NDIA Accountability Project

Impact of Independent Assessments on Allied Health Services

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

I work as part of a passionate team of allied health care providers providing services to NDIS participants. I wish to express our serious concern with the changes being proposed to Independent Assessments carried out for participants of the NDIS.

The NDIS aims to support people with disability to participate in and live an ordinary life. I believe the proposed independent assessments undermines this objective and I believe will significantly impact the outcomes and quality of life for participants with a disability.

Below is an outline of my concerns with these changes:

  • The reason for proposing the independent assessments undermines the fundamental principles of the NDIS. Every individual with a disability and the challenges they face on a daily basis is unique. No two participants are the same and participants with the same or similar disabilities can have vastly different needs and a very different disability experience which needs to be considered on an individual basis. The idea of implementing one dimensional assessment set to all people with a disability, doesn’t cater for the uniqueness of people in general as well as people with a disability. Participants are likely to feel less valued and respected with this approach.

  • There has been public discussion commenting on the deployment of human and financial resources via multi-million-dollar contracts to companies providing these assessments is an inappropriate use of taxpayer’s dollars and the process lacked appropriate governance. Allied health professionals already providing services to participants are better positioned to provide recommendations to NDIS that inform developing individualised plans and funding allocation for the following reasons:

    • Allied health professionals providing services to participants have insight into participants individual disability experience, by getting to know the participant at all levels over multiple interactions, using standardised assessments appropriate to their disability and situation, and using highly valued clinical observation and judgement.
    • Allied health professionals providing services to participants have been university trained to perform the duties NDIS are needing and are currently doing this for the NDIS.
    • Allied health professionals providing services to participants are AHRPA registered and abide by the code of conduct under each profession. Respect and consideration need to be given to the allied health professionals providing services to participants, that we are truthful, ethical and competent to provide recommendations to NDIS that inform funding decisions.
    • Allied health professionals providing services to participants know participants capacity and day to day difficulties that cannot be gained through one set of standardised assessments.
    • The existing process is a far more efficient use of time and funding as assessments and reports take less time to complete, when much of the

Concerns Over Assessment Tools

  • Concerns over the set of assessments intended to be used for the independent assessments for the following reasons:

    • Disabilities are varied and as such a small set of assessment tools cannot be used for all populations as well as disability/conditions and then provide accurate results.

    • The assessment tools proposed as part of the independent assessments are screening tools, not providing defined results or outcomes that cannot be solely relied upon to make decisions.

    • The assessment tools proposed as part of the independent assessments are not measuring the construct that NDIS want it to, ie. Vineland is used for diagnosing and treatment planning and not the level of impact the disability has on capacity or allocation of funding.

    • Clinical observation and judgement by clinicians familiar with participants are the strongest tools that can be used to determine the impact of disability and a person’s capacity. Standardised assessments are used to support clinical judgement/reasoning.

    • The proposed assessment tools may be used inappropriately, either to populations that they have not been appropriately tested and researched for or by health professionals that do not meet criteria for implementing or interpreting results of the assessment tools

    • The proposed assessment tools may have been modified to suit this NDIS independent assessment process, compromising the standardisation, reliability and validity of the assessment tools, as well as compromising the ethics of allied health professionals forced to use these modified standardised assessments.

    • The population group you propose to use the assessments on frequently have lesser understanding, awareness, cognitive ability or insight to answer accurately. The results of the assessments on many people with a disability will not provide accurate results/outcomes to inform decision making. A person’s complexity will not be successfully captured by the assessment proposed. This can only be provided by clinical observation and judgement from qualified clinicians over multiple sessions, using assessment tools to support these findings.

    • There is no evidence supporting the assumption that functional capacity can be measured in a “disability neutral” manner. There is an absence of a single assessment or set of assessments that measure functional capacity that can be applied to all people with a disability.

    • The independent assessments further marginalises those people with a disability from diverse backgrounds, not considering those speaking a language other than English. These assessments are not translated into other languages with no intention of NDSI to do so. The use of interpreters to translate is not appropriate and compromises the reliability of the assessments. Assessments for people with disability from a non-English speaking background needs to be completed in a sensitive way and often best

  • Concerns over the implications for the allied health work force o Placing allied health professionals into situations they are not experienced or capable to manage. o Placing allied health professionals into situations where they will be frequently reported to AHPRA for completing assessments/providing a service that are deemed unethical and against the code of conduct for their profession. o Adding to further pressure on the lack of allied health professionals needed in the market to provide services to those with disability as well as people requiring allied health services across other sectors including aged, health, workplace, education etc.

  • Concerns for reducing choice and control of participants o Participants are being forced to undergo assessments that are inappropriate for them and their situation which could result in altered funding and thereby reducing their capacity to aim towards achieving their goals. o The opportunity for participants to express the uniqueness of their disability experience, them as a person and their life will be removed.

  • Concerns with the implications for the decisions made from these assessments o Results from a set of assessments, with no consideration to individual experiences of the person with a disability, has the potential to inappropriately reduce funding or remove participants from the scheme altogether. Disabilities can vary from day to day, week to week, month to month and season to season. Many disabilities are progressive and early planning is important. Many disabilities can have days where minimal impact is felt and other days where all aspects of life are significantly impacted. The decisions made from these assessments have the potential to not recognise the differences in disability experiences, changing nature of disability or progression of disabilities, denying funding that is essential for better outcomes in future. o Limited opportunity to contest or have a plan reviewed has been implemented, reducing further choice and control and individual input from people with a disability. o If the independent assessments do remove people with a disability off the NDIS unfairly, people with disability will fall through the gaps and the gains we have made as a country in upholding the rights of people with a disability will take a backwards step.

Recommendations:

1.  Immediately pause the implementation of independent assessments.
2.  Consult and engage people with a disability and health care professionals working in
    disability and health care to assist in designing programs and systems.

  • Accept evidence and/or recommendations provided by a treating health care professional who is already familiar with the needs and capacity of a person with a disability, to guide the decision-making process for funding allocation and supports required by the person with a disability to achieve their goals.

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