengthy consideration and significant resource planning and in-depth expert and peak professional body input, before any further implementation is attempted. On

3 https://www.dss.gov.au/disability-and-carers-programs-services-for-people-with-disability-national-disability-insurance-scheme/review- of-the-ndis-act-report

this basis, the APS proposes that the proposed IA process be paused. To counter the possibility that the IA process will have unintended, adverse effects on people with disability, the APS seeks an assurance from the NDIA that discussion of all possible improvements to the IA process will occur with all stakeholder groups.

Term of Reference h. the circumstances in which a person may not be required to complete an independent assessment

[and]

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

The APS has concerns that, as it stands, the proposed IA process may be appropriate for very few applicants. It makes this observation based on various concerns. First, IAs have been allocated a maximum of three hours. In that time, the assessor needs to get to know an individual, understand the functional impact of their disability, and determine the types of support they have around them. The APS believes this is an insufficient amount of time to obtain the details required to understand the complex details and history of an individual’s life. Additionally, the mental state and in-the-moment functionality of people with disabilities can fluctuate and is open to being assessed on better or worse days and different parts of the day. A single assessment session, has the potential for misjudging the level of funding required and may lead to inappropriate plans that will work to the detriment of participants.

With respect to the question of the circumstances where an IA may not be required, the APS notes the NDIA’s intention to remove the (“List A and D”) access lists, which have hitherto identified disorders (e.g., Down syndrome, quadriplegia and high-impact sensory disability) and, hence, as a matter of normal practice, oblige individuals to undergo an IA.

The APS does not agree with that course of action and is strongly of the view that the automatic acceptance of disabilities under list A and list D must remain available for a range of applicants by disability type and age. Lists A and D have resulted in automatic Scheme acceptance and the generalist nature of the IAs proposed is likely to increase the burden on applicants and their supporters and result in negative outcomes for applicants. How IAs will increase equity and access for those with List A and D disabilities is unclear; for example, it is uncertain as to the extent to which applicants may need to fund other assessments to demonstrate eligibility. The APS contends that removal of Lists A and D will not increase access and there is a clearly expressed fear in the disability community that IAs will actually make access more difficult. The APS recommends consultation with key stakeholders to militate against any potentially negative effects of the list’s removal and ensure access to assessments by qualified health professionals for those who would otherwise have fallen under the former List A and D access impairments and disabilities, particularly in the case of cognitive, sensory and psychological disabilities.

There is concern that the type of generalist assessment proposed by the NDIA/NDIS will not meet the needs of Scheme applicants with a range of disabilities and impairments. This is obviously the case for profound physical and cognitive disabilities such as paralyses and ABIs derived from accidents and injuries. Not as obvious, but potentially as profound, is the case of severe psychosocial disability: as expressed at various places in this submission, this must be undertaken by appropriately qualified and experienced psychologists.

The proposed removal of Lists A and D is even more problematic when considered within the context of the IA process and associated barriers to assessment; including (but not limited to) a potential lack of compliance and the qualifications of the assessor. In addition, in some cases, the IA process will place unnecessary stress on families. For these reasons, and those outlined above, the APS recommend that the NDIA recognise that some individuals with certain disabilities need to be exempt from the IA process.

The removal of Lists A and D is highly problematic due to the potential intrusion into applicants’ privacy, the compliance-duress of the proposed assessment process, the lack of known, context-informed assessors and

the statistical weakness of many of the questionnaires proposed. Contrary to what is proposed, there is a need for some individuals with certain disabilities to be exempted from an IA, especially considering the added stress it will place on families. Illustrative of this is the case of an applicant who is a highly intelligent, young 22 year old, unemployed man with yet-to-be-confirmed Autism Spectrum Disorder, Obsessive- Compulsive Disorder and profound Generalised Anxiety disorder, who is living at home with his parents in an isolated lifestyle. His parents have reported him as housebound, given he becomes extremely uncomfortable, anxious and distressed in unfamiliar environments. According to them, he is incapable of successfully undertaking day-to-day functional tasks. They further stated that he is resistant to committing to interventions as he is uncomfortable with, and suspicious of, health professionals. He is not on the DSP and is totally dependent on his parents for his financial needs. He requires a thorough assessment. It is unlikely that his needs for assistance will be adequately catered for by the proposed IA process.

The APS recommends the option of follow-up assessments (as necessary) by appropriately qualified practitioners, especially psychologists, in more complex cases where cognitive, sensory, psychological and psychosocial functioning is impaired.

The APS urges the NDIA to adopt a person-centred approach to its consideration of the proposed changes with particular reference to the removal of automatic eligibility under the former Lists A and D. It is concerned about the potential impact on claimants, their families and carers and seeks an undertaking from the NDIA that no applicant will be disadvantaged by the IA process.

Term of Reference i. opportunities to review or challenge the outcomes of independent assessments

The APS is aware that under the proposed IA arrangements, the decision of an independent assessor cannot be appealed and if the process determines a person is not eligible for the NDIS or that a plan should be substantially less than it currently is, there is no avenue to challenge this. It is also aware that Scheme applicants will not be provided with a copy of the full assessment unless they formally apply to see it. There is concern that this position contradicts the Scheme’s declared intention to promote an individual’s position of choice and control. Further, the right to review and/or appeal a decision seems inherent to any assessment process and provides the opportunity for insight into the success or not of a particular model. For example, in its 2020 submission into the JSC Inquiry into the NDIS planning function, the APS observed that:

There is strong evidence that the review process is not working efficiently or effectively. There are long delays experienced by Participants in obtaining commitments to review and in completing reviews. It is common for the internal review process to take six months to complete. In the meantime, Participants often cannot access supports they require or expend funds relating to existing supports. This is borne out in feedback to the APS from its members that indicates that although treating health practitioners are intimately involved in plan reviews, and often generate them on behalf of Participants, there is considerable unfunded burden in this and no guarantee that the recommendation of the treating health providers will be acknowledged, agreed to or implemented. Thus, there are instances of appeals to the Administrative Appeals Tribunal (AAT) pursuant to failed or unanswered review requests wherein the AAT had endorsed the review request without any subsequent implementation of the AAT’s decision.

Such shortcomings were confirmed by the JSC in its Final Report for that Inquiry. In it the JSC described plan reviews as slow, unresponsive and too often likely to result lead to AAT appeals.

As currently proposed, IAs are significantly different to those outlined in the Tune Report4 in that

the assessments have not been co-designed with people with disability
any consultation appears rushed and participants’ concerns are routinely ignored

4 https://www.dss.gov.au/disability-and-carers-programs-services-for-people-with-disability-national-disability-insurance-scheme/ndis- legislative-reforms

there’s no leeway for individual people’s circumstances to ensure equity, consistent with the NDIS Act and
there are no protections, such as a participant’s right to challenge assessment results.

Based on the NDIS’s record in responding to review requests of any kind, the APS has little confidence that these shortcomings about IAs will be addressed.

The APS is very concerned that the application of the proposed assessment model to plan reviews, and the removal of appeal and review rights there, will act to reduce plan funds and the care and interventions under those plans, irrespective of participant choice and control considerations. Thus, an APS clinical- neuropsychologist member points to well-established precedents “where existing neuropsychological assessments have been overwritten by other professionals based conclusions from observations in the home environment and missing essential impairment in aspects of executive functioning”.

It encourages the NDIA to ensure clear mechanisms for review of the IA process and its outcomes. Further, the APS seeks clarification as to whether the proposal to deny the right of appeal is consistent with the United Nations Convention on the Rights of Persons with Disabilities5 and draw the inquiry’s attention to the issue paper from the Royal Commission into the Abuse, Neglect and Exploitation of people with a disability and the views therein expressed6.

As noted in its submission to the JSC Inquiry into the NDIS planning function, such a set of affairs is contrary to the proper conduct of the Scheme.

Term of Reference j. the appropriateness of independent assessments for particular cohorts of people with disability, including Aboriginal and Torres Strait Islander peoples, people from regional, rural and remote areas, and people from culturally and linguistically diverse backgrounds

This is a fundamentally important consideration that requires full exploration and best practice solutions. The APS has previously emphasised - for example, through the NDIS AHPA-auspiced IA project and a variety of submissions to the NDIS and the JSC - the need for the NDIS to pay due attention to the needs of culturally and linguistically diverse families, including first Nations peoples and members of CALD communities across its policies and protocols.

APS members are concerned that already too many individuals and families (especially those from CALD, refugee, first nations, rural/remote and low SES/Educational backgrounds) have difficulty understanding how to enter the Scheme and the relationship of an assessment to an NDIS plan and its outcomes under the existing entry process, let alone what is proposed under the IA process.

The APS also believes that it is important that the needs of socially disadvantaged families, parents with intellectual disabilities or mental illness and children in Out of Home Care, and adults in residential care settings are similarly catered for in the IA process.

The APS again expresses its appreciation of the opportunity to submit to this inquiry and hopes that the views expressed herein will be considered into the future – especially in terms of ensuring that the proposed changes do not cause any disadvantage or harm to applicants or participants with the Scheme.

There is much work to do on the IA process before the best model for it is able to be implemented. The APS contends that implementing a system like the IA process, without adequate research and having poorly qualified practitioners potentially undertake the tasks involved, places scheme participants and

5 https://www.un.org/disabilities/documents/convention/convoptprot-e.pdf 6 https://disability.royalcommission.gov.au/

applicants at risk through poorly constructed and communicated assessments will impact on their eligibility for services.

The APS again brings to the JSC’s attention that it has ongoing, significant concerns about the NDIS planning process and the behaviour of planners. It has repeatedly expressed these concerns to various inquiries and consultations. It is aware of the JSC’s concern around these matters. Unfortunately, there has been little apparent change within the NDIS around such matters. The APS is concerned that the IA process has the potential to add further confusion and will be contrary to the intention of the Tune Report.

In line with reforms underway for the mental health system in Victoria, there is a need to improve the transparency, accountability and responsiveness of the NDIS as a tax-payer funded Scheme.

Consistent with its previous submissions, the APS calls for the appointment of a body or entity to review what is proposed. It believes this this power or authority be given the Quality and Safeguards Commission of the NDIA. As part of this, the APS calls for the establishment of an expert advisory group to oversee implementation and evaluation, including ongoing review and co-design around the matters of concern that it has identified in this submission.

Based on the concerns raised in this submission, the APS seeks that the IA process as proposed be paused until “further in good faith” consultation is undertaken. As per its many previous submissions to various NDIA consultations and JSC Inquiries into the NDIS, the APS actively seeks the opportunity to engage in meaningful, ongoing bottom-up, not just top-down, consultation processes.