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Joint Standing Committee on the National Disability Insurance Scheme: Inquiry into Independent Assessments under the NDIS

St Vincent’s Hospital Melbourne - Mental Health (SVHM-MH)

This submission is made on behalf of the St Vincent’s Hospital Melbourne - Mental Health NDIS Committee. The Committee’s role is to oversee and guide the establishment of an effective operational interface between the service and the NDIS, with the aim of improving eligible consumers’ access to, and experience of the NDIS pathway. The Committee is comprised of representatives from all relevant disciplines, specialist areas, treating teams and management, and reports to the Mental Health Operations Committee. The Committee welcomes this opportunity to share the experiences of mental health consumers receiving treatment at SVHM-MH, vulnerable people who may otherwise be unable to contribute to this inquiry.

The NDIS experience for consumers of SVHM-MH

Being able to attend and contribute to consultations is challenging for people with mental health problems and psychosocial disability. It is reasonable to assume that the voices of those we work with may not have been heard at NDIS consultations and evaluations.

Local data analysis shows that more than 80% of consumers of SVHM-MH would benefit from NDIS supports and are eligible, but only one third have decided to seek NDIS access. For those engaged in NDIS at SVHM-MH we know that for every plan that is working, one has broken down in some way. For those whose plans have broken down, opportunities to provide feedback or attend consultations to speak about their experiences are often out of reach.

Multiple barriers to engagement mean that the National Disability Insurance Agency (NDIA) is unlikely to know about the NDIS experience for people with serious mental illness and psychosocial disability. In particular there may not be a good understanding of the impact that the proposed Independent Assessment (IA) process will have on people. Most consumers who access SVHM-MH experience significant functional impairment and already experience the engagement process as too difficult, drawn out, demanding, unclear and intrusive. We are concerned that the proposed IA process will only add to these existing barriers.

The response of St Vincent’s Hospital Melbourne - Mental Health to Proposed Assessments

SVHM-MH commends the NDIS principles and welcomes the NDIA’s commitment to equity and sustainability. However, we believe there are two fundamental flaws with the proposed IA process:

1. Independent Assessments will make accessing the NDIS more difficult for the people we work with,
2. There is a large and particularly vulnerable and marginalised group of people whose experiences are not adequately reflected in the data or consultations.

Summary

1. The proposed IA process addresses equality but not equity.

2. People with mental illness and psychosocial disability will continue to experience poorer outcomes.

3. Tertiary mental health services have a significant role in:

   a) Supporting consumers and carers in accessing and utilising the NDIS, and

   b) Ensuring consumer and carer experiences are represented in relation to proposed reforms.

4. Evidence suggests the proposed IA process may cause harm for consumers.

5. Design and outcomes of pilot projects do not provide an evidence base to support major reform.

6. The design of a proposed assessment framework further disadvantages people with serious and enduring mental illness.

Recommendations

1. Minimise burden on people trying to access NDIS:

   a. Address concerns of consistency, objectivity and sustainability of assessments as a market issue

   b. Work with professional bodies and

   c. Fund independent research to understand and develop best sustainable practice.

2. If a person chooses, allow their mental health clinician to complete or help to complete IA requirements.

3. The NDIA provides robust, independent evidence that shows new processes:

   a. Will not cause harm (either during the assessment process or via inadequate plan budgets)

   b. Will result in better outcomes, and

   c. Address barriers to engagement for people with psychosocial disability.

4. Investment in collaboration with tertiary mental health services, for example:

   a. Significantly expand the NDIS Health Liaison Officer role, and

   b. Fund new roles to lead NDIS operational interface and collaborate with mainstream services to:

    i. Reduce duplication
   
     ii. Build workforce capability and
   
      iii. Monitor and troubleshoot emerging issues.
   

The Joint Standing Committee’s Terms of Reference

The Joint Standing Committee’s Terms of Reference:

a) The development, modeling, 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. l) Any other related matters.

SVHM-MH’s responses to the Joint Standing Committee’s Terms of reference

The following is extracted directly:

Many submissions published on the Joint Standing Committee website articulate issues and experiences shared by SVHM-MH and provide extensive evidence and references to support those views. Rather than repeat these issues and references, this paper uses quotes from published submissions to acknowledge aligned issues and views and expand on how these impact on the people we work with. a) The development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS.

The SVHM-MH NDIS Committee believes that: i) The design and outcomes of the IA pilot project do not support major reform and supports Occupational Therapy Australia’s view that:

“…The pilot process should be halted until clinical authorities can better understand its impact on clients. There should be: i Proper, clinically driven evaluation of data; ii. A broader cohort;

Independent Assessments Submission #313

iii. More rigorous design, including consumer input into methodology.” (OTA p.11)

ii) Proposed changes address equality but not equity and assumes all participants possess equal skills and resources to navigate the process.

Reforms intended to improve people’s experience of the NDIS and improve outcomes for speople with psychosocial disability will be unsuccessful if barriers to engagement (See Appendix 1) are not understood and addressed. An example is lack of access to a telephone, or email or the capacity to manage correspondence.

A recent local review of SVHM-MH consumers found:

• Only half of consumers have reliable access to a phone (25-35% have a smart phone, 10-30% have landline or other mobile phone). For consumers of outreach teams like the homeless person team and mobile support team, very few have reliable access to a telephone.
• 1 in 10 have access to tablets/computers and Wi-Fi.
• Up to 75 % have difficulty engaging with phone (e.g., will not answer unknown numbers, have difficulties with concentration, comprehension and/or memory, experience paranoid and/or delusional ideas connected to phone).

iIi) Cost and service access concerns for people with complex needs should be addressed through collaborative working arrangements and service integration with tertiary mental health.

SVHM-MH is committed to partnerships and integrated care to address the needs of the community we serve. The introduction of the NDIS has presented challenges in terms of collaboration. Local efforts to address operational interface issues since NDIS roll out have had only limited success. An Organisational Readiness Checklist (Appendix 2) outlines a comprehensive approach undertaken by SVHM-MH to try to align with the NDIA and its processes to try to achieve the best outcomes for consumers.

Over the past five years there has been some excellent collaboration with a small number of responsive NDIS representatives but this has been very much dependent on individual relationships and goodwill and in the absence of established structures, connections are lost once individuals move on. In general there is a lack of formal relationships to support escalation processes and this compounds complexity at the current operational interface. The introduction of Health Liaison Officers is welcomed but they are a limited resource across multiple health services and there is no indication that the NDIA is intending to expand this much needed role.

Integrated care is an evidence based option that could address NDIS cost and service access concerns but this will require commitment and investment. Integrated care:

• Improves outcomes, efficiency of care and consumer satisfaction and is highly valued by service users, carers and families, particularly for people with complex health or social issues.¹

¹ Banfield, M, Gardner, K, Yen, L. et al. 2012, Coordination of care in Australian mental health policy

Independent Assessments

Submission #13

 Reduces overall costs and improves service access for people with complex needs. · Harnesses collective effort, maximises impact and makes efficient use of resources through integrated planning, reduced duplication of effort and shared ownership of processes and outcomes. · Is a key mechanism to achieve a more consolidated service approach to address service gaps and to pool resources to meet the needs of those accessing services?

b. The impact of similar policies in other jurisdictions and in the provision of other government services.

Learnings from similar policies indicate likely impacts of IAs are increased risk of harm associated with the process (OTA, 2021 p.11), and harm resulting from the process in the form of reduced funding in plans (AHPA, 2021 p.7). An anonymous submission from an Occupational Therapist with 12 years of community experience and currently involved in the pilots as an Independent Assessor outlines the physical, mental and emotional impacts of the process and cites concerns that the process may not capture all required information regarding each person’s individual circumstances - [https://www.aph.gov.au/Parliamentary Business/Committees/Joint/National Disability Insurance Scheme/IndependentAssessments/Submissions Accessed 4th May 2021](https://www.aph.gov.au/Parliamentary Business/Committees/Joint/National Disability Insurance Scheme/Independent Assessments/Submissions)

c. The human and financial resources needed to effectively implement independent assessments.

Tertiary mental health services provide ‘Access Request’ supporting evidence at no financial cost consumers. Clinicians are very skilled at assessing eligibility and providing evidence of functional capacity/need. For consumers of tertiary mental health services, the IA process may be a false economy and will further burden people trying to access NDIS. An example that will specifically impact SVHM-MH is the delay in NDIS access and planning decisions stemming from the IA process which will potentially impact discharge from inpatient mental health wards.

The current process enables timely access and planning decisions. This means timely and coordinated hospital discharges, often within days. Currently treating teams provide all necessary information and a decision is made. The proposed IA process will mean treating teams will still submit evidence but then an NDIA delegate needs to identify an IA provider to accept a referral. The IA providers need to contact the person within two days, book an assessment within 10days, and they then have 90 days to complete it.

The proposed IA process is likely to mean consumers will be discharged from hospital without supports being in place, or needing to remain in hospital for longer than is necessary while access decisions are made. In 2018-19 the average cost per bed day at SVHM-MH adult inpatient unit was $1461* per night. If an assessment took 90 days to be completed, and if completing the assessment was a barrier to discharge this could mean a cost of up to $131,490 for the period. In busy inpatient units where demand for beds often

² Benzer, J, Cramer, I, Burgess, J, et al. 2015, How personal and standardised coordination impact implementation of integrated care ³ The Peninsula Model for Primary Health Planning, 2013. ⁴ Victorian Council of Social Services and Victoria Department of Health and Human Services, 2009.

Independent Assessments

Submission #13

xceeds availability, it is likely that consumers will be discharged before assessments are completed and without appropriate supports, increasing the risk of unplanned hospital re-admission. (*Figure based on average cost per bed day reported for St Vincent’s Adult Mental Health by Department of Health and Human Services in 2018-19 Admitted Mental Health Program Cost Data Analysis).

Clinicians providing assessments and evidence for consumers trying to access NDIS use a person-centred, collaborative and trauma-informed approach. Between 10-30 hours are typically spent in preparing relevant evidence (see Appendix 3). Preparing supporting evidence for an Access Request takes a skilled mental health clinician (familiar with the consumer, their history and supports and with completing NDIS documentation) a minimum of 3 hours. This investment is borne out by SVHM-MH clinicians’ high success rate providing evidence that supports an Access met decision (locally this is close to 100%). Supporting a consumer to prepare for the Planning/Review meeting and prepare supporting documentation takes at least 10hours. At the upper end of the continuum 200 hours over a period of several months have been invested in ensuring access for a very complex consumer requiring multi-service support, with high levels of risk and a need for longitudinal assessment and collateral information collection.

in contrast, independent assessors are, without any prior knowledge of the person, xpected to complete the assessment in 3-6 hours.

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

The SVHM-MH NDIS Committee is unclear on processes for independent assessor credentialing, a concern cited by the AHPA (2021, p.2).

e. The appropriateness of the assessment tools selected for use in independent assessments to determine plan funding.

the proposed assessment tools are not reliable or validated for the NDIA’s intended use as part of the IA process to determine substantially reduced capacity and plan budget. Providing evidence to address eligibility and providing evidence for reasonable and necessary funding are two distinct processes requiring different information, approaches and resources. The proposed tools and methodology are arguably, clinically unsound.

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

the current NDIS process is difficult for people with serious mental illness. The proposed IA process will create an additional barrier that will potentially result in reduction of support, increased hospital admission, increased disability, greater demand on the treatment system, increased need for guardianship, more restrictive environments and ultimately, greater demand on NDIS.

Independent Assessments

Submission #313 g. The implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports. since the inception of NDIS a key element of determining if a support is ‘reasonable and necessary’ is to ensure it is directly tied to a person’s goals. IAs will not collect information on a person’s goals. In this way ias are not fit for purpose in determining if supports are reasonable and necessary. Two consumers of svhm-mh may have the same diagnosis and the same functional capacity (theoretically scoring exactly the same using the ia tools) and yet their support needs related to their individual goals may vary dramatically. customers of svhm-mh may only tolerate support with basic self-care tasks while others with a similar functional capacity may seek support with things like cooking, exploring social options, or support with parenting or other care roles. Without exploring individual goals and the supports that will work best for an individual it is likely that some customers will be overfunded while others are under funded. h. The circumstances in which a person may not be required to complete an independent assessment. there is sufficient evidence to suggest that ias may cause harm, that the tools are not fit for purpose and that the process may cause significant distress for customers of tertiary mental health services. To mitigate risk of harm, customers of tertiary mental health services should qualify for an exemption unless the person chooses to participate. The decision to grant exemptions should be subject to appeal. SVHM-MH clinicians and customers have experienced ndia administrative errors and decisions that are overturned when subject to review/appeal which highlights the importance of this option. approximately 30% of NDIA decisions regarding Access or Planning for customers of svhm-mh have required intensive follow up by clinicians to trigger a review and all have resulted in ndias initial decision being overturned. without the right to appeal, vulnerable people will have to choose between undergoing a process their treating team has assessed as high risk, or choosing not to seek the supports they need to manage their disability and work towards their goals. i. Opportunities to review or challenge the outcomes of independent assessments sVHM-MH shares the broader community’s concerns ia’s will be the key determining element on a persons eligibility in the absence of a reasonable level of accountability. We support ot australia’s recommendation that an independent appeals process be established and that this process includes a comprehensive functional assessment by a suitably qualified allied health professional to provide a thorough profile of the person’s capacity and needs (ota, 2021, p. 24). 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. the SVHM-MH experience is that engagement with the NDIS is already challenging (see appendix 1) and the proposed IA process creates another barrier to vulnerable cohorts being able to access the supports they need.

k. The Appropriateness of Independent Assessments for People With Particular Disability Types, Including Psychosocial Disability.

The structure and selection of assessment tools for IAs disadvantages people with serious enduring mental illness and has the potential to further strain family/friend/carer relationships. The process will rely on an accurate self-assessment of one’s needs, and having a support person/family/friend to attend the assessment. Both of these elements may prove difficult for people with serious mental illnesses and psychosocial disability. A person’s capacity for self-assessment can be impacted by different things. People need to see themselves as resilient and ‘able’ – this is critical to one’s survival and recovery but will not align with a process seeking for a person to identify their deficits. Cognitive impairment, experienced by many people with serious mental illnesses also impacts one’s ability to self–assess need.

The literature, local data and use of the WHODAS⁵ tool indicates consumer self-ratings of their own functioning are consistently higher than clinician rating. This potentially overestimated assessment of functioning will result in inadequately funded supports or being deemed ineligible for the scheme. Without psychosocial supports, the risk of deterioration and further disability is increased, potentially resulting in greater demand on the tertiary mental health system and the NDIS later.

Many consumers with serious mental illnesses experience extreme social isolation and this is the local experience at SVHM-MH. Many will not have family or a friend they can rely on to act as a support person or proxy during the proposed IA process. One proposed IA tool, the Vineland 3 must be administered through a proxy. Supporting a person with serious mental illness is challenging and being asked to participate in an assessment process that asks a carer to rate a person’s functioning when their rating may be quite different from the consumer’s own rating has the potential to disrupt valuable and vulnerable caring relationships.

Many consumers of SVHM-MH meet NDIS eligibility due to difficulties under the domains of social interaction and self-management. This means everyday tasks are difficult or impossible due to factors such as:

• a) Difficulty coping with situations involving stress, pressure or performance demands
• b) Impulsivity
• c) Slowed thoughts
• d) Understanding information clearly from others
• e) Engaging with or understanding written material
• f) Managing correspondence
• g) Holding reciprocal conversations
• h) Articulating needs and seeking help i) Being understood by others j) Regulating emotions and managing interpersonal conflict

⁵ World Health Organisation Disability Assessment Scale https://www.who.int/classifications/icf/whodasii/en. Retrieved May 2021

Independent Assessments

Submission #13 k) Navigating service systems l) Extreme social isolation and/or lack of support networks m) Impaired concentration, decision-making and organisational skills, motivation and judgement n) Difficulties establishing trust, engaging with others and misinterpreting events.

The same functional impairments that mean people are eligible for NDIS are the reasons they struggle with the access process, connecting with supports and using plan funding. It is not uncommon to find that consumers with NDIS funding are not utilising it as they struggle with setting up a plan without assistance.

Consumers should be given a choice to complete access requirements assisted by trusted mental health providers. At SVHM-MH this has been an important factor helping people obtain supports.

A case could be made supporting independent assessors developing capability around mental health; however, such development would require significant resources and wouldn’t address issues where consumers benefit from knowing and trusting their supporter – frequently a clinician at services like SVHM-MH who may have worked alongside them previously.

To mitigate risks associated with serious enduring mental illness, NDIA initiating engagement & collaborative work practices involving tertiary mental health services would prove useful. Ideally those receiving these services can choose participating in IA processes supported via evidence provided through treating teams considered during assessment planning or review.

Alternative models exist which SVHM-MH endorses: OT Australia proposed National Endorsed Assessor Team completing assessments led by experienced allied professionals including specialists (OTA 2021 pp14–15). The Royal Australian New Zealand College of Psychiatrists proposes Medicare Benefits Schedule style items for medical/health practitioners. l) Any other related matters.

The experience at SVHM-MH is that budgets increase over time - potentially indicating functional decline despite support provision. Locally it’s observed increased budget requests reflect changing circumstances enabling better plan participation allowing articulation needs engaging more effectively within existing structures.

Many initially find initial meetings overwhelming struggling to articulate requirements while building rapport slowly across supports. NDIS planners Local Area Coordinators often reassure both patients clinicians demonstrating no need immediately justify increases.

Independent Assessments Submission 313

everything into a first plan, and that often a second plan is bigger as people are more aware of what is needed.

another pattern observed locally and at other mental health services is that for many customers engaged with NDIS, plans were not well understood or had not been enacted f fully. In some cases supports in place had broken down over time for a variety of reasons, or could not be accessed in the first place. Mental health clinicians have needed to step in to assist with triggering plan reviews and securing more plan budget in order to ensure sustainable support are put in place. svhm-mh is in a position to be able to provide de- tidentified data and case studies highlighting these patterns if it would be useful to this inquiry.

Conclusion

In conclusion, evidence suggests the proposed ia process may cause harm for consumers. design and outcomes of pilot projects do not provide an evidence base to support major rowform. The design of a proposed assessment framework further disadvantages people with serious and enduring mental illness. SVHM’s recommendations should be considered by The Joint Standing Committee to address the fundamental flaws with the proposed IA process.

References

The Commonwealth of Australia. Joint Standing Committee on the National Disability Insurance scheme: Independent Assessments (2021). Public Hearing Friday 23 April, 2021. p.4( Proof Committee Hansard) https://parlinfo.aph.gov.au/parlInfo/download/committees/commjnt/c84a18cc-272b-46c0- 8cb1ae6034a8/toc pdf/Joint%20Standing%20Committee%20on%20the%20National%20Di
isability%20Insurance%20Scheme (2021).

Submissions to the Joint Standing Committee’s Inquiry into Independent Assessments
2021. Retrieved April 26 2021 from [https://www.aph.gov.au/sitecore/content/Home/Parliamentary Business/Committees/Joint/
National Disability Insurance Scheme/IndependentAssessments/Submissions]

• Allied Health Professions Australia (AHPA), March 2021. Consultation Response. Joint scheme: Inquiry into Independent Assessments.

• Melbourne Disability Institute, February 2021. An analysis of the NDIA’s proposed \approach to Independent Assessments: A submission to the Joint Standing Committee.

• Occupational Therapy Australia (OTA), April 2021. Australian Parliament Joint Standing committee on the National Disability Insurance scheme: Inquiry into Independent assessments under the NDIS.

• Young People in Nursing Homes National Alliance (YPINH), March 2021. Submission to the Joint Standing committee on the National Disability Insurance scheme’s inquiry into

The Royal Australian and New Zealand College of Psychiatrists (RANZCP), February 2021, [https://www.ranzcp.org/files/resources/submissions/ndis-access-and-eligibility-policy-with-
independen.aspx](https://www.ranzcp.org/files/resources/submissions/ndis-access-and-eligibility-policy-with-\nin independen.aspx)

Appendix 1: Overview of barriers related to engaging in the NDIS

A table outlining background context, complex needs, broader contexts, and general engagement barriers:

Appendix 2: Organisational Readiness Checklist

Readiness Indicators

• Senior management is committed to building an effective operational interface with the NDIS to ensure consumers and carers are supported to access and effectively participate in the NDIS.
• The mental health service has an endorsed change management plan / project plan for implementing the necessary changes to build an effective operational interface with the NDIS, consistent with the priorities identified in their strategic planning documents.
• The clinical mental health workforce are aware of and understand that supporting consumers and carers to access and participate in the NDIS is a key priority for the mental health service and an important part of their ongoing role, consistent with the National Standards for Mental Health Services
• An NDIS mental health program lead / portfolio holder or equivalent is nominated and opertional within the mental health service to function as the key contact point for NDIS issues and lead work within the service to establish an operational NDIS inface.
• An internal NDIS Steering Committee or equivalent is established and opertional within the mental health service to lead the organisational practice change and workforce development to support an effective NDIS interface.
• Appropriate resources are allocated to address the priority of building clinical mental health workforce literacy and capability with regards to the NDIS.
• An NDIS consumer and carer strategy is developed and implemented to build unsumer and carer knowledge and awareness of the NDIS
• The mental health service’s work practices and IT systems support the clinical mental health workforce
• The mental health service’s key practices, policies and procedures related to the following areas of consumer contact have been updated to reflect new NDIS

equirements, language or processes

• The roles and responsibilities of staff involved in supporting consumers and carers to 곎ss and participate in the NDIS and undertake shared planning and service oordination with NDIS funded providers are clearly documented, communicated and understood within the organisation

• Recruitment and workforce training and development systems, processes and documentation ensure that the clinical mental health workforce have the required capabilities

• Processes are in place to ensure the clinical mental health workforce’s NDIS nnowledge remains relevant and current

• Up-to-date information links or resources are provided to the clinical mental health orce that identify NDIS psychosocial providers and the types of disability supports ey provide within the mental health service’s catchment area

• The mental health service facilitates and supports its clinical mental health workforce to end relevant NDIS training (where available), or ensures staff have access to echnology to undertake online training.

• Clinical supervision is used to support NDIS related learnings and practice change

• Where necessary, additional resources are developed for staff to support their interface wth the NDIS access, planning, plan implementation and review processes

• The mental health service’s existing templates and tools that support clinician practice ave been reviewed and updated to reflect current NDIS requirements, language and

Independent Assessments Submission 313

The following details how a mental health service supports participants in accessing the National Disability Insurance Scheme (NDIS).

Interface & Responsibilities

e processes

18 Consumer and carer friendly information about how to access and participate in the NDIS is available.

19 The mental health service has identified and engaged the key local stakeholders required for a successful NDIS interface.

20 The mental health service has a statement of respective mental health service, NDIA and LAC responsibilities which articulates how decisions are made and agreed escalation processes.

21 Where the mental health service is a party to established local alliances or partnership structures, this will include NDIA regional office representatives and the LAC.

22 The clinical mental health workforce are supported to develop local relationships and partnerships with the NDIA regional office (e.g., through the NDIA engagement officer), the LAC and Support Coordinators to improve communication, understanding of respective roles, and to support effective working relationships.

23 The mental health service facilitates regular forums with NDIS providers within their catchment area for the purposes of information sharing, improved service coordination for shared consumers and relationship building.

24 There is an established data collection strategy to identify risk and systemic issues with: * the mental health service’s interface with the NDIS; and * Consumers and carers access and participation in the NDIS. Clinical impact (e.g., clinician workload or Emergency Department impact) Consumer experience (e.g., impact of access process on consumers or evaluation of their experience regarding support received from the mental health service when accessing and participating in the NDIS). Carer experience Access (e.g., MHCSS recipient’s transition to NDIS, monitoring access, planning and review barriers / issues / enablers, barriers to access and advocacy for hard-to-reach and difficult-to-engage consumers etc.).

25 There is an organisational system to monitor and respond to poor NDIS access, planning, plan implementation or review or shared planning outcomes; and adverse consumer experience of the NDIS pathway.

26 An NDIS issues log or other process to record and report on NDIS provider/safety issues is embedded in the mental health service’s work practices.

27 The mental health service has established feedback loops to raise significant quality issues about NDIS funded providers with: DHHS (until June 2019); the Mental Health Complaints Commission (until June 2019); the NDIA (ongoing), and NDIS Quality and Safety Commission (from June 2019). Opportunities are sought for collaboration with other mental health services on shared issues.

Governance & Collaboration

e processes

28 Opportunities are sought for collaboration with other mental health services on shared issues.

29 The mental health service has an established mechanism for regular external interagency meetings to review the effectiveness of the interface between the service and the NDIS and to develop solutions to more complex issues.

30 There is an established NDIS quality and safety committee, or standing item on the mental health service’s quality and safety committee (or equivalent), to address service coordination issues and trouble-shoot NDIS service provider issues.

31 The mental health service facilitates regular forums with NDIS providers within their catchment area for the purposes of information sharing, improved service coordination for shared consumers and relationship building.

Appendix 3: Breakdown of clinician activities to support NDIS Access

A table detailing clinical activity requirements is provided below:

If initial ARF unsuccessful:

| Completing request for Internal Review, liaising with other services and completing additional evidence and follow up, reviewing with consumer (emails x 6, phone calls x 10) | 5 hours |

*Based on experience of St Vincent’s Hospital Melbourne Mental Health NDIS Program Lead.