Submission to the Joint Standing Committee on the National Disability Insurance Scheme
Summary
As an NDIS participant, I want to express my concerns about the planned use of independent aassessments related to the following three terms of reference:
- a. the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding;
- f. the implications of independent assessments for access to and eligibility for the NDIS;* i. opportunities to review or challenge the outcomes of independent assessments.
Concerns
The NDIS has published details on why they want to bring in independent assessments and provide valid reasons for choosing a toolkit of six assessment forms: questionnaires. Outrage and fear surrounding independent assessments seem to stem from:
- the NDIS and Minister’s steamrolling attitude,
- a lack of assessment tool samples (Where can I view them?), lack of information on the required scores to pass the assessments, the lack of information on how the scores relate to funding.
Independent assessors will most likely use the following questionnaires for me because I have a physical disability:
- World Health Organisation Disability Assessment Schedule (WHODAS) 2.0 36 * A Lower Extremity Function Scale (where applicable – depending on response in participant information section)
- Craig Hospital Inventory of Environmental Factors (CHIEF)
People who haven’t gone to the trouble of tracking down these questionnaires miss out on studying them and putting through submission to the Joint Standing Committee and to the NDIS. The assessment questionnaires need to be viewable or downloadable from the NDIS website if the Government is serious about fairness.
Two questions in the WHODAS 2.0 36 questionnaire concern me, and they are:
D2. 1 Standing for long periods such as 30 minutes.
At my first plan review, my allocated LAC asked this question, and I said I couldn’t stand for more 2 minutes without my pain increasing, that is ‘cannot do’. I’m not sure if this is 5 or 6 on the scale, but I found out that my previous LAC recorded 5 for that question at my second plan review. If 5 is the worst-case scenario, then that is fine, but if 6 is the worst-case scenario, then they’ve cheated me. At this second plan review, I answered ‘Cannot do’, and the reviewer challenged me by saying I said 5 last year. Can you see how independent assessments can go wrong?
I believe that participants (if able) should write their answers on the assessment form rather than giving oral responses to the assessor. Alternatively, the participant should sight the answers at the assessment time to ensure the assessor has recorded them correctly.
D2.5 Walking a long distance such as a kilometre (or equivalent)
I’m sorry, but of those with physical disabilities, who can measure the distance they can walk on any given day? So many factors come into it. Is the surface flat, shaded or full sun, what is the weather like? Is the person wearing proper footwear and are orthotics involved, etc. How slow or fast is the person walking? Does the person need a walker when walking, etc.? Most of the time I can walk for about 20 minutes in a shopping centre on most days, but I don’t know how far I cover. If it’s necessary to stand in a queue for more than 2 minutes, I will abandon the whole thing and walk out. Give me a way to measure the distance covered, and then I can say for sure how far I can walk. Some days I can’t walk more than 5 metres because my pain is so severe. Also, what is the question getting at, anyway? What if walking that distance means you can’t do anything for the rest of the day, week or month?
The question needs more detail and parameters to determine what they are trying to find out. And again, the participant (if able) should write their answers on the assessment form rather than giving oral responses to the assessor. Alternatively, the participant should sight the answers at the assessment time to ensure the assessor has recorded them correctly.
How are the answers to these and the other 34 questions in the WHODAS 2.0 36 questionnaire tied to funding? I just don’t understand how they determine funding at all, let alone how it will relate to questions asked during the independent assessment.
Two questions in the Lower Extremity Function Scale questionnaire concern me.
- Going up or down 10 stairs
Why 10 stairs? Who came up with that? What is this question getting at? What if a person can go up and down 10 stairs, but ends up wrecked? Again, the question needs more detail.
- Sitting for 1 hour
I can only sit on some chairs for a few minutes, some not at all, but with seating aids on an adequate chair, I can sit longer. With my specialised chair at home, I can sit longer. After sitting, I lie down for at least 30 minutes before I can get up again. Sometimes I have to lie down for several hours before I can get up. Why is one hour the measurement for this question? What does it mean? If I tried to sit on an inappropriate chair for an hour, I would end up collapsing on the floor within minutes. Some people can sit for 1 hour but end up wrecked for the rest of the day. This question needs more parameters.
Most of the questions in the Craig Hospital Inventory of Environmental Factors (CHIEF) concern me.
Has anyone on the Joint Standing Committee seen this questionnaire? It’s really vague. See question 8 as an example. It asks “In the past 12 months, how has the availability of education and training you needed been a problem for you?’ I would answer ‘daily’, but the assessor won’t
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know the reason. I also ticked it as a big problem. How does this question assess someone’s disability when they don’t understand why a participant answered it this way? It could relate to lack of money or because of a physical disability or both, but like I said, the assessor won’t know why. Many other questions will elicit subjective answers. I’m not sure if this questionnaire garners the right sort of information. And I don’t know how you would relate funding to this questionnaire without further questions not shown on any assessment tools.
Conclusion
The central premise for using independent assessments is to ‘help to inform’ eligibility for the NDIS. The NDIA/NDIS should not rely solely on the assessments when determining eligibility. Suppose someone has better detail and data than the information garnered from the assessment process. In that case, they should submit it for evaluation because under section 4.31 of the Review of the National Disability Insurance Scheme Act 2013 it states that: “… this review understands that assessments will be offered free of charge and will help to inform a person’s eligibility for the NDIS.” It does not say that the assessments themselves should be the sole source of data that decides eligibility. It says the assessments will ‘help to inform’ eligibility.
Independent assessments can help assessors better understand the challenges people with disabilities face. Still, if the NDIS cuts funding or denies people access to the scheme based on assessments alone, word will get around, and the Government will receive an avalanche of appeals. People should provide their medical records and explain in their own words how their disability affects them together with a letter from their local GP and request reviews of decisions if the NDIS only uses independent assessments to determine eligibility. Introducing independent assessments could lead to a lengthy campaign from disability groups around Australia to clog up the Administrative Appeals Tribunal with appeals.
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