Concerns regarding introduction of Independent Assessments by the NDIA | External submission

Disability Advocacy DA www.da.org.au

Disability Advocacy NSW Head Office Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085

31 March 2021

The Hon Kevin Andrews MP Chair Joint Standing Committee on the National Disability Insurance Scheme Parliament House CANBERRA ACT 2600

Dear Chair,

Disability Advocacy NSW (DANSW) welcomes the opportunity to participate in the Joint Standing Committee’s inquiry into the proposed introduction of Independent Assessments by the National Disability Insurance Agency (NDIA).

DANSW will be contributing to the inquiry in two ways:

DANSW has provided its full endorsement of a joint submission prepared collaboratively by The NDIS Appeals National Advocacy Network¹ (“the Appeals Network”) of which DANSW is a member. DANSW endorses and all the concerns raised, and recommendations made therein.
To compliment the joint submission, DANSW has also prepared an individual submission addressing several key areas of the inquiry. We focus our commentary on critical areas of concern raised by our clients and community members and also our extensive experience providing advocacy support for people with disability on NDIS related issues.

The Appeals Network joint submission and DANSW’s individual submission both address several key areas of the inquiry that advocacy organisations are well positioned and qualified to respond to. Areas of inquiry not specifically addressed are otherwise most appropriately responded to by specialist professional organisations such as professional associations for psychologist, physiotherapists and occupational therapists and bodies representing demographics with particular needs such as First Nations or Culturally and Linguistically Diverse (CALD) people with disability.

¹ National Disability Insurance Scheme Consultation Paper: Access and Eligibility Policy with independent assessments (23rd February 2021).

ABN: 93 9843 83421

Disability Advocacy DA www.da.org.au

Disability Advocacy NSW Head Office Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085

About Disability Advocacy NSW

DANSW provides individual advocacy to people with all disabilities and all ages to over two thirds of NSW. DANSW has a presence in Sydney but also maintains a regional, rural and remote focus with local disability advocates located on the ground in Armidale, Bathurst, Broken Hill, Blue Mountains, Coffs Harbour, Central Coast, Dubbo, Newcastle, Port Macquarie, Tamworth and Taree.

DANSW provides assistance to clients across a wide range of advocacy issues, including National Disability Insurance Scheme (NDIS) access and reviews, discrimination, education, health, accommodation, finances, and justice matters. During the 2019-20 financial year DANSW assisted with 3,077 advocacy matters, and 1,086 inquiries.

Since the roll out of the NDIS in NSW, NDIS-related matters are the highest requested support, totalling 55% of support provided and we see this increasing at an exponential rate.

Figure 1. Breakdown of NDIS support provided during 2019-20.

Support Type	Percentage
NDIS - Access/Planning	34%
NDIS - Internal Reviews	33%
NDIS - AAT Appeals	29%
NDIS - General	4%

ABN: 93 9843 83421

Disability Advocacy DA www.da.org.au

Disability Advocacy NSW Head Office Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085

Recommendations

The introduction of any Independent Assessment arrangement within the NDIS system should be deferred until:
- A more comprehensive appraisal of the NDIA’s proposed Independent Assessment model and corresponding legislative changes to the NDIS Act (2013)² is undertaken, ideally by an independent review body in consultation with the wider disability community.
- There is additional opportunity for input and consultation about the proposed changes for current and prospective participants, the disability sector and wider disability community.
- The NDIA provide more specific details about the proposed changes to the NDIS Planning process.
- The NDIA has finalised development of a robust quality assurance framework to ensure the Independent Assessment model meets validity and reliability standards and ensure people have a clear, accessible and responsive avenue to raise concerns/complaints about any aspect of the assessment process.
- Impartiality of the Independent Assessment providers can be verified. The NDIA needs to provide explanation about how they will manage the conflict of interest issue arising from their contractual relationship with the Independent Assessment providers.
We recommend that the NDIA observe the recommendation made in the Tune review³ that Independent Assessment providers should be subject to uniform accreditation requirements that are designed and implemented jointly by the NDIA and appropriate disability representative organisations.
The NDIA should allow for an opt-in model so that prospective and current NDIS participants can choose whether they wish to utilise the Independent Assessment process to provide evidence to the NDIA about their disability and/or support needs. The model should permit individuals to provide evidence to the NDIA about their disability and support needs from their own treating health professionals if this is their preference.

² National Disability Insurance Scheme Act (2013)

³ Review of the NDIS Act report- Tune review (2020)

ABN: 93 9843 83421

Disability Advocacy DA www.da.org.au

Disability Advocacy NSW Head Office Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085

DANSW Consultation Process

In consideration of our submission, DANSW developed a survey to distribute to clients and the wider community for feedback on the Independent Assessment process. The survey was published via Survey Monkey⁴ and emailed to both past and current clients, as well as distributed on social media.

In total, 204 responses were received from our clients and community members.

Survey Results

Question 1: Do you think that everyone should be given a choice whether or not they want to participate in the independent assessment process?

Question 2: The NDIA thinks that an independent assessment will give them a better understanding of how you manage in your everyday life. They think this will help them make better and fairer decisions around your funding.

Do you think that an independent assessor would be able to understand your disability (or the disability of someone you care for) in order to make fair recommendations to the NDIA?

⁴ https://www.surveymonkey.com

ABN: 93 9843 83421

Disability Disability Advocacy NSW

Suite 1 Level 2, 408 King Street

Newcastle West NSW 2302 Advocacy 1300 365 085 www.dad.org.au

t Yes

Not sure 13%

No 65%

Question 3: Please share any other feedback, questions or concerns that you have with the proposed changes to the NDIS access and/or planning process, including the decision to introduce independent assessments as part of the NDIS. Please explain in as much detail as possible.

Thematic Analysis of Qualitative Feedback

Clients and community members surveyed identified consistent themes within their responses regarding concerns about the proposed Independent Assessment process. Primary themes are set out in Figure 3.

Concerns justifying disability/support needs to someone unknown	80% of responses
Specialised knowledge needed to understand disability	75% of responses
Loss of choice and control under proposed changes	68% of responses
Concerns regarding the independence of proposed changes	57% of responses
Regarded the independent assessment process as unfair	48% or responses
Poor experiences with independent assessments historically	25% of responses

Figure 3. Thematic analysis of responses provided in survey. ABN: 93 9843 83421

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Critical Areas of Concern and Inquiry Responses

Independence, qualifications, expertise and quality assurance of independent assessors

d) the independence, qualifications, training, expertise and quality assurance of assessors

There is significant ambiguity in the information available about the independence, qualifications and expertise of Independent assessors and the quality assurance measures the NDIA intend to implement.

The critical concerns held by DANSW, our clients and community members are as follows:

Independence, qualifications and expertise

In observing the Tune review, it was recommended that “assessors provide truly independent functional capacity assessments, so they are not perceived as agents of the NDIA”. The IA model proposed by the NDIA has not taken on board this crucial aspect of the recommendation.
Under the proposed model, the NDIA will be directly funding assessments through 8 contracted providers who successfully tendered for the initial 3-year contract. This contractually bound relationship between NDIA and assessor creates a perceived, if not actual, conflict of interest and there is no information in the Independent Assessment proposal that explains how the NDIA will manage this conflict.
According to the tender document5 there will be specific KPI targets imposed on providers including what tools they must use, how long they should spend on each assessment and how long they have to submit the final report to the NDIA. Given that ongoing funding is likely linked to their adherence to these KPI’s it raises the question about the actual level of independence the Independent Assessment providers will have and be able to exercise in the implementation of the program.
The assessors do not get to choose the most appropriate assessments to conduct on any given person but instead will be told by the NDIA which tools they must use. It is unclear who will be making this determination in the NDIA and whether they have the appropriate skills and qualifications to decide whether a particular tool or set of tools are most appropriate for the person subject to the assessment.
There are proposed timeframes of 2.5-3 hours for assessors to prepare for the assessment, complete the assessment and complete the report for the NDIA. Based on our experience with clients and independent assessments to date, this seems an unrealistic timeframe for

5 Independent Assessment Panel Tender- RFT 1000724626- Document 1: Statements of Work 6 ABN: 93 9843 83421

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assessors to adequately prepare for and conduct the assessment and produce and submit an accurate high-quality report to the NDIA.

If adherence to unrealistic KPI’s can lead to loss of funding and providers are focused on meeting their contractual obligations and protecting their funding arrangement, there is significant risk that the employed Independent Assessors will not be afforded adequate time to conduct thorough assessments and produce high-quality accurate reports.
Under the proposed IA model all independent assessors, regardless of their qualifications and area of expertise will be able to conduct any of the assessments on any cohort. This would mean that it is possible that a psychologist may be expected to conduct and assessment on a person who has a physical disability which it outside of their area of expertise.
The level of training provided by the NDIA appears to be minimal with providers only required to have their assessors undergo an online training module prepared by the NDIA prior to conducting these assessments on prospective and current participants.

Quality Assurance

The NDIA have provided minimal information about the quality assurance framework they intended to implement as part of the Independent Assessments system. In section 3.11 of the consultation paper “Access and Eligibility Policy with Independent Assessments” the NDIA state that they are developing a quality assurance framework with no details about what this will entail and how they intend to develop the process.
The Tune review6 recommended that Independent Assessment providers should be subject to uniform accreditation requirements that are designed and implemented jointly by the NDIA and appropriate disability representative organisations. We recommend that the NDIA observe this recommendation and ensure that a quality assurance framework is developed in a collaborative way to ensure the IA system meets validity and reliability standards.
Part of a robust quality assurance framework involves implementation of a clear and readily accessible complaints and review process. Under the proposed model, participants do not have the right to challenge the results of the functional capacity assessment nor seek a second opinion, they are unsatisfied with the assessment. They do have the option to make a complaint, but this process has yet to be clarified.

6 Review of the NDIS Act report- Tune review (2020) 7 ABN: 93 9843 83421

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Client and Community Responses

“Independent assessment to be independent has to have no relationship with NDIA and the participant otherwise it’s not independent, it’s NDIA provided.”

“Independent assessments are never independent when the NDIA is paying the Assessors for the reports, they will say whatever the NDIA wants them to say”

“An NDIS assessment should not be performed by a contractor, nor in any ‘quasi’-manner, but only by appropriate registered specialists, preferably with considerable acquaintance with the subject person”

“My condition requires informed and patient assessment over time in order to observe its variations and disabling effects”

“Having unqualified assessors performing this task is dangerous, unfair & quite ridiculous. Many disabilities such as my own, can vary from one individual to the next & asking simple “yes” or “no” response questions to satisfy a criteria-based assessment doesn’t provide an accurate assessment for any individual’s level of disability or their funding or needs”

“I am concerned that having an assessment completed by someone that has no knowledge of a person with complex disabilities will only identify the obvious issues, also that some people with disabilities are not able to sufficiently articulate their problems/difficulties”

Concerns Justifying Disability to Someone Unknown

DANSW received a plethora of responses from individuals raising concerns about justifying their disability to an assessor. Several responses from our survey raised the importance of having a relationship with a treating professional as a crucial element to receiving adequate supports. Further, participants felt that they would be adversely affected by having to undergo an assessment with someone they do not know. People with disabilities spend a significant amount of time and effort developing a network of professionals to adequately address the impacts of their disabilities across several domains. DANSW maintains that primary reliance on an independent assessment undermines the assertion that a ‘fair’ and ‘accurate’ decision can be made. 8 ABN: 93 9843 83421

Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085 www.da.org.au

Client and Community Responses

“Our lives cannot be reduced to numbers by people who we do not know, who meet us for 3 hours on one day in our life.”

“I don’t think anyone, regardless of their qualifications, could build enough rapport to conduct a true & accurate review in so short a time.”

“They might be able to understand my disability, but the issue is whether they can have a better understanding of my disability and its functional impacts than my GP after an individual assessment by an independent assessor. Where is the value added?“

“It is my believe that introducing another layer of bureaucracy to a system where the best advocates for assessment are probably directly involved with the participants. Simply because they know the capacity of the individuals and their disabilities. I believe that someone who doesn’t know the individual and their circumstances is not best placed to make this assessment”

“Our lives cannot be evaluated by a pre-determined universal set of defined questions that scores answers as yes or no, big or little, or on a scale of 1 to 5.”

“An independent assessor, who you do not know, and does not know you, would have no way of understanding the complexities of the varying degrees of the different disabilities and the challenges within each daily function of the person/participant, and for their carers”

Loss of Choice and Control Under Proposed Changes

Alongside the principles outlined in the United Nations Convention on the Rights of Persons with a Disability (‘UNCRPD’), the NDIS Act (2013) was established in accordance with its Guiding Principles to uphold the rights for people with disabilities to “exercise choice and control, and to engage as equal partners in decisions that will affect their lives” [s4(8)]2. It is DANSW’s position is that the introduction of a mandated independent process represents a revision back to a medical, as opposed to a social model of disability, and at its core denies the rights of people with disabilities to exercise choice and control.

DANSW suggests that the introduction of a mandated process disregards the recommendations made in the Tune review as being a discretionary measure, and most importantly fails to uphold the recommendation of the ability for a person to choose their assessor. The proposed aims of the introduction of independent assessments- to provide decision-making consistency and to reduce wait times for decisions- are changes that can be regarded as beneficial to both existing and 9 ABN: 93 9843 83421

Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085 www.da.org.au

prospective participants of the NDIS. DANSW has supported several members of the community who have identified the financial burden of obtaining evidence to assess their eligibility to the NDIS as a key barrier to accessing the scheme. Despite these challenges however, the majority of people surveyed maintained that choice and control is a necessary consideration to the introduction of independent assessments.

DANSW upholds the position that people with disabilities are experts in their disabilities and must retain the right to exercise choice and control in the NDIS.

Client and Community Responses

“The independent assessments are merely yet another example of people with a disability not being respected or heard by the NDIA, or able to determine our own futures. Independent assessments equal loss of dignity and self-determination. Regardless of what the NDIS believes, I am a person, not a number on a balance sheet.”

“I believe myself and other participants of the NDIA should be able to choose their own independent professionals that have a better understanding of individual needs”

Independent Assessments – An Unfair Process

A significant portion of clients and community members identified the roll out of independent assessments to be an unfair process, primarily because it fails to address the heterogenous nature of disabilities.

It is DANSW’s position, that a standardised approach to determining the diverse needs of people with disabilities is insufficient and grossly inappropriate.

At DANSW, we support clients with differing abilities and needs, several of these clients also experience needs across both physical and psychosocial domains, sometimes episodic in nature. Often, we engage with clients who are not able to articulate their experiences in a way that is conducive to the ‘language’ of the NDIS i.e., clients who lack insight/capacity, clients who have difficulty building trust and rapport with services and systems. As a result, several clients engage with DA to have NDIA decisions reviewed through internal and external pathways due to the nature and impact of their conditions not being understood by the NDIA. There continues to be amounting frustrations within the community regarding the inability of assessors to comprehensively capture diverse needs.

DANSW is concerned that if these frustrations already exist, a ‘one-size-fits-all’ approach will likely amplify these issues, rather than providing informed solutions. There is a concern that the 10 ABN: 93 9843 83421

Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085 www.da.org.au

ability for an assessor to adequately build rapport and accurately capture the needs in such a tight time-limited period, is unlikely to provide any benefit to participants.

Client and Community Responses

“Essentially, independent assessments will negatively impact people with a disability because it uses assessment tools that do not respect that the effect of each person’s disability is unique to them.”

“I believe it would cause more injustice, stress and distress to all involved to have independent assessors.”

“It’s hard enough being a person with a disability to get the help we require this would just make everything harder and delay important services for those in need.”

“I don’t see any benefit for the participant to have an independent assessment, but I see a lot of benefit for the insurance company.”

“More assessments are a waste of money, time and valuable resources. People know what they need, and they need assistance, not continual assessments. Please save the taxpayer dollars and only assess where there is a need.”

“The NDIS appears to be moving itself more and more away from actual support and moving into a finance department. Alarm bells should be ringing.”

“The proposed assessment model is just another gruelling, brutal, traumatising NDIA process, which always end for me with a feeling of loss and despair.” 11 ABN: 93 9843 83421

Disability Disability Advocacy NSW Suite 1 Level 2, 408 King Sireet Newcastle West NSW 2302 Advocacy 1300 365 085

www.dd.org.au

Recommendation 1

The introduction of any Independent Assessment arrangement within the NDIS system should be deferred until:

A more comprehensive appraisal of the NDIA’s proposed Independent Assessment model and corresponding legislative changes to the NDIS Act (2013)’ is undertaken, ideally by an independent review body in consultation with the wider disability community.

There is additional opportunity for input and consultation about the proposed changes for current and prospective participants, the disability sector and wider disability community. The NDIA provide more specific details about the proposed changes to the NDIS Planning process.

The NDIA has finalised development of a robust quality assurance framework to ensure the Independent Assessment model meets validity and reliability standards and ensure people have a clear, accessible and responsive avenue to raise concerns/complaints about any aspect of the assessment process.

Impartiality of the Independent Assessment providers can be verified. The NDIA needs to provide explanation about how they will manage the conflict-of-interest issue arising from their contractual relationship with the Independent Assessment providers.

Recommendation 2

We recommend that the NDIA observe the recommendation made in the Tune review® that Independent Assessment providers should be subject to wniform accreditation requirements that are designed and implemented jointly by the NDIA and appropriate disability representative organisations.

Implications for NDIS Access and Planning

J) the implications of independent assessments for access to and eligibility for the NDIS. g) the implications of independent assessments (‘IAs’) for NDIS planning, including decisions related to funding reasonable and necessary supports.

? National Disability Insurance Scheme Act (2013)

® Review of the NDIS Act report- Tune review (2020)

12 ABN: 93 7343 83421

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The NDIA claim that they want to introduce independent assessments to ensure there is fairness, equity and consistency in decision making around access and planning:

“By making the independent assessments free, we are removing the financial burden of evidence gathering, to access and use the NDIS, and making sure participants have the right assessments to assist in the planning or review process.

We want the NDIS to be available for everyone, no matter what their financial situation is.

Independent assessments mean that new and existing participants have the same opportunity to access an internationally recognised, evidence-based and consistent assessment, which provides an up-to-date and complete assessment of their functional capacity.” 9

NDIS Access

Under the current system, the onus is on a prospective participant to provide evidence of their disability to support their request for access. DANSW agrees with the NDIA’s concerns regarding the heavy financial burden of evidence gathering but do not agree that the independent assessment model proposed by the NDIS is the best way to address these concerns of inequity.

Clients and community members feel that it would be a waste of resources in circumstances where a prospective participant already has information from their treating specialists to support their application.

Client and Community Responses

“If they are reassessing people that have already had an assessment and have funding and people that they already work with them and know their needs. It seems incredibly wasteful to employ an independent consultant not to mention the stress addition assessment may have on individuals having to see a stranger just for this purpose.”

“They might be able to understand my disability, but the issue is whether they can have a better understanding of my disability and its functional impacts than my GP after an individual assessment by an independent assessor. Where is the value added?“

DANSW asserts that there are already provisions in the National Disability Insurance Scheme Act (2013)2 to address the financial inequalities that the NDIA have identified with the current system. However, this power does not appear to be commonly put in to practice by the NDIA to assist those seeking to access support under the NDIS.

9 https://www ndis.gov.au/participants/independent-assessments/independent-assessment-q-and/why-we-are- introducing-independent-assessments 13 ABN: 93 9843 83421

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Under s26(1)(a) of the existing legislative framework of the NDIS Act, the NDIA already has the power to fund an independent assessment in circumstances where the applicant would not be able to otherwise provide information from their existing doctors and allied health professional.

S6 of the NDIS Act outlines the types of support and assistance which the NDIS may provide, stating:

“to support people with disability to exercise choice and control in the pursuit of their goals, the Agency may provide support and assistance (including financial assistance) to prospective participants and participants in relation to doing things or meeting obligations under, or for the purposes of, this Act.” 2

S6 does not specify that a person with a disability needs to be a participant under the NDIS in order to receive support and assistance from the NDIS. In fact, there are already areas where the NDIS already exercise its power under s6 to provide support to people with disabilities such as the funding of local area coordination services who are funded by the NDIS to link people with disability to mainstream services, provide information and resources and to assist with applying to the NDIS.

It is possible that an opt-in model could readily be implemented under the current legislative framework. The NDIA already has the power to provide financial assistance to prospective participants to gather evidence about their disability and functional capacity to enable the NDIA to make an Access decision. This readily addresses the NDIA’s publicised goal of reducing inequity around the Access process but without wasting resources, limiting choice and control and uniformly subjecting all prospective participants to unnecessary assessments.

NDIS Planning

The NDIA claim that the proposed changes will “empower participants to exercise greater choice and control over their lives and ensure the NDIS remains sustainable”. They claim this can be achieve if they:

“Change the way we do planning to deliver personalised plan budgets and support participants to have greater flexibility in using their funding in a way that best suits them.

Ensure we’re spending time with participants when it matters the most and supporting them to use their approved budget effectively.”10

10 NDIS 2020, Consultation Paper: Planning policy for personalised budgets and plan flexibility, https://www ndis.gov.au/community/have-your-say/planning-policy-personalised-budgets-and-planflexibility, accessed 31/3/21). 14 ABN: 93 9843 83421

Disability Disability Advocacy NSW Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 Advocacy 1300 365 085

www.da.org.qu

There is a high degree of ambiguity in the framework provided by the NDIA about the proposed changes to the planning process. It is unclear how these changes will in fact result in fairer, more consistent decisions, greater funding flexibility and more support around budget implementation.

Whilst it is hard to make well informed recommendations with such unclear information, we, along with our clients and community members, are greatly concerned that this new system will not result in better outcomes for participants but conversely create further inequities, increase the complexity of an already complex planning system and limit choice and control for participants.

Client and Community Responses

“My condition requires informed and patient assessment over time in order to observe its variations and disabling effects”

“NDIS is already getting reports from specialists who know these clients and have informed/ educated information about their condition. these reports are already being presented to the NDIS. so Why isn’t that enough?! health workers and speech therapist do not have the training or education to assess someone with complex conditions”

“Tt is ridiculous that the NDIS cannot trust health professionals who attended university to specialize in people’s health and disability needs to make fair assessments on people’s needs. Having skilled people do one off assessment will disadvantage the most vulnerable in our communities to those who cannot articulate their needs”

Recommendation 3

The NDIA implement an opt-in Independent Assessment model so that prospective and current NDIS participants can choose whether they wish to utilise the Independent Assessment process to provide evidence to the NDIA about their disability and/or support needs. The model should permit individuals to provide evidence to the NDIA about their disability and support needs from their own treating health professionals exclusively or in addition to the Independent Assessment report. ABN: 93 9843 83421

Suite 1 Level 2, 408 King Street Newcastle West NSW 2302 1300 365 085 www.da.org.au

Considerations for Psychosocial Disabilities

While there is significant diversity among physical disabilities, psychological disabilities warrant a particular focus in the development of an independent assessment process. DANSW’s largest cohort identifies with a psychosocial disability as their primary condition. People with psychosocial conditions are significantly disadvantaged when trying to seek help because of barriers surrounding trust and rapport building and perceived stigma.11 An independent assessor who does not have an existing relationship with the person being assessed, and/or who does not have necessary skills and experience in working with someone who has a psychosocial disability and/or complex trauma may not be best placed to assess functional capacity.12 Whether an independent assessment will be trauma informed and recovery focused: the proposed process of implementation of the model does not align with a trauma-informed, recovery-orientated approach.10

DANSW is particularly concerned that significant disadvantages will result from a failure for independent assessments to accurately capture the diverse needs of psychosocial conditions. There is limited evidence to suggest that a time-limited assessment will provide more, if any, benefit as opposed to a comprehensive assessment. The variability of psychosocial conditions in conjunction with their often-episodic nature brings to question whether any assessment tool can be valid and reliable. The NDIA’s failure to address these concerns warrants urgent attention and review.

Client and Community Responses

“Independent assessment from someone who doesn’t know me like my own doctors do, or my circumstances and my phycological problems would not be fair. It sounds more like a reason to take away services. Before NDIS I had no help at home, my partner had to bear the burden of all of the household duties that I used to be able to do. I suffer with agoraphobia so I would lock myself away at home not participate in my community. With the help of NDIS I have help at home with the things I can’t do. I now have a support worker who has helped me get out into the community. I am so scared if this help gets taken away by an assessor that doesn’t know me and my situation”

“For a person on NDIS for psychosocial disability, I dread the idea of an independent assessment. Meeting new people is a stressor for me. I have had very negative experiences with bodies such as the NDIS and Centrelink that have worsened my condition”

11 Henderson, C., Evans-Lacko, S., & Thornicroft, G. (2013). Mental Illness Stigma, Help Seeking, and Public Health Programs. American Journal Of Public Health, 103(5), 777-780. doi: 10.2105/ajph.2012.301056 12 https://mhaustralia.org/general/members-policy-hub-ndis-independent-assessments 16 ABN: 93 9843 83421

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Summary

DANSW and our community members, maintain that the introduction of an independent assessment process must uphold a flexible and individually tailored response to ensure the diversity of disabilities is fairly and adequately represented.

DANSW welcomes the opportunity to provide additional feedback on the proposed introduction of independent assessments in consultation with the NDIA.

Amanda Brickwood Manager Advocacy

DANSW wishes to acknowledge all our clients and community members for taking time to contribute to this submission through our consultation survey. Your feedback, insights and recommendations were invaluable and greatly appreciated. 17 ABN: 93 9843 83421