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

I am an Occupational Therapist, qualified since 2008, and have a Masters in Clinical Rehabilitation. I currently work with recipients of the NDIS. The clients I work with have a variety of complex disabilities including Spinal Cord Injury, Stroke, Traumatic Brain Injury, Cerebral Palsy, degenerative and progressive neurological conditions, intellectual disability, and severe rheumatoid arthritis. A great majority of these clients also have comorbid mental health diagnoses as well as multiple other conditions which affect their disability and day to day functioning.

As Occupational Therapists the key components of our practice are client focused and holistic care. We understand that individuals with disabilities often have complex and fluctuating needs from day to day. When completing functional assessments currently for the NDIS, these take 10 hours per assessment. Assessments required to support access to SIL (Supported Independent Living) or SDA (Specialist Disability Accomodation) will require between 15-20 hours. We will often assess the client on more than one occasion, and we collaborate and liaise with all health and medical professionals involved. We review current and previous reports. We talk to family, carers, and support workers. Occupational Therapists also use a combination of standardised assessment, informal assessment, obervation, and functional assessment and task analysis. This is a very involved and detailed process to gain an accurate picture of the client’s current disability, functional abilities, strengths, and weaknesses and support needs. It is outrageous to imagine that this process and the decision of what type of package and funding a client could be eligible for could be completed in a few hours, as is proposed by the new Independent Assessment changes for the NDIS.

I am opposed to the Independent Assessment changes proposed for the NDIS.

Below I have summarised my concerns regarding the use of Independent Assessments:

- The use of Independent Assessments will utilise a "one size fits all" approach, leaving some
    participants without much needed funds;
- Increase stress and trauma for participants and their families;
- Independent assessments will not be able to effectively capture an individual's needs within
   a short appointment, using only limited assessment tools, and with only one type of health
    professional completing the assessment;
- Independent assessments will lack consultation with participants current allied health
    therapists, with no observation, and no qualitative assessment;
- These assessments will remove the participant out of the centre of decision making,
   opposing key principles the NDIS was founded on;
- The standardised tools do not take into account all types of disabilities, or for those who
  come from a culturally or linguistically diverse background, or are First Nation People;
- Health professionals completing the assessments may potentially be practising outside of
    their area of expertise when completing these limited assessments, for example a
    physiotherapist using a standardised tool meant for psychologists and assessing an
     individual’s ability to complete their daily tasks of living;
- The proposed Independent Assessment toolkit lacks the depth and breadth necessary to
    assess an individual’s disability and the impact it has on their life:
    *  Construct validity is the ability of the tool to actually measure what it is intended to
          measure. There are issues with construct validity in the Independent Assessment

• toolkit - the construct being measured with Vineland 3 and CHIEF are adaptive behaviour and environmental factors respectively, not functional capacity.

o There is an absence of evidence supporting the assumption that functional capacity can be measured in a ‘disability neutral’ manner, in Australia or internationally. Research highlights the global absence of a single assessment tool or suite of tools, proven to have the ability to do this (Madden, 2015). WHO ICF research branch developed the ICF Core Sets in acknowledgement of functional variability between disability groups.

o Neither the Vineland-3 nor CHIEF, assessments in the proposed Independent Assessment toolkit, are validated for psychosocial disability and the WHODAS-2 has limitations e.g. does not comprehensively assess functional capacity for self-care because it does not assess the capacity or barriers to consistently wash; get dressed; plan, organise and prepare a meal; manage medication; implement daily routine.

o The WHODAS-2, another proposed assessment tool, only considers the past 30 days, and is not sufficient to capture the fluctuating capacity experienced by many people with psychosocial disability.

o The WHODAS-2 does not consider capacity for work and study, when the person is not currently engaged in these activities. The WHODAS-2 does not provide insight into the person with psychosocial disability’s capacity for economic participation.

o Using a checklist assessment such as the WHODAS-2 with participants with cognitive and intellectual disabilities without input from family, carers, support workers and other health professionals also risks underestimating the full impact of their disability on their day-to-day life. For example, an NDIS participant with an acquired brain injury who lacks insight and awareness into their disability may respond yes when asked if they can shower and dress themselves. However, they may require set up assistance, supervision and prompting from a support worker/family member/carer to assist them to correctly plan, sequence and safely carry out the task.

· Independent Assessment clinicians forming an assessment outcome without considering collateral information and reports from other health professionals is in direct opposition to best practice.

· International studies evidence the potential for harmful outcomes when disability assessment is conducted via a point-in-time standardised checklist by a mandated assessor. These harmful outcomes include increased rates of suicide, increased mental health impacts and increased reliance on prescribed medication (Barr, 2015)

· The United Nations Convention on the Rights of the Person with Disability (UNCRPD), which Australia signed in 2007, and the National Disability Strategy 2010-2020 (2010), emphasise the inclusion of people with disabilities in decision-making, and active participation in designing systems that support them.