Submission to the Joint Standing
Committee on the National
Disability Insurance Scheme
Inquiry into Independent
Assessments 2021
St Agnes Care and Lifestyle Submission
March 2021
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Index
Executive Summary 3
Introduction 4
Occupational Therapy 4
Terms of reference
1. The development, modelling, reasons and justifications for the introduction of
independent assessments into the NDIS 5
2. The impact of similar policies in other jurisdictions and in the provision of other
government services 10
3. The human and financial resources needed to effectively implement independent
assessments 11
4. The independence, qualifications, training, expertise and quality assurance of
assessors 13
5. The appropriateness of the assessment tools selected for use in independent
assessments to determine plan funding 14
6. The implications of independent assessments for access to and eligibility for
the NDIS 15
7. The implications of independent assessments for NDIS planning, including decisions
related to funding reasonable and necessary supports 15
8. The circumstances in which a person may not be required to complete an independent
assessment 17
9. Opportunities to review or challenge the outcomes of independent assessments 18
10. 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 18
11. The appropriateness of independent assessments for people with particular disability
types, including psychosocial disability 23
12. Any other related matters 23
-
References 24
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Executive Summary
St Agnes Care and Lifestyle (SACAL) welcomes the opportunity to provide feedback and
suggested recommendations regarding the implementation of NDIS Independent
Assessments.
The National Disability Scheme (NDIS) provides individualised and person centred support for
people with a disability. An NDIS plan of supports which is developed and tailored to the
person’s individual needs and if required, the NDIS will also fund reasonable and necessary
supports that help participants achieve their goals (Overview of the NDIS Operational Guideline
- About the NDIS).
The NDIS Act 2013 Object and Principals are based on provide reasonable and necessary
supports enabling people with a disability to realise their potential for physical, social,
emotional and intellectual development; participate in social and economic life; enable people
with disability to exercise choice and control; and maximise independent lifestyles and full
inclusion in the mainstream community.
The main issues we would like to raise in our submission are listed below, and the detrimental
impact independent assessments will have on people with disabilities in Australia:
-
The development of the IA process without consultation with professional bodies and
the lack of understanding of the process of completing functional capacity assessments
and professional scope of practice
-
The introduction of IA’s without consideration of previous and existing similar policies in
other jurisdictions and in the provision of other government services
-
The lack of culturally appropriate and person centered assessment pathway
-
The lack of a clear review of decision pathway and complaints pathway
-
The impact on the human rights of the person with a disability and the potential to
cause harm
-
Disregard for the following legislative, NDIS and global documents and agreements
-
Objects and Principals of the National Disability Insurance Scheme Act 2013
-
NDIS Aboriginal and Torres Strait Islander Engagement Strategy, 2017
-
National Disability Insurance Agency Cultural and Linguistic Diversity Strategy 2018
-
National Disability Insurance Agency Rural and Remote Strategy 2016–2019,
February 2016
-
Closing the Gap in Partnership, National Agreement on Closing The Gap, July 2020
-
UN Convention of the Rights of Persons with Disabilities
-
-
The conflict of interest of independent assessment panel providers
-
The unethical implementation of the IA pilots
-
Ongoing workforce issues and quality of service delivery
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Introduction
St Agnes Care and Lifestyle (SACAL) is a disability service provider located in Port Macquarie on the New
South Wales Mid North Coast, servicing the Hastings and Macleay regions.
SACAL, formally known as Centacare has been delivering services to people with a disability for 25 years.
We are an NDIS registered organisation and as such, service delivery must meet the NDIS Quality and
Safeguards Commission specific quality and safeguards requirements.
SACAL provides the following National Disability Insurance Scheme (NDIS) funded services:
- Occupational Therapy (OT) – adult, paediatric & Early Childhood Early Intervention (ECEI)
- Support Coordination – Level 2 & Level 3 (Specialised)
- Supported Living
- Support services in the home and community
- Day program
I am the Manager of Therapy Services, which includes OT and Support Coordination. I am a practicing OT
with 28 years’ experience working in rural and remote communities with NSW Health, private practice
and working with people with disabilities pre and post NDIS.
Occupational Therapy
‘Occupational therapy is a client-centred health profession concerned with promoting health and well
being through occupation. The primary goal of occupational therapy is to enable people to participate in
the activities of everyday life. Occupational therapists achieve this outcome by working with people and
communities to enhance their ability to engage in the occupations they want to, need to, or are expected
to do, or by modifying the occupation or the environment to better support their occupational
engagement.’ (WFOT 2012)
Occupational therapists provide services across the lifespan and have a valuable role in supporting
participants affected by developmental disorders; physical, intellectual, chronic and/or progressive
disability; and mental health issues. (National Disability Insurance Agency Consultation Paper: Access
and Eligibility Policy with independent assessments, Occupational Therapy Australia submission,
February 2021)
Since the introduction of NDIS, OT has played a pivotal and vital role in assessing a person’s function,
determining the person’s capacity to engage in their occupations and recommending the support they
require to do so.
The World Federation of Occupational Therapists (WFOT) states the process of How Occupational
Therapists work, https://wfot.org/about/about-occupational-therapy
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Assessment
The occupational therapy process is based on initial and repeated assessments. The occupational therapist together with the person they are working with focus on individual and environmental abilities and problems related to activities in the person’s daily life.
Assessment includes the use of standardised procedures, interviews, observations in a variety of settings and consultation with significant people in the person’s life.
Planning
The results of the assessment are the basis of the plan which includes short and long-term aims of treatment. The plan should be relevant to the person’s development stage, habits, roles, life-style preferences and the environment.
Intervention
Intervention focuses on programs that are person oriented and environmental. These are designed to facilitate the performance of everyday tasks and adaptation of settings in which the person works, lives and socialises. Examples include teaching new techniques and providing equipment which facilitate independence in personal care, reducing environmental barriers and providing resources to lessen stress.
Cooperation
Occupational therapists recognise the importance of teamwork. Cooperation and coordination with other professionals, families, caregivers and volunteers are important in the realisation of the holistic approach.’
Occupational Therapy is an Australian Health Practitioner Regulation Agency (AHPRA) registered
profession and Occupational Therapists must meet the standards, policies, codes and guidelines set by
AHPRA and the Occupational Therapy Board of Australia.
Terms of reference
1. The development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS
NDIS pilots
Occupational Therapy Australia (OTA) documents the ethical considerations of the IA pilot study in their
National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with independent
assessments, Occupational Therapy Australia submission; February 2020, Appendix 4 –The IA pilot study:
Ethical considerations, p 20, 21. OTA identify the issues of informed consent, potential for harm,
transparency, generalisability, conflict of interest and the lack of the engagement of an independent
Human Research Ethics Committee (HREC) to oversee the pilots.
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The NDIS Independent Assessment Framework (August 2020), The Rationale for Reviewing NDIS
Assessment of Functional Capacity, 2.1 Information Currently Obtained, highlights the information
obtained about a person’s function varies greatly due to the following factors:
- The Role and Experience of the Person Providing Information
- The Assessment Measures Used
- The Design and Purpose of the Assessment
- Level of Detail and Comprehensiveness
- Standardisation and Psychometric Properties
- How Recently Details Were Obtained
- Method of Assessment and Interpretation of Results
This demonstrates an obvious lack of understanding of the complex process of completing functional
capacity assessments to obtain the most holistic and comprehensive information, the responsibility of
the OT to select the most appropriate assessment tools based on clinical judgement, and the
professional scope of practice and skills required to complete the process of functional capacity
assessments. This is not just completing a single standardised assessment. The process involves:
-
Gathering a full history which includes interview with the client and relevant caregivers, and
access to medical and health professional documents and reports to evidence medical and
functional histories and risk
-
Consideration of recommendations and information included in referrals, handovers and clinical
documentation
-
Observing function in the environments tasks are carried out such as home, community, work -
OT uses clinical judgement to decide this
-
Completing task analyses if clinically indicated – OT uses clinical judgement to decide this
-
The use of standardised assessments and procedures – OT uses clinical judgement to decide the
most appropriate assessment tool
-
Consultation with significant people in the person’s life
-
Professional expertise and experience in the area of practice to understand the disability, assess
risks and inform solutions
The World Federation of Occupational Therapists (WFOT) outline the process of OT assessment
https://wfot.org/about/about-occupational-therapy
‘The occupational therapy process is based on initial and repeated assessments. The occupational therapist together with the person they are working with focus on individual and environmental abilities and problems related to activities in the person’s daily life.
Assessment includes the use of standardised procedures, interviews, observations in a variety of settings and consultation with significant people in the person’s life.’
This point also raises concerns about the lack of suitability of the standardised assessments chosen by
the NDIS to measure functional capacity as identified by Occupational Therapy Australia (OTA) in the
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National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with independent
assessments, Occupational Therapy Australia submission; February 2020, Appendix 3 – Appraisal of the
proposed IA toolkit, p17, 18, 19.
The NDIS Independent Assessment Framework (August 2020), The Rationale for Reviewing NDIS
Assessment of Functional Capacity, 2.2 Individual Difference is Compatible with Consistency of
Assessment states, ‘It is possible to accommodate individual difference while implementing consistent
information, gathering protocols and requirements’ (p7).
Accommodating individual differences will not be achieved through the proposed Independent
Assessment (IA) process as the approach is one size fits all. The person’s individual disability and the
impact of this on every day life; historical and medical information; cognition; receptive and expressive
language capacity; memory; insight into their disability and function; general understanding and
comprehension; understanding of the NDIS and funding, care needs and support networks, and
psychosocial function, cannot possibly be determined through a 3 hour standardised assessment. The IA
process would seriously discriminate against the person with the disability by not gathering adequate
and appropriate information to determine functional capacity. This would indicate the IA proposal is
designed to determine accessibility to the NDIS Scheme based on minimal information, and provide
funding which is not individualised.
The IA’s will be completed by health professionals outside their scope of practice and not consider other
significant factors in the life of the person which impacts their function. The IA proposal is at risk of
creating further disadvantage and discrimination for an already disadvantaged and discriminated
population of people.
The National Disability Insurance Scheme Act 2013, General principles guiding actions under this Act will
not be met with the introduction of IA’s as the rights, participation, choice, control, self determination,
and support needs will be undermined by engaging in a process which does not consider all the
circumstances which impact’s the person’s function, and is not in the best interests of the person.
The NDIS Independent Assessment Framework (August 2020), The Rationale for Reviewing NDIS
Assessment of Functional Capacity, 2.2 Individual Difference is Compatible with Consistency of
Assessment states, ‘A significant point of comparison for NDIS participants is their functional capacity.
Information on a person’s functional capacity is required by the Act and is a major part of the decision-making
process in NDIS, so the type of information obtained in this regard needs to be as consistent and reliable as
possible’ (p7).
Consistency and reliability of information obtained in regards to NDIS participant function will not be
achieved if functional capacity is assessed as proposed by the NDIS in the IA Framework as outlined
below:
-
Functional Capacity Assessments will be carried out by a variety of health professionals who are
not trained, skilled or supervised in completing these assessments.
-
Reliability of the information cannot be determined by completing a standardised assessment
only, as critical information will not be obtained due to the process not being completed
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holistically. Standardised assessments are only one piece of the assessment process as
described.
-
The IA assessment tools are not designed to determine access, eligibility or funding for supports,
resulting in disadvantage, discrimination and the potential to cause harm for people with a
disability.
Information on the person’s functional capacity is required by the Act and is a major part of the decision
making process in NDIS. This means the NDIS will be making decisions for people with a disability from
information obtained via an assessment process which is not comprehensive, does not follow a
functional capacity assessment pathway, will be completed by professionals who do not have the skills,
training and will be operating outside their scope of practice, and without gathering all the information
to make these decisions which should promote the rights, participation, choice, control, and self
determination of people with a disability.
A truly independent body needs to ensure IA’s are fit for purpose as there is a conflict of interest when
organisations conducting the IA pilot have a vested interest in the outcome of the trials.
The NDIS Independent Assessment Framework (August 2020), The Rationale for Reviewing NDIS
Assessment of Functional Capacity, 2.3 NDIS Processes states (p7),
As well as the inconsistencies above which do not necessarily cause biased assessment, there are two key
causes of potential bias:
-
An assessment approach which is perceived to be deficits-based, whereby people feel the need to
present themselves at their worst in order to be funded for the supports that they need.
The NDIS provides funding to a person with a disability based on their deficits ie, funding is provided for
supports for what the person cannot do, not what they can do.
-
Real or perceived inconsistency and uncertainty around the process of decision making by the NDIS,
which may lead to assessors overstating, whether intentionally or not, the need for funding for
supports for the people with whom they have developed a professional relationship. Clinicians
advocating for their clients is fundamental to any therapist-client partnership.
In my experience, providing services to NDIS participants since 1 July 2017, there is inconsistency within
the NDIS with decision making, information dissemination, processes, staff knowledge and
understanding of processes, staff skills, abilities and understanding. As an organisation, we do not trust
information delivered by NDIS staff as we receive differing advice, depending who we speak to. We have
experienced situations where NDIS planners have not read all the supporting documentation and
evidence and as a result, the person’s plan has been appealed with the Administrative Appeals Tribunal.
The NDIS has queried requests that have been clearly justified in the initial documentation presented at
the person’s planning meeting and health professionals have spent a large amount of time reiterating
the information contained in the original reports, at the expense of the individual’s NDIS plan.
Health professionals build relationships with clients and advocate for their needs based on assessment
and justification. It is a health professional’s ethical and professional responsibility to ensure there is no
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bias or conflict of interest when determining client needs and to complete appropriate assessments and
justification of this. Empathy for a person does not translate to bias. Suggesting bias toward the person
with a disability is undermining clinician’s professional scope of practice, specialty skills, professional
responsibilities and obligations. NDIS needs to work with professional bodies and AHPRA to develop and
implement a practice framework for each health profession, ensuring health professionals:
-
Operate within their scope of practice
-
Have the skills and experience required in the specific area of which they are practicing
-
Have a supervision framework in place to ensure health professionals are developing the clinical
skills required to engage in their scope of practice. This will ensure skill growth in all health
professions and sustainability of the NDIS scheme.
-
Ensure practice guidelines are in place for each health profession
It is also critical to have a national strategy for the education and training of health professionals to
enable growth of health professions and subsequent sustainability of the NDIS.
OTA has developed an alternative model for assessing eligibility for the NDIS which is a proposed
‘functional assessor endorsement program, which appropriately skilled and experienced allied health
professionals could choose to undertake in order to qualify to assess eligibility for the NDIS’ (National
Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with independent
assessments, Occupational Therapy Australia submission; February 2020, Appendix 7 – NEAT: An
alternative IA model, p24, 25).
The NDIS Independent Assessment Framework (August 2020), The Rationale for Reviewing NDIS
Assessment of Functional Capacity, 2.3 NDIS Processes states, ‘An explicit definition of functional capacity
is required for NDIS purposes that allows for evidence based assessment’ (p8).
An explicit definition of functional capacity needs to be determined with professional bodies and AHPRA
and a framework developed for all health professionals. Contracting IA’s through external organisations
does not provide an explicit definition for functional capacity and the IA process removes
comprehensive assessments being completed due to reliance solely on standardised assessments.
The NDIS Independent Assessment Framework (August 2020), The Rationale for Reviewing NDIS
Assessment of Functional Capacity, 2.3 NDIS Processes also states (p8),
‘Current NDIS operational procedures require a person to specify their ‘primary disability’. This has encouraged
the use of disability-specific assessment tools to describe a person’s functional capacity. Tools of this type serve
a specific purpose and tend to assess a person’s functional capacity in assumed areas of functional concern,
prioritising, weighting, or even neglecting some areas rather than taking a ‘whole person’ approach. This is not
well aligned with the NDIS Act, which requires a broader assessment of functional capacity. Such tools also give
rise to potential risks if certain areas of a person’s functional capacity are understated or even overlooked.
There is a need to recognise that a person’s functional capacity is influenced by a dynamic and complex
elationship between one, or often multiple known conditions, as well as other conditions yet to be diagnosed,
environmental and personal factors. A shift in assessment process is required to acknowledge that the
existence of a particular condition or disability does not necessarily have the same impact on everyone, and
differences in functional capacity are evident even when people have the same diagnosis. This understanding
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and appreciation of the relationship between functioning and the unpredictable impact of a particular
condition, requires a shift towards a whole of person, diagnosis-neutral assessment process.’
Due to the use of a singular NDIS determined assessment and atomistic assessment process, the IA
process does not
-
enable a broader assessment of functional capacity
-
recognise that a person’s functional capacity is influenced by a dynamic and complex
relationship between one, or often multiple known conditions, as well as other conditions yet to
be diagnosed, environmental and personal factors
-
acknowledge that the existence of a particular condition or disability does not necessarily have
the same impact on everyone, and differences in functional capacity are evident even when
people have the same diagnosis
-
promote understanding and appreciation of the relationship between functioning and the
unpredictable impact of a particular condition, requires a shift towards a whole of person,
diagnosis-neutral assessment process.
For this to occur, it is critical the assessment process is carried out as detailed by WFOT
https://wfot.org/about/about-occupational-therapy
2. The impact of similar policies in other jurisdictions and in the provision of other government services;
My Aged Care Commonwealth Home Support Programme (CHSP)
‘Under the CHSP, trained assessors (Regional Assessment Services) work out what support each person needs
during a face-to-face assessment in the home.’ (Department of Health, About the Commonwealth Home
Support Programme (CHSP)).
https://www.health.gov.au/initiatives-and-programs/commonwealth-home-support-programme-
chsp/about-the-commonwealth-home-support-programme-
chsp#:~:text=The%20CHSP%20is%20an%20entry,than%20doing%20things%20for%20them
OT’s working in this space have commented Regional Assessment Services assessors do not have the
professional skills to complete the assessments and are completing assessments outside their scope of
practice, informing the person of their recommendations which may not be appropriate (eg, installation
of rails, assistive technology). When the OT completes their assessment and the recommendations differ
from the information delivered by the assessor, the person is often disgruntled with the OT. This process
undermines the training, skills and specialist knowledge of OT’s, resulting in potential harm for the aged
people being assessed.
Centrelink Disability Support Pension (DSP)
From 2006, Centrelink outsourced DSP Medical Review assessments to external providers, resulting in
commercial outcomes for the service providers, poorly trained and skilled health professionals
completing the assessments, and lack of understanding of the application of the legislation. These
assessments have been completed again by Centrelink Assessors due to the poor quality of the
assessments and outcomes for the people.
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Personal Independence Payment (PIP) assessments UK
Access to the UK national disability scheme Personal Independence Payment (PIP) is completed via a PIP
test which assesses daily living and mobility. PIP payments received for daily living component and
mobility component are at either a standard rate or an enhanced rate, depending on the PIP score for
each component.
TURN2US https://www.turn2us.org.uk/Benefit-guides/Personal-Independence-Payment/What-is-PIP
Please see links below to articles about the harm caused to people with disabilities due to the PIP
assessment process and subsequent lack of funding.
https://www.wsws.org/en/articles/2020/07/29/maln-j29.html
https://www.disabilitynewsservice.com/atos-pays-out…/…
https://www.disabilitynewsservice.com/court-orders…/…
https://www.independent.co.uk/…/benefits-uk-disability…
https://www.disabilitynewsservice.com/atos-nurse…/…
https://www.liverpoolecho.co.uk/…/how-disabled-people…
3. The human and financial resources needed to effectively implement
**independent assessments**
The implementation of IA’s will have significant workforce implications and negative impact for NDIS
participants and people with a disability. The introduction of the NDIS has resulted in a substantial
increase in demand of health professionals, particularly OT’s, resulting in long waitlists and time limited
intervention due to the competing prioritisation of need.
IA’s will create competition for recruitment of allied health professionals in a space which is already
experiencing a shortage and where supporting new graduate staff is difficult due to immediate loss of
income for providers as a direct result of the need to bill for services to be financially sustainable. There
will be a shortage of health professions in the NDIS space further exacerbated with competition from
successful IA providers.
It is critical a competent workforce is grown in the NDIS space. Time and money needs to be invested in
the development of competency frameworks across all allied health professions to ensure best practice,
ethical service delivery, and professionals operating within their scope of practice.
In addition, there will also be an economic cost attached to the appeals process which will result in
people being funded inadequately.
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Dr Shereen Hussein, a UK analyst from King’s College London, discusses with Probono Australia (28
August 2017), the risks associated with the lack of workforce and adequate training and quality
safeguards to support the NDIS.
https://probonoaustralia.com.au/news/2017/08/learn-mistakes-uk-expert-warns-australian-ndis-
OTA also states:
‘OTA is acutely aware of workforce shortages across the sector and the impact this has on a person’s capacity
to access the scheme. OTA supports a model of engaging allied health providers with the relevant background,
experience and training to improve timeliness of eligibility screening. However, OTA must emphasise that this
model should only be used for eligibility screening, not for any type of assessment requiring discipline-specific
expertise.
OTA is concerned that allied health clinicians will be recruited solely to carry out IAs. This will disrupt and erode
the emerging allied health provider base which is already insufficient to manage the present demand.
OTA is also concerned that only a select number of organisations will be contracted out to provide IAs, limiting
the pool of assessors available and ultimately limiting participant choice – supposedly a key tenet of the
scheme. These assessors may or may not have the relevant background or experience to effectively assess all
cohorts, particularly those who are vulnerable and/or those who have complex needs from an area of practice
in which the assessor is not experienced (Barr et al., 2012).
OTA asks what processes will be put in place to ensure the tender process is equitable and transparent; that
vested interests and/or conflicts of interest are identified; and that independent assessors receive sufficient
orientation and training to carry out IAs before they commence. OTA would be happy to collaborate with NDIA
to develop a model for training or endorsing assessors to carry out eligibility screens.
Recommendations
-
Establish a standardised, regulated endorsement program to qualify suitably skilled and experienced
existing providers to provide comprehensive functional assessment including support-needs
identification.
-
Ensure the independent assessors have relevant skills and experience with the cohort they are
assessing. For example, only use mental health professionals to assess people with psychosocial
disability. This could include psychologists, occupational therapists or social workers.
-
Enable people with disability to access assessors with disability-specific expertise and the ability to
accurately determine support needs.
-
Implement a review process to ensure there is an equitable and transparent tender process in place.’
(National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with independent
assessments, Occupational Therapy Australia submission; February 2020, Independent assessor
workforce, p8, 9, 10.)
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4. The independence, qualifications, training, expertise and quality assurance of assessors
Independence
A conflict of interest will exist with IA’s being conducted by organisations funded by the NDIS. In addition
to this, of particular concern is the KPI’s which will be required to be met to sustain ongoing funding and
do these KPI’s conflict with the general principles guiding actions under the National Disability Insurance
Schmeme Act 2013? The IA process will have commercial outcomes and will be completed by
organisations contracted and paid for by the NDIS. This is not an independent process. The concerns of
independence is further questioned when the NDIS Consultation Paper: Access and Eligibility Policy with
independent assessments submission date closed on 23 February 2021 and the Independent
assessment panel was announced on 26 February 2021. In addition to this, some of the assessment
panel providers have parent companies who provide direct NDIS services and former NDIA CEO, Robert
De Luca is the CEO of one such company, Zenitas Healthcare (ABC News, 25 March 2021,
https://www.abc.net.au/news/2021-03-25/david-bowen-raises-concerns-on-ndis-independent-
OT Australia (OTA) proposes an alternative model to IA’s in their National Disability Insurance Agency
Consultation Paper: Access and Eligibility Policy with independent assessments, Occupational Therapy
Australia submission, Appendix 7 – NEAT: An alternative IA model. OTA propose ‘an assessor endorsement
program would meet the NDIS requirements of a more consistent approach to assessment, while enabling
participants and applicants to retain choice and control of provider. Assessors would be empowered to utilise
their professional judgement and clinical reasoning skills.’
Qualifications, training, expertise and quality assurance of assessors
A national competency framework and clear definition of functional capacity would provide quality
standards to support the ongoing training, skill development, and expertise of allied health
professionals. In addition to and supporting this would be clear guidelines through professional bodies
defining scope of practice. This governance would ensure the ongoing sustainability of high quality,
ethical and best practice health professional service delivery.
It is critical for allied health professionals to have expertise in completing functional capacity
assessments and understanding the presentation, complexities, prognosis and risks of varying
diagnoses and disabilities when completing assessments. Ongoing supervision is critical for all health
professionals, and particularly new graduates, to ensure training, development of skills and expertise,
and the quality of service provision. This will not be provided in the IA model, presenting significant risk
to people with a disability through lack of access to the scheme and poor funding in plans due to lack of
skill and expertise of health professionals in addition to the singular assessment process.
See attached National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with
independent assessments, Occupational Therapy Australia submission, February 2021; Independent
Assessor Workforce, p8&9.
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Experienced allied health professionals will be very unlikely to occupy roles as independent assessors
due to the unethical process and risk to people with a disability. NDIS qualification requirements for
assessors is a minimum of 12 months full time clinical experience post general registration. (NDIS news,
26 February 2021; https://www.ndis.gov.au/news/6118-independent-assessment-panel-announced)
This places people with a disability at further risk of disadvantage and violates their rights as stated in
the UN Convention of the Rights of Persons with Disabilities;
Article 5 – Equality and non-discrimination
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-5-equality-and-non-discrimination.html
Article 17 – Protecting the integrity of the person
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-17-protecting-the-integrity-of-the-person.html
Article 26 – Habilitation and rehabilitation
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-26-habilitation-and-rehabilitation.html
5. The appropriateness of the assessment tools selected for use in
**independent assessments to determine plan funding**
OTA raise the following concerns in their National Disability Insurance Agency Consultation Paper:
Access and Eligibility Policy with independent assessments, Occupational Therapy Australia submission,
February 2021; Personalised budgets and plan flexibility, p8.
-
IA tools are not designed for the purpose of determining personalised budgets and plan
flexibility
-
‘substantial problems, disruption and delays in providing the relevant supports, services,
assistive technology and/or home modifications when decisions for personalised budgets and
plan flexibility are made without comprehensive assessment of the participant’s needs.’
In their National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with
independent assessments, Occupational Therapy Australia submission, February 2021; Appendix 3 –
Appraisal of the proposed IA toolkit, p18, OTA also states ‘OTA is also deeply concerned by the proposal
that IAs may inform a participant’s current and future plan funding. The tools were not designed for this
purpose and there is no evidence to support the assumption that they can be used as such. (This is expanded
upon in OTA’s submission to the NDIA’s Planning Paper).’
See attached National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with
independent assessments, Occupational Therapy Australia submission, February 2021; Personalised
budgets and plan flexibility, p8; Appendix 3 – Appraisal of the proposed IA toolkit, p17, 18, 19.
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6. The implications of independent assessments for access to and eligibility for the NDIS
The NDIS Independent Assessment Framework (August 202) states ‘when considering the selection of
assessment tool(s), the primary purpose needs to be considered. The primary purpose of an assessment of
functional capacity for NDIS is to support Access and Planning decisions. This can be achieved by using a suite
of assessment tools that collectively have different properties.’
OTA highlight their concerns and recommendations re using IA’s for access and eligibility to the NDIS In
their National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with
independent assessments, Occupational Therapy Australia submission, February 2021; NDIS Access and
Eligibility, p 5, 6, 7. The concerns include and are not limited to:
-
The IA toolkit is not fit for purpose
The process impinges on the rights of people with disability and limits their choice and control
-
The tools proposed for the IA are not designed to effectively identify functional needs related to
the NDIS assessment domains and there is no clarity on how the data collected from these tools
will be collated or analysed to determine eligibility
-
The proposed toolkit is predominantly based on self-report measures that are not designed as
assessment tools or as tools to determine functional capacity
In their National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with
independent assessments, Occupational Therapy Australia submission, February 2021; Appendix 3 –
Appraisal of the proposed IA toolkit, p17, OTA also states ‘It is entirely inappropriate to determine a
person’s eligibility for NDIS supports using a set of tools which were neither designed nor validated for
this purpose and population.’ This is elaborated on further on pages 17, 18, 19.
7. The implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports;
The National Disability Insurance Scheme Act 2013, Part 2—Objects and principles; 4 General principles
guiding actions under this Act (below) will not be met due to the generic assessment process impeding
the gathering of adequate information and evidence to determine reasonable and necessary supports
for people with a disability. The IA process does not allow people with a disability their equal rights to be
able to determine their best interests, to exercise choice and control and to be equal partners in
decisions as they will not be given the opportunity to fully communicate and demonstrate their needs
using a narrow and singular focused assessment process.
(8) People with disability have the same right as other members of Australian society to be able to determine
their own best interests, including the right to exercise choice and control, and to engage as equal partners in
decisions that will affect their lives, to the full extent of their capacity.
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(11) Reasonable and necessary supports for people with disability should:
(a) support people with disability to pursue their goals and maximise their independence; and
(b) support people with disability to live independently and to be included in the community as
fully participating citizens; and
(c) develop and support the capacity of people with disability to undertake activities that enable
them to participate in the community and in employment.
‘Australians with disability have a right to best-practice assessment of their individual needs. Alternatives
to these hastily-construed IA’s, that use assessment tools validated for ALL disability groups, and are
aligned with internationally-recognised, evidence-based, contemporary practice, have not been explored
or analysed for cost-benefits. Alternative approaches could ensure equity and honor principles such as
choice and control; trauma-informed care; inclusion of existing support providers; and participant co-
design.’ (Written by Muriel Cummins, AHPRA-registered Mental Health Occupational Therapist)
Furthermore, The National Disability Insurance Scheme Act 2013, Part 2—Objects and principles; 4
General principles guiding actions under this Act (below) will not be honored through the IA process,
placing people with disabilities at further disadvantage, discrimination and risk of harm.
(12) The role of families, carers and other significant persons in the lives of people with disability is to be
acknowledged and respected.
(13) The role of advocacy in representing the interests of people with disability is to be acknowledged
and respected, recognising that advocacy supports people with disability by:
(a) promoting their independence and social and economic participation; and
(b) promoting choice and control in the pursuit of their goals and the planning and delivery of
their supports; and
(c) maximising independent lifestyles of people with disability and their full inclusion in the
community.
NDIS IA’s will not meet The National Disability Insurance Scheme Act 2013, Part 2— Participants’ plans;
Division 1—Principles relating to plans, 31 Principles relating to plans (below) as the process is narrow,
not fit for purpose, nonholistic , undervalues the person, lacks competency and is restricted. As a result,
people with a disability will not receive the funding they require to achieve social and economic
participation, exercise choice and control in the pursuit of their goals and the planning and delivery of
their supports or promote the provision of high quality and innovative supports that enable people with
disability to maximise independent lifestyles and full inclusion in the mainstream community.
The preparation, review and replacement of a participant’s plan, and the management of the
funding for supports under a participant’s plan, should so far as reasonably practicable:
(a) be individualised; and
(b) be directed by the participant; and
(c) where relevant, consider and respect the role of family, carers and other persons who are
significant in the life of the participant; and
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(d) where possible, strengthen and build capacity of families and carers to support participants
who are children; and
(da) if the participant and the participant’s carers agree—strengthen and build the capacity of
families and carers to support the participant in adult life; and
(e) consider the availability to the participant of informal support and other support services
generally available to any person in the community;
(f) support communities to respond to the individual goals and needs of participants; and
(g) be underpinned by the right of the participant to exercise control over his or her own life; and
(h) advance the inclusion and participation in the community of the participant with the aim of
achieving his or her individual aspirations; and
(i) maximise the choice and independence of the participant; and
(j) facilitate tailored and flexible responses to the individual goals and needs of the participant;
and
(k) provide the context for the provision of disability services to the participant and, where
appropriate, coordinate the delivery of disability services where there is more than one
disability service provider.
8. The circumstances in which a person may not be required to complete an independent assessment
An independent assessment would only be appropriate to complete for people who do not have
complex needs in addition to family/carers who have the capacity to understand the process and
support the person throughout the assessment process. This would be limited to a very small cohort of
people and exclude, but not limited to, people with cognitive impairment, neurological conditions, spinal
cord injury, brain injury, psychosocial impairment, complex behaviours, communication impairment,
people who are homeless or at risk of homelessness, people who are in contact with the justice system,
people who have experienced trauma, people in contact with state family service departments, children
in out of home care, children at risk of school suspensions.
Independent assessments would be a useful tool paid for by NDIS to enable equitable access to the
NDIS Scheme, however the process of an IA should be comprehensive, not dependent solely on
standardized assessments selected by the NDIS, and follow the assessment process as outlined by The
World Federation of Occupational Therapists (WFOT), https://wfot.org/about/about-occupational-therapy
‘OTA believes a risk assessment should be conducted before requiring any applicant to undertake an
independent assessment. In particular, people with trauma, PTSD, schizophrenia and Level 3 ASD may be at
risk of adverse outcomes from participating. Clients who might be exempted include those with psychosocial
disability, ASD, communication disorders, traumatic brain injury, acquired brain injury or cognitive
impairment; those experiencing homelessness; and those with severe pain or fatigue which precludes them
from engaging in discussion for more than approximately 20 minutes, such as those with Lyme Disease,
Chronic Fatigue Syndrome or migraines.’ (National Disability Insurance Agency Consultation Paper: Access
and Eligibility Policy with independent assessments, Occupational Therapy Australia submission,
February 2021; Appendix 1: OTA Response to Consultation Questions, 8. What are the limited
circumstances which may lead to a person not needing to complete an independent assessment? (p14)
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9. Opportunities to review or challenge the outcomes of independent assessments
Opportunities to review or challenge the outcomes of independent assessments appears to be limited in
the literature from NDIS in regards to IA’s. The National Disability Insurance Scheme, Consultation paper:
Access and Eligibility Policy with independent assessments, November 2020, Version 1.0, p23, states
‘Independent assessment results themselves will not be directly reviewable by the AAT.’ By eliminating the
process of review of outcomes of IA’s, people with a disability will face discrimination and a violation of
their rights as stated in the UN Convention of the Rights of Persons with Disabilities;
Article 5 – Equality and non-discrimination
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-5-equality-and-non-discrimination.html
Article 17 – Protecting the integrity of the person
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-17-protecting-the-integrity-of-the-person.html
Article 15 – Freedom from torture or cruel, inhuman or degrading treatment or punishment
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-15-freedom-from-torture-or-cruel-inhuman-or-degrading-treatment-or-
punishment.html
Article 16 – Freedom from exploitation, violence and abuse
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-16-freedom-from-exploitation-violence-and-abuse.html
10. 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
I have a 28 year career working as an Occupational Therapist in rural and remote communities in NSW
with Aboriginal and Torres Strait Islander (ATSI) people. From my personal experience, it takes many
years to build a trusting relationship in rural and remote communities and within ATSI communities.
Aboriginal and Torres Strait Islander Communities (ATSI)
ATSI communities require culturally responsive service delivery which is provided by organisations and
health professionals who understand the diverse culture within the communities we work in, and have
established trusted relationships.
The Aboriginal Health Impact Statement, NSW Health; 2017 outlines the Burden of ill health among
Aboriginal people and states, ‘Due to the higher prevalence of disease among Aboriginal people, they are
18 of 26
expected to utilise health services at a much higher rate than non-Aboriginal people. However, data suggests
that Aboriginal people’s overall utilisation of health services is only marginally higher. Barriers to accessing
health care contribute to the poor health status of Aboriginal people. They include discrimination, lack of
cultural safety, distance from home and out of pocket health care costs.’ (p7)
Closing the Gap in Partnership, National Agreement on Closing The Gap, July 2020, is an agreement
between the Coalition of Aboriginal and Torres Strait Islander Peak Organisations, and all Australian
Governments, with the objective ‘to overcome the entrenched inequality faced by too many Aboriginal and
Torres Strait Islander people so that their life outcomes are equal to all Australians.’ (p4) The agreement
approach is to work in partnership with ATSI communities, listen to them and change the way we work
with them in response to what they have to say. The agreement promotes and prioritises ATSI cultures
and people to improve the life and health outcomes for ATSI people.
The NDIS Aboriginal and Torres Strait Islander Engagement Strategy, 2017, commits to engagement with
ATSI communities with a community by community approach in a way which supports involvement. ‘Our
statement of commitment to Aboriginal and Torres Strait Islander peoples is also demonstrated through our
Reconciliation Action Plan (RAP). The RAP identifies the ways we will work to progress the NDIA’s vision for
reconciliation by building respectful relationships and creating opportunities for Aboriginal and Torres Strait
Island people.’ (p6)
The key principles of the NDIS Aboriginal and Torres Strait Islander Engagement Strategy, 2017 are
stated as follows:
‘The NDIA’s commitment is underpinned by the following principles (p8):
-
Centrality of Country, Culture and Community – Aboriginal and Torres Strait Islander peoples with
disability and their representatives have emphasised that Country, Culture and Community should be
central to any policy that affects Aboriginal and Torres Strait Islander peoples with disability.
-
Human rights – Aboriginal and Torres Strait Islander peoples and people with disability should be
afforded the same rights as other Australians. This includes those rights that Australia has assented to
as signatory to the United Nations Declaration on the Rights of Indigenous Peoples and the United
Nations Convention on the Rights of Persons with Disabilities.
-
Inclusion in mainstream services is as important as specialist disability services – the NDIS will provide
an opportunity for specialist providers to cater to the individual specialist support needs of Aboriginal
and Torres Strait Islander peoples with disability, while also providing an opportunity to improve the
access of Aboriginal and Torres Strait Islander peoples with disability to disability service providers and
to promote service provision that is culturally appropriate for Aboriginal and Torres Strait Islander
people within both the disability sector and other service systems.
-
Universal consideration of disability – the impact of disability should be addressed as a matter of
course within policy deliberations and governance for all policies affecting Aboriginal and Torres Strait
Islander peoples.
-
Meaningful engagement with Aboriginal and Torres Strait Islander peoples with disability – the views of
Aboriginal and Torres Strait Islander peoples with disability are central to the design, delivery and
evaluation of policies and services which affect them. There must be respect for the cultural knowledge
that exists in Aboriginal and Torres Strait Islander peoples with lived experience of disability. The
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involvement of Elders and representative organisations is necessary for strengthening trust in
government efforts.
-
Improving the evidence base on Aboriginal and Torres Strait Islander peoples with disability –
Improvements in data collection are needed with respect to Aboriginal and Torres Strait Islander
peoples with disability across a range of portfolio areas, to help build the NDIA’s capacity to track and
measure outcomes. Greater effort must be made for research to be community-driven (i.e. reflecting
the interests of those with lived experience of disability and community members), with Aboriginal and
Torres Strait Islander organisations having a custodial role in assuring the cultural security of research
and outcomes on behalf of communities. The NDIA is committed to working with Commonwealth,
State and Territory governments to leverage existing capabilities and resources, including data,
wherever possible to contribute to this growing evidence base.’
IA’s will not be culturally responsive and will not be conducted in a way which supports the NDIS
Aboriginal and Torres Strait Islander Engagement Strategy, the Closing the Gap in Partnership, the
United Nations Declaration on the Rights of Indigenous Peoples and the United Nations Convention on
the Rights of Persons with Disabilities. ATSI communities will be further disadvantaged and face cultural
discrimination as a result of IA’s.
Culturally and Linguistically Diverse Backgrounds (CALD)
The Federation of Ethnic Communities’ Councils of Australia (FECCA), states in the Mental Health and
Australia’s Culturally and Linguistically Diverse Communities, A Submission to the Senate Standing
Committee on Community Affairs, July 2011, ‘By failing to address and support the mental health needs of
both established and new migrant and refugee peoples and communities, the current health system
perpetuates rather than ameliorates the social exclusion and isolation, homelessness, low employment levels,
and poorer health experienced by many CALD Australians.’ (p3)
‘Culturally competent service providers and practitioners are those who:
-
are generally interested in and respect cultural diversity;
-
continuously strive to effectively work within the cultural context of an individual, family or
community;
-
are aware of how the cultural norms of the CALD group differ from their own; and
-
feel confident and efficacious to address the issues of their CALD clients, even if they are unfamiliar
with the CALD group.’
(Enhancing family and relationship service accessibility and delivery to culturally and linguistically diverse
families in Australia; AFRC Issues No. 3 – June 2008).
The following is a summary of recommendations for prioritising strategies for improving the CALD
capacity of a service outlet (Enhancing family and relationship service accessibility and delivery to
culturally and linguistically diverse families in Australia; AFRC Issues No. 3 – June 2008),
-
Improve the overall quality of the service
-
Implement equal employment opportunity and multicultural policies to increase recruitment of
CALD staff
-
Collect data on factors that measure or assess culture
20 of 26
-
Market and promote services to increase awareness of them, and their perceived relevance, to
CALD and ethnic minority families
-
Service providers and practitioners in the outlet should receive training in cultural competency
-
Consider practical issues, such as the physical locality of the service, the layout of the rooms,
opening times, staff profile and links between different services
-
Partner with other CALD-focused centres or organisations in the local community
The National Disability Insurance Agency Cultural and Linguistic Diversity Strategy 2018 has the vision of
‘people with disability from Culturally and Linguistically Diverse backgrounds participate socially and
economically in their communities and experience wellbeing on an equal basis with others in our community.’
(p6)
‘At the core of this Strategy is the recognition all people have a right to equal access to services irrespective of
their cultural background or language. The Strategy acknowledges that historical inequities continue to impact
on how people exercise these rights.’ (p11)
The NDIS CALD Diversity Strategy key principals include:
- Human rights
- Culture and community are central
- Inclusion in mainstream services
- Universal consideration of disability
- Dignity of risk
- Meaningful engagement
- Improving the evidence base
The NDIS CALD Diversity Strategy five Priority Areas are:
-
Engage with communities
-
Make information about the NDIS accessible
-
Increase community capacity and broaden consumer choice
-
Improve our approach to monitoring and evaluation
-
Enhance cultural competency within the NDIA and its Partners in the Community.
The key principals and priority areas will not be met with IA’s due to the blanket approach to conducting
the assessment process which is not culturally respectful, does not acknowledge the importance of
culture and community being central and community engagement being critical, and does not honor the
human rights of the CALD population with a disability.
CALD communities are at serious risk of further disadvantage, discrimination and risk of harm.
The implementation of IA’s for ATSI, CALD and rural and remote communities people with a disability will
face discrimination and a violation of their rights as stated in the UN Convention of the Rights of Persons
with Disabilities;
Article 5 – Equality and non-discrimination
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-5-equality-and-non-discrimination.html
21 of 26
Article 17 – Protecting the integrity of the person
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-17-protecting-the-integrity-of-the-person.html
Article 14 – Liberty and security of person
https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-
disabilities/article-14-liberty-and-security-of-person.html
Rural and remote communities
In my personal experience, people who live in rural and remote communities are less likely to share
personal information with people who they do not trust, are less likely to ask for help due to the culture
of ‘making do’ and the understanding that services are not readily available, and are less likely to accept
assistance unless they trust the providers.
‘As expected, people living in major cities are less likely to have problems accessing a range of services
than those living in other areas. Those in outer regional or remote areas are the most likely to have
difficulties accessing services. This is true irrespective of family type. (The Australian Institute of Family
Studies; Research summary – March 2011; Jennifer Baxter, Alan Hayes, Matthew Gray; p4). The research
study concludes, ‘There are also differences in children’s developmental outcomes across geographic
areas, with children in major cities doing better for physical development and learning outcomes than
children in other areas. While there are many similarities in the nature of families and their lives across
areas of varying remoteness, overall distance still exercises some “tyrannous” influences on the lives of
Australians and their families.’ (The Australian Institute of Family Studies; Research summary – March
2011; Jennifer Baxter, Alan Hayes, Matthew Gray; p7).
IA’s will not be delivered by health professionals within rural and remote communities with established
working relationships within those communities. Multinational companies with unknown employees will
complete the assessments, which may occur via telephone due to location and distances, and very
personal questions will be asked. People in rural and remote communities will be highly likely not to
participate in the IA process due to the disadvantage of the process.
The National Disability Insurance Agency Rural and Remote Strategy 2016–2019, February 2016, states
the following goals (p3):
- ‘Easy access and contact with the NDIA
- Effective, appropriate supports available wherever people live
- Creative approaches for individuals within their communities
- Harnessing collaborative partnerships to achieve results
- Support and strengthen local capacity of rural and remote communities’
The National Disability Insurance Agency Rural and Remote Strategy acknowledges that people with
disability and their families and carers who live in rural and remote communities are challenged by
(p11):
22 of 26
- ‘limited service choice and availability;
- the need for travel and transportation;
- difficulties with recruiting, training and retaining professionals;
- issues relating to service/support quality; and
- lack of alternative accommodation options’
11. The appropriateness of independent assessments for people with particular disability types, including psychosocial disability;
It is extremely important to recognise and acknowledge the requirement for health professionals to
have expertise in the disabilities they are assessing to ensure they have an understanding the
presentation, complexities, prognosis and risks of varying diagnoses and disabilities when completing
assessments. Disabilities are complex and the people living with their disabilities deserve this to be
recognized and the impact on their lives to be validated. IA’s will not serve this purpose. IA’s will not be
appropriate for people who have disabilities which include, but not limited to, cognitive impairment,
neurological conditions, spinal cord injury, brain injury, psychosocial impairment, complex behaviours,
communication impairment.
It is also critical to acknowledge the lack of insight some people have into their disability, such as
psychosocial impairment and ASD, and the subsequent overstating of their capacity. The person’s actual
functional capacity cannot be determined by completing one standardised assessment which may not
be validated for the disabilities they are assessing. This has been identified by OT Australia in the
National Disability Insurance Agency Consultation Paper: Access and Eligibility Policy with independent
assessments, Occupational Therapy Australia submission; February 2020, Appendix 3 – Appraisal of the
proposed IA toolkit, p17, 18, 19.
12. Any other related matters
Conclusion
SACAL would like to take the opportunity to thank the panel for carrying out the inquiry and for the
opportunity to submit a response and express our concerns in regards to the implementation of NDIS
independent assessments.
We would also like to reiterate our ongoing concerns regarding:
-
The development of the IA process without consultation with professional bodies and the lack of
understanding of the process of completing functional capacity assessments and professional
scope of practice
-
The introduction of IA’s without consideration of previous and existing similar policies in other
jurisdictions and in the provision of other government services
23 of 26
-
The lack of culturally appropriate and person centered assessment pathway
-
The lack of a clear review of decision pathway and complaints pathway
-
The impact on the human rights of the person with a disability and the potential to cause harm
-
Disregard for the following legislative, NDIS and global documents and agreements
- Objects and Principals of the National Disability Insurance Scheme Act 2013
- NDIS Aboriginal and Torres Strait Islander Engagement Strategy, 2017
- National Disability Insurance Agency Cultural and Linguistic Diversity Strategy 2018
- National Disability Insurance Agency Rural and Remote Strategy 2016–2019, February 2016
- Closing the Gap in Partnership, National Agreement on Closing The Gap, July 2020
- UN Convention of the Rights of Persons with Disabilities
-
The conflict of interest of independent assessment panel providers
-
The unethical implementation of the IA pilots
-
Ongoing workforce issues and quality of service delivery
Suggested Recommendations
-
A National Competency framework for each health profession developed in consultation with
professional bodies and AHPRA
-
Clear definition, process and guidelines need to be developed around functional capacity
assessments in consultation with professional bodies
-
The implementation of an NDIS Ethics framework
-
An NDIS workforce development strategy in consultation with professional bodies
-
OTA recommendations attached - National Disability Insurance Agency Consultation Paper:
Access and Eligibility Policy with independent assessments, Occupational Therapy Australia
submission, February 2021
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nal,%20rural%20and%20remote%20australia.pdf. Download 29.03.2021
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The National Disability Insurance Agency Rural and Remote Strategy 2016–2019, February 2016
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