Committee Secretary Department of the Senate Parliament House CANBERRA ACT 2600 AUSTRALIA
28/3/2021
To Whom it May Concern,
FEEDBACK REGARDING INDEPENDENT ASSESSMENTS AND CONCERNS REGARDING NDIA SCHEME DESIGN
As a passionate OT who has practiced for 24 years, always been a member of the association and is an employer of over 20 occupational therapists I am writing to share my grave concern about the current NDIA plans with independent assessments.
My private practice ‘Moore Rehab Outcomes’ is now in its 10th year and we are a medium size business with 8 Admin staff and over 24 clinicians (www.moorerehab.com.au). We are proud of our commitment to evidence based practice, client centred outcomes and empowering our patients to achieve independence and autonomy,
From the outset of the NDIS roll out, I found a large incongruence between my business’ core values and the poor infrastructure of NDIA and lack of appropriately qualified staff making decisions regarding our report recommendations.
In fact, very early on I made the business decision to deregister from providing NDIS services. This was due to numerous frustrations with their procedures, delays in approvals , payment system , travel arrangements and lack of respect for my clinicians’ recommendations with very poor understanding of clinical reasoning and knowledge by NDIA decision makers.
Concerns regarding independent assessments
I am aware of current proposed legislation to roll out independent assessments by the appointed panel, and my concerns include:
1) Proposed methodology of independent assessments using a ‘check a box’ toolkit without adequate liaison or input from the treating team.
Complex clients require a thorough assessment to determine their needs, which simply cannot be obtained in a one-off consult (if input from the team is not included). Assessing participants’ function requires a wholistic and multi- faceted triangulation of information, looking at not only diagnosis and reported needs but the gathering of evidence to underpin clinical reasoning.
A simplistic checklist is a approach, and will no doubt mean that complexities may not be captured. (particularly in assessing psychological or cognitive impairments, which can fluctuate in presentation and be more subtle in presentation)
2) Proposed use of set outcome measures to determine eligibility
I have great concerns about the inappropriate use of outcome measures which are not designed for an eligibility purpose. Outcome measures are designed to measure change in function and should be considered in the context of the functional observation of the participant / their environment / diagnosis / psychosocial and physical status. There is great danger in using a computer driven scoring checklist to determine funding needs.
3) Apparent conflict of interest with appointed IA panel
I am aware that there are suggestions that the panel providers appointed for these assessments have conflict of interest, with some companies providing both assessment and intervention.
More concerningly is the fact that a previous manager of NDIA owns one of the providers, with no doubt internal knowledge which places them at an unfair advantage in the market place. I am also concerned to hear that these panel providers are proposing to use new graduates or inexperienced clinicians to complete these assessments, which I find highly inappropriate. Surely we should be empowering our experienced clinicians to make such decisions versus junior staff, who do not have the knowledge or skill set for complex assessments.
As an owner of a medium size business, I feel that the appointment of only eight providers has restricted so many smaller businesses – and that there is restricted access for work with this model.
4) Viability of private practitioners
Most concerning to me is the hundreds of occupational therapists who have taken the leap to start private practice in this space. On various
Facebook support pages I am a member of, there is great anxiety regarding the procedures/templates, inconsistent decision making, great delays in approvals, cost of non billable work and travel, difficulty contacting or following up requests and great dis-satisfaction in meeting their participants’ needs. There is report of greater negative complaints from upset and desperate families who are unable to access the equipment, home modifications or treatment which their clinician has recommended; and often the treating clinician is blamed for this (when they are not the ones delaying approvals).
There is a large risk to more private practitioners exiting the scheme, leaving our most vulnerable disabled population without the expertise they require. A large proportion of private occupational therapists are voicing they are frustrated, disillusioned; that their core desire to provide meaningful intervention has been trodden on by this system. Without support and advocacy for our profession, I am fearful that many of these private practitioners may “give up” and their businesses will fail. If our voice is not heard, there is enormous risk to the work opportunities, job satisfaction, viability of private practitioners and sole traders in the market place.
Risk of harm to participants
But most importantly, there is a risk of harm to our participants if they are not provided with adequate funding for care, equipment and rehabilitation and not assessed by appropriately experienced clinicians.
I am happy to speak with you further, and raise this in support of my occupational therapy colleagues who are struggling to provide intervention in the current framework of NDIA.
Yours faithfully,
Kate Moore