Submission
Date: 31 March 2021
Dear Committee Members,
Ask that my name is withheld in publishing this submission. All information contained in the submission on the following pages can be published.
If you would like further information or clarity, please feel free to contact me.
Kind regards,
Thank you for this opportunity to provide a submission on the proposed introduction of Independent Assessments under the NDIS.
I am a parent redacted: s47F - Personal privacy complex support needs and who is an NDIS participant and, I have worked for seven years as an NDIS support coordinator. I write today based on my experience of the NDIS as a parent /plan nominee and in my professional role. I am well aware of the problems within the NDIS, and aware, as well, of many terrific outcomes for people with disability.
in this submission i will address terms of reference a) and g).
a) The development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS
Submission 234
The proposed changes whereby a ‘personalised budget’ will be determined by the result of an independent assessment is radical. This change dermines key principles of the NDIS. Much damage will be done to people with disability and the scheme if the proposed changes are not halted immediately.
The simple idea of an objective measure might sound great in theory. But ipple are not objects!
it will be impossible for an independent assessor to understand the nuances and complexities of a person’s individual situation, and how this intersects ith their impairments, within such a short period. Indeed, even highly skilled practitioners can take years of knowing a person to fully appreciate how their functional capacity interacts with their environment and living situation.
Furthermore, there is an adage from the disability rights movement: “nothing about us, without us”. The proposed independent assessments fail this. There has been limited consultation on independent assessments and there is ostrong and vocal opposition across the sector and, importantly, from people with disability themselves. For this reason alone, independent assessments should not go ahead. Future changes to the NDIS should be with a transparent consultation and codesign with people with disability, families, aud allies.
NDIS is a complex system
The government has cited inconsistency in funding as the reason for inintroducing Independent Assessments. There is no doubt, there is inconsistency in the plans and funding people with disability receive.
The NDIS is exceptionally complex; it comes with its own language, and I say, it is unnecessarily confusing.
Submission 234
We have created a scheme for the savvy. Little wonder there is such inconsistency in funding budgets.
If you can understand the language of the NDIS, know the words to use and, mportantly, the words not to use, you will have a better funding outcome. (for example never say “treatment”, you say “therapy” if you are seeking funding to improve skills).
The disparity between higher and lower socioeconomic areas is due to many people being systematically disadvantaged by the unnecessary complexity of the scheme. This can be fixed now. The NDIA should simplify the language, provide easy read information, and proactively supports to help people navigate the scheme.
Independent Assessments won’t address this disparity. Three hour assessments where someone needs to convey their life circumstances as well as functional capacity result in further entrenched inequality rather than alleviate it.
Plan flexibility
The NDIA has promised simpler schemes with greater plan flexibility. However, that too could happen immediately. A simplified scheme and increased plan flexibility don’t depend on Independent Assessments; they aren’t linked. There’s good reason to doubt the sincerity of any promise regarding plan flexibility.
During COVID, the NDIA allowed participants access ‘core’ funds for ‘support coordination’. It worked well for those who either lacked sufficient support coordination or had no prior experience.
Submission 234
coordination. Recognising the benefit, the NDIA initially announced in October 2020, that Support Coordination could continue to be funded from core ongoing. However, in February, with little notice, this flexibility was revoked. No reason. Just was. No one was asking for more money. People with disability were just using their funds flexibly. But, seemingly on a whim, this flexibility is taken away.
People with disability and families do not have faith that the promise of plan flexibility will be kept.
g) The implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessarysupports.
The NDIA seem to let their slip show in the recent NDIS quarterly report (Year8, Quarterly 1.) including a line that Independent Assessments are a cost saving measure.
Convenient ways to provide less funding in NDIS plans is to: · Push back onto mainstream, community and informal supports · Fund people at shared support rates
Mainstream, community and informal supports
Recent published information from the NDIA and government has had a renewed emphasis on mainstream and community supports. This is okay so long as those supports actually exist and are available to people with disability. However, as a support coordinator we frequently see participants being pushed back by the NDIA onto, literally, non-existent mainstream/community support.
Independent Assessments
Submission 234
Support coordinators are regularly supporting people with complex needs caught in the ‘argy bargy’ of the NDIS interface with mainstream services.
Before more radical changes occur, there needs to be real commitment from State and Federal governments to work together to ensure that people - real people - are not caught in gaps.
Shared Supports
to date there is no information, that I am aware of, which discusses shared
s \\upport. Yet the so called ‘economies of scale’ significantly reduce the cost
\\of support and this is a dominant funding model with the NDIS.
The outcomes when people with disability are forced to share support,
forced to live with people not of their choosing, are frequently very poor. For
more information you can read the Disability Royal Commission’s Public Hearings reports.
i am very concerned that people who want and need individual support will
b e funded at rates for shared support. We already see funding for individual
s upport refused, in situations where it is clearly required. People who want to
l ive on their own, or because of their disability and /or struggle sharing with others are forced to live with others because they do not have enough funding for alternatives.
Everyday living costs
d espite the promises of greater flexibility in how a participant chooses to use
t heir NDIS funding, there has been consistent talk from the Government
Independent Assessments
Submission 234
The use of NDIS funds on non-disability specifics supports is poorly understood within the NDIA and in the community.
Howerver, there is great ingenuity that comes when people with disability have freedom in how they choose to meet their disability support needs.
For Example
e Participant with physical disability purchasing ‘Google Home’ to independently access environmental control e Participant with intellectual disability going to the barber weekly for a shave instead of a support worker or mum shaving them. e Participant with communication impairment purchasing an iPad to use as a communication device.
these Purchases might at first glance look like everyday expenses but they are nonetheless meeting a support need and at lower cost than alternatives.
W hen considering everyday expenses we need to ask the question “every day for who?”
I f participants are restricted to disability specific purchases the scheme will cost more; it will stifle innovation and the outcomes for people with disability will be poorer.