Therapy Works CQ
Occupational Therapy & Sensory Gym
babies | children | adolescents | adults seniors
to the Joint Standing committee of the National Disability Insurance Scheme
Re: Independent Assessments
My name is Ryan Sheedy. I am an Occupational Therapist or OT employed by Therapy Works CQ in Rockhampton, Central Queensland and I am writing this on behalf of the practice and its principal Samantha Woods. I myself have over 18 years’ experience as an OT, with over half of that time spent working closely providing clinical support and services to people with disabilities both in federal government (CRS Australia), State Government (Disability Services Queensland) and non-government organisations. Samantha Woods has over 30 years’ experience as an Occupational Therapist working in hospital (Princess Alexandra Hospital Brisbane and Rockhampton Hospital), community and private practice settings. Therapy Works CQ employs a total of 13 therapists (including OT’s, Speech Pathologists and Physiotherapists) and has well over 100 years of combined clinical experience. The clinicians work with people who are participants of the NDIS on a daily basis. Therapy Works CQ as a practice has evolved along with the implementation of NDIS to strive to meet the service needs of people with a disability, whilst working within the challenging environment as an NDIS provider in a scheme which continues to change as it moves forward.
As a regional practice, the discussion around independent assessments in NDIS has raised interest and concerns. As Occupational Therapists, one main facet of our profession is to assess people’s functional capacity, the information gained then being used to guide our therapeutic direction in providing services to people, and assisting them to obtain the supports that are required to maximise their function and increase independence. Functional Capacity Assessments are essentially at the core of our specialist training, and as Occupational Therapists, we are the profession most qualified to undertake Functional Capacity Assessments.
The government’s recent announcement that the NDIA has gone through an open tender process to find the right organisations to provide independent assessments has raised further concerns. Whilst the tender process was posted on the Austender website, it was not announced to registered NDIS providers any formal NDIS channels. It was also posted on Austender between March and June 2020, during which time the COVID-19 pandemic had practices such as ours scrambling to adapt to non-contact meetings via Skype and ZOOM, investing much time and money into our capacity to deliver telehealth to enable the practice to continue to be viable during lockdowns. Between the timing and the lack of formal announcements at the time about the process being held, many
Therapy Works CQ Occupational Therapy & Sensory Gym Samantha Woods B. Occ. Thy. T: 07 4922 0376 Edwards Chambers PO Box 552 Principal O.T. F: 07 4922 0418 Suite 12, 174 Quay Street Rockhampton Occupational Therapist E: admin@therapyworkscq.com.au Rockhampton Qld 4700 ABN 68 015 232 493 WI therapyworkscq.com.au
Independent Assessments
Submission 327
small practices such as ours did not get an opportunity to even tender, to throw their hat in the ring and have a chance to provide or deliver these services.
The more recent statement about which organisations will provide the independent assessments has raised further concerns. Whilst these organisations may in some cases have a national footprint, their levels of knowledge and experienced staff, particularly within the Central Queensland region is certainly questionable when compared to Therapy Works CQ.
Other information which has come to light throughout the announcement of implementation of independent assessments has raised further questions, not just those about the independence, qualifications, training, expertise and quality assurance of these new assessors for the announced organisation; nor just about the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding.
Would not a person’s treating occupational therapist, who may have either a short, or in many cases, long history of working with a person with a disability, be a better choice to assess someone’s functional capacity, than someone who has literally just walked in and conducted a standardised assessment, based undoubtedly on a highly regimented and refined assessment process, which I assume would have been designed by an NDIS “panel of experts”. I would like to know further about who designed the “independent aassessment process” and how they consulted to develop an assessment which is meant to be conducted, according to the NDIS’s communications, in somewhere between 20 minutes and 2 hours. Are we expected to believe that this process will provide a true picture of a person’s disability? My 18 years’ experience has taught me that many s \ people with a disability will understate the nature of how their disability impacts them across multiple domains; maybe this is because of the Australian attitude of “she’ll be ight” or “someone else has got it worse than me”? Without taking the time to conduct a thorough assessment and perform professional clinical observations, which often are net always possible in a short time window (such as is planned for the independent assessments), it is not possible to have an accurate picture of what a person’s functional capsity and disability support needs truly are.
Organisations that will be conducting the “independent assessments” in rural and remote regions with fly-in-fly out models of service will also not understand the challenges that are posed for people with a disability living in rural and remote Australia, where the nnearest service hubs are, the logistics of travel, accessing specialised disability equipment and services, or possibly even just having access to necessary supports day to day.
Communications from NDIS have also raised concerns that the “independent assessment process” is being rolled out as a thinly veiled attempt at reducing financial expenditure in the NDIS in the guise of a clinical assessment. If the purpose of the assessments, as NDIS state on their web page is to “capture some of the key information we need to create your NDIS plan and budget”, I again ask, why this information would not be better povided by a local treating therapist who has the training, ability, and access to the tools to provide this?
HHow will treating therapists’ opinions and professional recommendations be considered when compared with information gleaned from an “independent assessment”? Will
Independent Assessments
Submission 327
the decisions that are unfavourable? I have had similar experiences numerous times over in the past three years working with NDIS participants where I have submitted an assistive technology request which was initially declined by a NDIS planner, only to be overturned after I requested the decision was reviewed. This occurs, I imagine, because the initial planner had no clinical knowledge or expertise to make that decision in the first instance. My years working with and understanding government organisations have taught me to challenge decisions that contradict my training and ethics; to try and achieve the right outcome for the person with a disability and get them what they need, because they eed it; not because I am trying to spend more of the NDIS’s money. There is a risk the “independent assessment process” will disadvantage people who don’t have the will or capacity to challenge decisions that leave them in a worse off position; a risk that is likely to eventuate into a reality if organizations delivering these assessments are not apropriately skilled, nor have adequate knowledge of local services and resources when performing the assessments.
Ultimately, the practice I work for would like to continue working with the NDIS and its unique participants to try and improve their lives and achieve positive outcomes for them, but it‘d be remiss of us not to raise what we feel are valid concerns about the independent assessment process as it is slated to roll out. Surely more consultation is required on a regional, rural and remote level. There must be a way to roll out this process whilst still rowing therapists who are already engaged in service delivery activities with participants, to input their clinical observations and expertise to maximise results for both participants of the scheme and NDIS.
Finally, if the NDIS is going ahead with Independent Assessments, Therapy Works CQ u2019d like to be able to provide Independent Assessments to NDIS participants within the Rockhampton and Central Queensland region. We would be able to provide these in dependent assessments in the CQ region, through an Allied Health company separate to Therapy Works CQ. We would be able to provide highly experienced Allied Health therapists, particularly Occupational Therapists to undertake these assessments. We believe that the NDIS failed to communicate to NDIS registered providers of Allied Health Services about the Independent Assessment tender. Registered providers were not invited to tender and generally have no need to refer to the government Austender website. As a registered NDIS private practice,‘s invested considerable resources into completing the NDIS registration process, we would have appreciated being informed about this tender process through the NDIS provider emails that are sent to us believe this lack of communication has been a failing on behalf of the NDIS and their provider engagement team and process. Therefore, we would submit that the tender process be re-run, and for this process to be communicated through provider emails, so that all registered providers are able to put in a tender to provide independent Assessments in a fair process.
If you require further clarification, please do not hesitate to contact me on Samantha Woods can be contacted
Kind Regards,
Ryan Sheedy B. Occ. Thy. 24/03/2021