Submission re: Independent Assessments

I am an experienced occupational therapist who has worked in the community for over 12 years. I have recently worked in the NDIS space for the last 6 months and more recently have been involved with the NDIS Independent Assessment pilot. I am writing this submission from personal experience and not on behalf of any organisation.

Terms of reference –

• the development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS

I would like to start by acknowledging that access to the NDIS has been difficult, inconsistent and caused unnecessary financial burden to many individuals with a disability and their families. This is particularly the case for those that have a disability that varies in intensity and functional disability, such as for someone with Multiple Sclerosis. I know of participants trying more than 3-4 times before finally being accepted on to the NDIS, purely because the process is confusing and health professionals find it difficult writing reports in the language accepted by the NDIS. That being said, I do not believe that the Independent Assessments in their current form of implementation meet that need for a more consistent, simpler and affordable approach accessing the NDIS. I would rather see the option and choice for people with a disability to choose to see an independent assessor or to arrange their own functional capacity report and have both options funded to a certain price range by the NDIS.

• the independence, qualifications, training, expertise and quality assurance of assessors; While working for a provider who is involved in the Independent Assessment Pilot, I understand that my colleagues all have the qualifications necessary to use the assessment tools. However, although we have all received the same training from the NDIS and our own organisation in completing these independent assessments, I have no doubt that those who have never worked in the disability field will lack the clinical judgment required to complete the assessments in adequate details. After completing independent assessments myself, I can personally say that it is physically, mentally and emotionally draining. I have had participants cry during the assessment and others who have had no support persons there with them. I am concerned that the pressure to complete the assessments will compromise the quality and thoroughness of the assessments and therefore will not capture all the required information regarding the participants circumstances. At present, organisations are requiring assessors to complete 2 independent assessment per day, which take around 3 hours, plus they must travel to and from the appointment (which is roughly 30-45 minutes to each home) and then another 1-2 hours to finalise the details of the assessment to make sure it is thorough and consistent in the results. I can attest to the risk of burn out from this high expectation to complete the assessments and submit them within a very short timeframe.

I also have to make mention of that fact that occupational therapists are well trained and traditionally seen as the ‘experts’ in relation to functional capacity. I am concerned that a physiotherapist would be out of their scope when completing the independent assessment with a participant who has a psychosocial disability or an autistic child. They are likely to miss key information as they are not clinically adept to reporting on such functional limitations and analysing results of the assessment tools used. For example, part of the independent assessment asks if there are any discrepancies between the assessments (ie. The Vineland 3 completed by a close contact vs the self-report questionnaire completed by the individual), and asks the assessor to explain why there is a discrepancy. This is a complex question to address when an independent assessor has only been in contact with the individual for a few hours. The assessor may not actually know why there is inconsistencies between what a family member who lives interstate says and what the participant

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says about their function. At present there is nowhere on the independent assessment that the health professional can indicate that further assessment is warranted.

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

I do not regard the independent assessments as a full functional capacity evaluation. I have completed functional capacity assessments for clients in the past and believe that the current independent assessments are a screening tool rather than a robust evaluation of an individual functional capacity.

The tools selected are not designed to be used as a clinical tool for eligibility for funding. The assessments were chosen because the have robust psychometric properties, yet this is being undermined by using the tools with populations outside of this scope. For example, the Care and Needs Scale (CANS) is a tool which was designed to be used with those who have had an acquired brain injury, yet it is being used with every independent assessment for those over the age of 18. While the Vineland 3 and the CHIEF are helpful in understanding adaptive behaviours and environmental factors, they do not measure functional capacity.

The Vineland 3 is currently being answered by a close contact of the individual, however if the participant only has ‘paid supports’ in their life, the estimated results of the assessment will negate the benefit of using the tool, thus making it a waste of time.

I do not understand how a screening tool such as the independent assessment will be an adequate means of determining appropriate funding for a participant, without taking in to account all the other reports and assessments completed by the participant’s multi-disciplinary team. I believe the NDIS will only be getting half of the full picture of an individual’s circumstances using the assessments in the toolkit.

The tools do not address areas concerning an individual’s community integration, personal care relating to menstruation, carer burden, executive function and insight.

g. the implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports

Part of my concern around the use of independent assessments for planning and funding of reasonable and necessary supports is the lack of clinical judgement to make recommendations in the independent assessment. How can someone have funding in their plan for assistive technology, if the independent assessment does not allow for information for the participant’s treating therapists.

Thank you for your time in reviewing my submission.