We, Bernadette M O’Connor and Marisa A Crowe, are two Allied Health Professionals who wish to submit feedback in to the proposed NDIS independent assessment process.
The following feedback has been structured around the terms of reference for the Joint Standing Committee and based on review of the following document:
- Independent Assessment Framework August 2020
- Access and Eligibility Policy with independent assessments
- NDIS website – Independent assessors
- NDIS website – Operational Guidelines
This submission is based on the collective knowledge of our experience as allied health professionals working with children and young people and direct clinical experience of assisting children and young people to access and navigate the NIDS, as well as providing NDIS services.
The following feedback addresses the Terms of Reference as outlined below:
1. The independence, qualifications, training, expertise and quality assurance of assessors;
- 1.1. Information on the website provides a list of professions which may be available to complete the independent assessments. As this list of assessors is not built into the Framework or in to the NDIS Legislation, there is concerns that the professionals who are deemed suitable may change without community consultation.
- 1.2. It is also unclear as to how the NDIS will ensure appropriate skilled clinicians with appropriate clinical knowledge to interpret the outcomes of the proposed assessments. Currently there are no credentialling requirements within the NDIS that ensure appropriate levels of experience or skill in providers, other than those mandated to practice such as AHPRA registration or professional Association membership. There are no objective quality control measures for clinical service delivery within the NDIS. The NDIS website states clinicians will need to:
“Have a minimum of 12 months full time clinical experience (post General Registration) working in their field with an appropriate level of clinical supervision”
however, given the current lack of objective quality control measures already established within the NDIS practice guidelines and registration criteria, further evidence needs to be provided to ensure quality and knowledgeable clinicians are employed to conduct these assessments.
2. The appropriateness of the assessment tools selected for use in independent assessments to determine plan funding;
- 2.1. There is no clear information on how the independent assessment will shape a plan. In the Framework document, the use of the tools in the planning process is not mentioned until page 22. Additionally, the Framework speaks to the validation of the tools to
determine impact of disability on function, however there is no evidence provided that these tools have be validated for use in support provision.
-
2.1.1. There is also no evidence provided as to how these tools can be used to help inform NDIS goals or how they work in conjunction with a participants ‘choice and control.’ If these tools are to be used to help inform plans and supports, evidence should be provided to demonstrate how identified functional incapacity indicates goals and dreams for a participant.
-
2.1.2. Specific and robust documentation is needed as to how these assessments will inform a plan, as distinct from an access decision, and the consequences of differing personal preferences and clinical recommendations when a plan is being utilised.
-
2.2. The Independent Assessment Framework states:
“A comprehensive assessment of function across all the domains referenced in the disability requirements may place unrealistic and unmanageable demands on professionals in terms of time, costs incurred, training and resources available to explore multiple domains.” (p 13).
This statement acknowledges the skills and time required to obtain a complete picture of the participant, however this is unlikely to be any more achievable with the independent assessors than with a health care professional who knows the participant over a long period of time.
The concern of potential ‘sympathy bias is highlighted in the Framework as a reason as to why the assessments should be independent, however there has been no evidence of the NDIA investigating an option such as offering ‘NDIS assessment credentialling’ to community and health providers. If a healthcare professional had access to this, they would have a better understanding of what the NDIS needs in terms of evidence and consistency in reporting.
The Framework talks to a lack of standardisation being provided thus far by health professionals however the NDIA have not provided guidance prior to this consultation regarding what evidence they wish to see or even provided a list of tools that are eligible to use to assess functional impairment. The NDIA should provide the opportunity to trial the tools and standardised reporting first, rather than removing this as an option in its entirety.
- 2.3. The Framework also reference The Disability Care and Support-Productivity Commission Inquire Report, 2011, stating:
“…. The assessment process should include aspects of learning and applying knowledge, and community and social participation” (Independent Assessment Framework p 13)
None of the tools identified assess learning and applying knowledge skills. In regard to community and social participation, the WHODAS, for example, asks the participant their experience with community and social participation, however doesn’t request the tester to observe the participant in these situations. Although it’s important to
understand a participant’s reality, some disabilities disrupt a participant’s insight in to their ability to perform in these areas. A health professional who knows the participant are more likely to know the true extent of this impairment than an independent assessor.
If this is what is needed to get an accurate picture of a participant, how are the independent assessors going to be able to complete this?
3. 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;
-
3.1. There is no available data on the validation of the identified tools for use with interpreters. Some are validated in original form when translated, but there is no available evidence to advise the test-retestability when the tester speaks in English and an interpreter is used.
- 3.1.1. If a clinician has the skills to complete one of the identified assessments in a language other than English, (therefore, use the validated translated version); what credentialling will be required to ensure the clinician has the proficient skills of an interpreter (This also applies to Section 1)
4. The human and financial resources needed to effectively implement independent assessments;
- 4.1. Information is not provided in the available documentation as to what experience and credentialing will be introduced to ensure consistency across planners. If the tools are used to inform plans, information should be provided on the expertise of planners to interpret the results of the assessments and apply them to the criteria of ‘reasonable and necessary’.
5. Any other related matters;
- 5.1. The Independent Assessment Framework document states:
‘The primary purpose of an assessment of functional capacity for NDIS is to support Access and Planning decisions.’ (p22)
It also states:
‘Equity and consistency may be gained in multifaceted complex cases when NDIS delegates have consistent and comparable assessment finding available to them.’ (p24)
Given that the NDIS Operational Guidelines outline that the NDIS is based on four insurance principles, with one of them being:
‘the total annual funding base required by the NDIS is determined by an actuarial estimate of the reasonable and necessary support needs of the target population. The NDIS continually compares these estimates of utilisation and costs with actual
experience and outcomes.’
It is unclear if the NDIA plans to use the information gathered from these assessments and their subsequent plans to create their own normative data in which to further the available actuarial data for the ongoing provision of services.
If this is the plan, this needs to be made explicit and ongoing assessment of this actuarial estimates needs to be made available for community review.
In this event, there also needs to be provision for robust outcome measures to check that plans provided based on the independent assessments are meeting the needs of the participants and improving a participants ability to achieve their goals.
In summary:
-
Clearer information needs to be provided on the expertise of clinicians who will perform the assessments and what quality assurance measures are implemented; the expertise likely exists within existing health and community services and dedication of additional resources to these to perform the required and requested assessments needs to be considered as an option.
-
The information provided by NDIA/ NDIS is unclear as to the relationship between the assessment of function and the subsequent plan creation. There is also no evidence provided to demonstrate the tools identified are appropriate for plan creation or identifying participants goals that inform a plan;
-
The tools identified have not been validated for use with interpreters. Should clinicians be able to complete the assessments in languages other than English, there is no documented requirement for the clinicians to be accredited interpreters;
-
There is no information provided on the quality and experienced required of subsequent planners and their expertise in currently interpreting the results of the assessment and applying them appropriately to a plan;
-
It is not clear in the documentation available that the results of the independent assessments won’t be used as normative data for actuarial purposes. If this is the plan, the actuarial modelling needs to be made available for assessment by the NDIS community and robust outcome measures also need to be employed to ensure outcomes are being achieved.
Thank you for your consideration.
redacted
redacted
Bernadette O’Connor
Speech Pathologist
Speech Pathology Australia
redacted
Marisa Crowe
Occupational Therapist
APHRA registration
redacted