Evelyn Bugel BA (Psych), Grad Dip (Psych) Adv Dip (Gestalt Therapy) Post Grad Dip (Spec Ed) Psychologist and Counsellor for Carers

April 8, 2021

        SUBMISSION TO THE JOINT STANDING COMMITTEE
     ON THE NATIONAL DISABILITY INSURANCE SCHEME’S
           INQUIRY INTO INDEPENDENT ASSESSMENTS

This submission is made by Evelyn Bugel, psychologist. Evelyn Bugel has had general registration for 14 years with the Australian Health Practitioner Registration Agency. Evelyn has specific interest and expertise in working with carers of people with disabilities. Evelyn Bugel has also delivered services to individuals with National Disability Insurance Scheme packages. Prior becoming registered as a Psychologist, Evelyn worked in the disability sector for 20 years.

This submission comments on issues in relation to terms of references 4 and 5 of the inquiry, relevant to my area of practice.

I am concerned that the introduction of Independent Assessments (IAs) will be damaging to NDIS participants and the consultation process on this policy is not consistent with the core principles of the scheme, including co-design and choice and control. The argument made in favour of IAs is that these assessments will lead to consistency and increase, that it will be more focussed on function, rather than medical diagnosis, and make the Scheme sustainability. I do not believe that IaS will lead to these outcomes, rather, that the it compromise outcomes for people with disabilities and undermine and replace the skilled assessments currently being undertaken by professionals in the sector

In this submission, I strongly argue for a stop to the implementation of IaSs.

I call for the implementation of any future functional assessments and evaluation of their role in the NDIS to include and involve with people with disability and other stakeholders with expertise in the area, including academics and allied health professionals.

I call for rigorous evaluation of functional assessments against their purpose of allocation of budgets for reasonable and necessary supports that meet participants’ goals

I call for an assurance that the NDIA will not use functional assessments as the sole (or main) basis of funding decisions. Reasonable and necessary supports need to be judged against participant goals.

Terms of Reference # 4:

The independence, qualifications, training, expertise and quality assurance of assessors.

The NDIA propose to use allied health professionals to make the IAs, without a requirement that the allied health professional be trained in the area in which the assessment is focussed. So, a physiotherapist may use tools typically used by a psychologist or speech therapist to assess functioning of someone with Autism Spectrum Disorder. Many of the measurement tools that may be used by the assessors are for clinicians who have had specialist training in the use of these psychometric and other tests. The families who have participated in the piloting of these assessments have already indicated how underqualified many assessors were and how information they and the person with the disability volunteered was dismissed. In the IAs proposed, there are not to be safeguards in place for underqualified, unskilled assessors and the difficulties they may have acting outside of their area of training. Furthermore, without an appeals process, there will be no recourse if an assessor makes an inappropriate or incorrect assessment of a participant’s effectiveness.

Terms of Reference # 5:

The appropriateness of the assessment tools selected

for use in independent assessments to determine plan funding

I am concerned about the selection of the tools for the IAs, in particular that the tools chosen will not be used for their intended purpose. The tests, if not used for their intended purpose, cannot be relied upon to provide the high levels of reliability and validity associated with them.

The NDIA’s report on the development of IFAs and selection of tools acknowledged there was no single tool that could be used as the basis for funding decisions. Therefore, they chose a suite of tools that could be used to assess participants. The NDIA have suggested that they have chosen Tools with high levels of reliability and validity, however, they are proposing that these be used to assess and allocate budgets that will help participant’s meet their stated goals, which is not the purpose of these Tools. The NDIA claims that “the tools will be used collectively” for this purpose – it is not clear how the NDIA would do this using these tools. If used by individuals who are inexperienced (see above), the NDIA will not be able to justify this or the results of their assessments. The details in relation to the pilot evaluation are scant. It appears to have been poor quality and did not asses the impact of the IAs. The numbers - 145 surveys - are few given the range and diversity of NDIS participants. Moreover, the NDIA did not provide information on whether the assessments led to funding that would have provided reasonable and necessary support for those involved to reach their goals. In essence, the pilot was totally inadequate in assisting us to know whether IAs are suitable. The pilots were conducted by the NDIA itself, which is not an independent process. An evaluation protocol should be developed and approved before the intervention is implemented and evaluated to prevent selecting and reporting only the results that suit the reporter. It is unethical for the NDIA to implement such widespread change without a more diligent independent evaluation of the effectiveness against outcomes and agreed upon by people with disability.

Evelyn Bugel, Psychologist