Joint Standing Committee NDIS - Independent Assessments submission March 2021
Marymead has been operating in the Canberra and surrounding NSW regions for over 50 years, delivering therapeutic and support services to meet the needs of children, young people and families in the community. Our organisation has a justifiable reputation for the delivery of high-quality services to support vulnerable children, young people and families.
The submission provided by Marymead is in response to reading the NDIS’ Consultation paper: Access and Eligibility Policy with independent assessments and further research of DSC publications. Comments have been made against the terms of reference.
The development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS; Marymead acknowledges the aim to reduce waiting t imes and the cost of health professionals for applicants/participants in gathering evidence about their ‘reduced functional capacity’, these costs and w ait times w ill still exist for diagnosis that is required to be eligible for the scheme. It is also key to note that many of the health professionals have known the participant over a longer period of time and are in a better position to understand the life impacts of their disability than an independent assessor, who typically has a short period of time to build rapport and trust to ascertain adequate information about a participant’s lived experience to determine their ‘functional capacity’. It is also noted that the language change to ‘functional capacity’ no longer appears to recognise an individual’s lived experience and strengths.
There is a great risk of a quick assessment becoming a deficits-based experience for the participant, w hich may impact their confidence, mental health and ability to engage in the assessment process and the scheme.
The human and financial resources needed to effectively implement independent assessments;
It is unclear who the ‘assessor organisations’ are and how participants are able to make a choice.
Marymead would value information in regards to the intended quality control mechanisms that w ill be in place to ensure some level of consistency across Australia. We note that the NOIA states that a quality framework is being developed, it would be hoped that such a mechanism would have been in place during the pilot stages.
marymead.org.au
CANBERRA GOULBURN WAGGA WAGGA MORUYA 255 GOYOER STREET 32 VERNER STREET 85- 87 FITZMAURICE STREET CORNER CAMPBELL ANO PAGE STREETS NARRABUNDAH ACT GOULBURN NSW WAGGA WAGGA. NSW MORUYA NSW PO BOX 4 260 KINGSTON ACT 2604 PO BOX 286 GOULBURN NSW 2580 PO BOX 699 WAGGA WAGGA NSW 2650 PO BOX 994 MORUYA NSW 2537 PHONE 02 6162 5800 PHONE 02 <48271600 PHONE 02 4827 1620 PHONE 0406 375 247
PHONE 0 2 6162 5800 > FA.X 02 6295 9944 > EMAIL enquiries@marymead.org.au MARYMEAD IS A CATUOLIC AGENCY Of TllEARCflDIOCCSE Of CANBERRA AND GOULSURN. ABN ’JO 6n ~,o 841
The independence, qualifications, training, expertise and quality assurance of assessors;
The assessment will be the same quality as the assessor making the assessment and their personal and professional attributes. From our experience, this has been reflected in participants’ experiences with NDIS planners.
The allied health professionals listed (occupational therapists, physiotherapists, psychologists) all have different trainings and professional approaches and frameworks that they would bring to independent assessments. There is currently a shortage of these professionals in the provision of therapy services for NDIS participants and there are concerns that the Independent Assessment scheme will further stress this labour market shortage, resulting in pinch points being moved to another point in the process.
There appears to be a lack of reference to Social Workers role within the Independent Assessments process. This is worth highlighting and further consideration due to the holistic approach to their training.
The appropriateness of the assessment tools selected for use in independent assessments to determine plan funding;
Assessment tools can be affected by a range of variables, particularly the skill and attributes of the assessor, the level of comfort the participant feels, the environment in which the assessment occurs, the presence or absence of support people and advocates. It is questionable whether an assessment completed under ‘test conditions’ has any direct relationship to the participant’s ability to initiate or complete similar tasks in real life.
The implications of independent assessments for access to and eligibility for the NDIS;
There is a risk that NDIS plans and budgets become disability-based, rather than based on lived experience and individual aspirations. There is the risk that the scheme becomes deficits based rather than strengths-based.
The circumstances in which a person may not be required to complete an independent assessment;
If the delegate’s decision not to grant an exception for an Independent Assessment is not a reviewable decision, this could lead to a lack of transparency and options in the Independent Assessment scheme.
Opportunities to review or challenge the outcomes of independent assessments;
It is of concern if Independent Assessment results themselves will not be directly reviewable by the AAT and if the delegates request that an applicant has an independent assessment for the purposes of informing an access decision under the NDIS Act’. This will be beyond many people to pursue and could lead to a two-tier system, where those who are able to pursue and / or have advocates receive something different to those who may not.
marymead.org.au
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Marymead would appreciate clarity on how ‘soundness’ and ‘robustness’ of an Independent assessment is determined and would question where choice and control in a participant’s ability to challenge a decision about their life is factored.
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;
Marymead would appreciate additional information on consultation with the communities named above.
The appropriateness of independent assessments for people with particular disability types, including psychosocial disability;
Marymead would like to suggest that further consideration is given to those with complex disabilities, especially those who are non-verbal and / or unable to express themselves through assistive technology; families with multi-generational disability, isolated individuals and those without advocates or support networks.
| Name | Ruth Jalloh |
|---|---|
| Phone Number | redacted |
| Postal address | 255 Goyder Street, Narrabundah, ACT, 2604 |
Submission sent to ndis.sen@aph.gov.au on 31/03/2021
marymead.org.au
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