NDIA Accountability Project

Partner's disabilities and concerns about generalist assessors

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Submission to the Joint Standing Committee on the National Disability Insurance Scheme

30th March 2021

I write in relation to the Terms of Reference highlighted below

e. the development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS; b. the impact of similar policies in other jurisdictions and in the provision of other government services; c. the human and financial resources needed to effectively implement independent assessments; d. the independence, qualifications, training, expertise and quality assurance of assessors; e. 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; g. the implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports; h. the circumstances in which a person may not be required to complete an independent assessment; i. opportunities to review or challenge the outcomes of independent assessments; j. 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; k. the appropriateness of independent assessments for people with particular disability types, including psychosocial disability; and l. any other related matters

My partner is an NDIS participant. I have supported:

  • her original access application;
  • a request for more information which was in essence resubmit the same information in a different format;
  • a second request for more information where the NDIA member of staff agreed that this was a further request to resubmit the same information in a second different format;
  • her appeal when deemed ineligible;
  • her appeal when her supports manifestly failed to meet her needs;
  • the planning meeting for her revised, more adequate Plan;
  • her Plan review;
  • her appeal against her new Plan which significantly reduced her supports, and included numerous errors of fact which demonstrate that the NDIA had not read supporting evidence;
  • her request to have simple factual errors corrected so that she would not lose access to key parts of her supports;
  • her complaint to the NDIS CEO,

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I agree that the NDI$ is in serious need of streamlining. I suggest the Committee consider:

  • removing the unnecessary layer of the LAC;
  • external review of the manifestly over-engineered processes and systems upon which NDIA decision-making relies;
  • removing the requirement to reconfirm disability functional impacts where a GP attests that the impact is unchanged;
  • requiring NDIA officers to give their full names and direct phone lines to participants, to streamline contact - and recognise participants’ humanity and dignity.

Independent Assessment are NOT the way to do this.

My partner has a number of different disabilities, some of which are rare. After a long, expensive and arduous process, she is now under the care of a clinical team with knowledge and expertise in those conditions. No generalist assessor can replace the expertise of this team, and it is insulting and disrespectful to the professions and to people with disability to suggest that they can.

a. the development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS;

If there are reasons and justifications for a 360-degree reversal of the previous NDIS position that evidence of the impact on disability on functioning should come from a clinician with experience and qualifications in the specific disability, I have not seen it, and no one in my network has seen it.

I have not seen modelling of the impact of the introduction of IAs, but have seen a number of leaks from NDI$ staff which suggest that the aim is to cut costs. I would expect modelling to demonstrate clear increases in choice and control, and in streamlined process, for a reform of this nature to be justified.

I urge the Committee to halt the introduction of independent assessments until such justification and modelling is shared with all current NDIA participants.

D. the independence, qualifications, training, expertise and quality assurance of assessors;

Disability is not homogenous. Generalist assessors cannot replace the qualifications, training and expertise of the vast range of clinicians across the field of physical, intellectual and psychosocial disability.

Assessors and Assessment Agencies will depend for their continued financial survival on their performance being acceptable to Government. This is not independence. It does not compare, or even come close to, the clinical independence of medical and allied health personal.

If this scheme proceeds, as a minimum for probity quality assurance should be conducted by agencies or academics entirely independent of the assessment agencies and of government.

f. the implications of independent assessments for access to and eligibility for the NDIS;

In one word - Grave.

Generalist assessors do not have the knowledge base or clinical expertise to adequately assess eligibility based on the functioning impacts of the huge range of very different disabilities experienced by potential NDIS applicants.

As noted above, the current planning and decision-making practice of the NDIA is labyrinthine, trauma-inducing, duplicatory and obscurantist. My partner has had NDIA assessors make directly contradictory decisions on whether exactly the same support is or is not reasonable or necessary. Decision-making guides and analyses are not easily accessed, and my experience is that NDIA staff are the reverse of open and transparent about their process.

Independent Assessments will contribute information which is clinically inadequate into this existing dysfunctional system.

They are not the answer.

h. The circumstances in which a person may not be required to complete an independent assessment;

If the scheme proceeds, it is imperative for fairness and natural justice that it does not apply to current NDIS participants, who have already expended significant time and effort in submitting clinically specific evidence in support of their applications and reviews.

Unless there is a significant change in disability, current participants’ GPs should be able to attest that the impact on functioning remains unchanged.

If there is a significant change, the relevant clinical expert should submit evidence.

i. Opportunities to review or challenge the outcomes of independent assessments;

If the scheme proceeds, it is imperitive [sic] for fairness and natural justice that all participants are offered the opportunity to submit clinically relevant evidence to review or challenge outcomes of independent assessments. Where the relevant clinical expert does not agree with the conclusions of a generalist assessor, their view should prevail,

This is critical for fairness, but underlines the faulty premise at the heart of the Independent assessment process – that one size fits all.

I am gravely concerned at reports in the media that independent assessment contracts are promised to large non-specialist firms with strong links to the current Government.

I urge the Committee to investigate.