Independent Assessments Submission 237
Date: 31 March 2021
Joint Standing Committee on the National Disability Insurance Scheme – Inquiry in to Independent Assessments
I have been a carer for my husband for the last 25 years. He suffers from Bipolar disorder and chronic anxiety and has been unable to work since 2008 when he was only able to manage part-time work. He has been on the Disability pension for nearly 9 years and has had an NDIS package for 2 years.
I have travelled alongside him and supported him as he negotiated the NDIS processes. The services which he has been able to access are making a big difference to him and giving him hope. I do not believe that the proposed independent assessments with the tools listed will be able to adequately capture the extent of the impact his conditions have had on his life.
When he first applied for the NDIS, he was able to submit reports for his treating psychiatrist, who he had seen over many years and his psychologist. I am really worried that these reports are now not going to be part of the new independent assessment process which he will be required to undertake in the next year or so.
He was invited to participate in a pilot but due to his anxiety was not able to do so.
The implications of independent assessments for access to and eligibility for the NDIS;
According to the Consultation paper: Access and Eligibility Policy with independent assessments, the assessment will use tools which are questionnaire based.
I am concerned about the fact that the assessment is solely based on assessment tools. Given my experience and that of other carers that I know, the decision for continued NDIS access should not be based solely on the proposed independent assessment but should definitely include reports from current health professionals who have known the person for some time. This should include reports from his workers employed within his NDIS package as well.
Psychosocial disabilities can often be extremely complex but the independent assessment does not allow for this.
I do not understand how such an important decision can be made about a complex disability without such qualitative information.
The development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS;
Lack of consultation. I have been surprised at the speed of the implementation of this new process. The Selection of Assessment Tools was released Sept 2020 and the Consultation paper: Access and Eligibility Policy with independent assessments was only published in November 2020. The date for feedback to the NDIA was February 23rd which allows little time to understand the tools, consider the implications and
Independent Assessments
Submission 237
provide comprehensive feedback. Submission date for the Joint committee is end of March which is only 1 month later.
has the feedback to date been taken on board ? Given the media reports about tendering for independent Assessments, it would seem that the government is intent on proceeding with the proposed changes without taking the feedback it has received to date into account.
The independence, qualifications, training, expertise and quality assurance of assessors;
i do not have any confidence that independent assessors will have the appropriate skills or knowledge. Having a qualification is one thing but to have experience and knowledge of this complex area of disability is crucial. i heard of a case in the pilot, where someone with autism was assessed by a physiotherapist which seems totally inappropriate.
in addition to bipolar disorder, my husband suffers from debilitating and enduring anxiety his presentation is usually articulate, polite and well presented, but his life that has been crippled by anxiety to the extent that he can’t work, doesn’t have friends or any community participation. I am concerned that his presentation will be misleading to an assessor who lacks adequate experience and knowledge of this type of disability or my husband.
psychologists were listed as one health professional. Many psychologists do not have a significant depth or breadth of knowledge about mental illness.
the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding.
again, i question the adequacy of these assessments to determine the supports that someone such as my husband requires. Individual supports and services are central to the Person-Centered approach which underpins the intention and philosophy of the NDIS.
The Minister for the NDIS Stuart Robert recently claimed (March 2021) that the independent assessments were strongly recommended by the Productivity Commission when it built the scheme in 2011.
however former NDIA chief executive David Bowen qualified this, saying that
“the Productivity Commission recommended independent assessments as part of a range of assessment tools to measure a participant’s disabilities and support needs. This was never a one-size-fits-all model. This was about personalised plans, recognising the individual circumstances of people now they’re introducing an assessment where you see someone who has no knowledge of your history [and] no personal relationship with you.”
Opportunities to review or challenge the outcomes of independent assessments;
Review Process.
The documentation states that “The access decision remains a reviewable decision and the applicant can request an internal review and then appeal the decision at the Administrative Appeals Tribunal (AAT).” (Consultation paper: Access and Eligibility Policy with independent assessments, November 2020, p 23).
HHowever, the Consultation paper goes on to say that “Independent assessment results themselves will not be directly reviewable by the AAT” and “Disagreeing with the results of an otherwise sound and robust independent assessment is not sufficient for the NDIA to fund another assessment”. (p23) GGiven that the independent Assessment is based on the assessor’s interpretation and understanding of the respondent’s answers to the tool questionnaires, I seriously question the statement that it is ‘sound and robust’. And as such I cannot believe that the assessment outcome is not reviewable by the AAT. This seems a fundamental flaw with the proposed changes to the NDIS.
The appropriateness of independent assessments for people with particular disability types, including psychosocial disability
Severe mental illness can take away potential, reduce overall health and reduce life expectancy. This is certainly true in my husband’s case who has ongoing heart problems. A single assessment based around a questionnaire, by a person who only meets someone suffering from a complex mental illness is unlikely to capture the complete picture. This is why it is so important that in the case of psychosocial disability, reports from a person’s treating team form part of the assessment – both for access, continued access and funding of supports.
This submission has drawn information from the following: -
W HODAS 2.0 World health Organisation Disability Assessment Schedule, 36-item version Interviewer-administered
Improving the national Disability Insurance Scheme – DSS information paper (Nov 2020)
Consultation paper: Access and Eligibility Policy with independent assessments. November 2020. Version 1.0.
Using the WHODAS 2.0 to assess functional disability associated with mental disorders. Am J Psychiatry. 2014 Aug; 171(8): 818–820.