Submission re NDIA’s plan to provide Independent Assessments
Ideally the NDIA would be run as an agency that facilitates the well being of the participants and their families through respect, honesty and consultation.
Participants deserve to be assessed by competent, experienced practitioners with extensive, diverse experience in disability, particularly in the area of disability of the participant. The proposed changes of Independent Assessments resemble the adversarial relationships we see in modern insurance claims. In general insurance, this is a very sad trend. In disability this proposed approach to assessments has the potential to simply disempower those with a disability, making them feel unsupported, disrespected and second class citizens.
The introduction of the NDIS was visionary and widely appreciated. It levelled the field. Everyone with a disability could ask for reasonable supports and generally be given what was appropriate. Families where there is a person with a disability have huge challenges but with the introduction of the NDis, the financial challenge was less. They still often carry huge burdens, being the primary carers of the person with the disability. Funding also meant that families could afford to choose who worked with them, able to find experienced therapists rather than rely on inexperienced but well intentioned help from charitable organisations.
I share the overarching aim of the National Disability Insurance Scheme (NDIS) across Australia that is not impacted by a participant’s location. That is a commendable aim but equity in access to the NDIA is impacted by many more factors which cannot be controlled by a tick of the box assessment. And it seems that to establish a ‘consistency’ across disability assessment the NDIA proposal is suggesting that access be determined by a system that loses many of the good qualities of the current system yet doesn’t truly address the real challenges which occur at present.
My background
I am a Speech Pathologist of over 40 years’ experience. For the last 30 years I have worked in Disability. In the early years we begged for support from all sorts of charities for even basics like wheelchairs etc. We greeted the NDIS with joy, as did our clients as we all felt their journeys would be easier, and thankfully, they were.
in 2005 I undertook post graduate education in the USA where I specialised in Autism, with qualifications in Relationship Development Intervention. I have worked almost exclusively with people with Autism and their families ever since in my private practice. My work is wonderfully satisfying as I see my clients grow and develop to a level of functioning in the World that they and their loved ones perhaps did not dare to even dream of. This development is a result of parent training and counselling which means the empowered parents can work with their family member in ordinary life situations, in their real life, not a clinic. When necessary, the person with Autism may work with me but that is to tackle specific problems such as language development and on rare occasions, to support what is being done by the parents. This is a research-based approach that maximises the parental impact.
Independent Assessments
Submission 334
minimises the need for intervention by others who can generally only be parental substitutes. “The new NDIS Access and Eligibility Policy will put the focus back on the individual and their function and support needs”. It is difficult to understand how the focus is not upon the individual, their function and their support needs in the NDIA. The clients are supposedly the centre of the functioning and funding of the NDIS. But there are difficulties in the present system that could and should be addressed before this wide ranging and problematic ‘fix’ is applied. Many others have made pointed submissions as to why the suggested method of ‘independent assessments’ falls short of the needs of the participants who use the NDIS and I simply need is to say that I support the opposition to this blanket method of assessing needs. It cannot truly and fairly assess the reasonable and necessary needs of the NDIs clients in a true and fair manor. But that has been argued extensively in many of the other submissions.
The present assessment system. The present system of assessing the needs of NDIS participants is flawed and before reinventing the whole system, opening the way for new problems which have no doubt been outlined in many other submissions, it would be prudent for the NDIA to address current problems. Many participants and their families are dissatisfied with their interactions with the NDIS. I watch as families approach their annual assessment with anxiety and dread. What follows is what I feel is reflected to me by the participants and their families.
The Concerns:
a) Secrets
There appears to be a culture within the NDIA that what is done within the Agency is to be secret. Clients have been told things about their plans but also told that they are not supposed to know this. NDIS staff often prefer to remain anonymous. There appear to be guidelines for how much funding can be given for certain disorders but these are unknown outside the NDIA. This creates an adversarial atmosphere which is detrimental to the relationship and sometime to the mental health of the client or their family members. Clients also feel that there is scant guidance on what is needed in their annual funding application. Some respond by preparing huge submissions, others barely provide anything, because they have no guidance on what is truly needed. b) Poorly trained Local Area coordinators
The Education and quality of Local Area Coordinators must be addressed. Some participants are lucky and their LACs not only have a sound knowledge of services available but also have the ability to listen to the needs
Independent Assessments
Submission 334 c) Poorly trained Planners
The Qualifications of Planners are unknown to participants but there is a feeling that many come from the general insurance area where they have an adversarial attitude. It would reassure participants if they were able to be reassured and see evidence of knowledge of disability in its various forms within Disability. d) Feedback
to many participants, the NDIS feels like a big black secret box. Extensive proposals for funding are made by the participants and their families yet feedback is minimal. This does not allow the participants and families to easily accept their funding level nor to learn how their next application may more readily reflect their needs.
A redacted seems to be no guidance about how many reports a participant should submit which can result in participants spending huge amounts of money. Perhaps report numbers could be limited.
Poor guidance to therapists for input results in 20+ pages from some, which are probably not read to a simple one-page opinion from others. Some offer standardised tests; their need is not broadcast. Guidance again would be helpful.
e) Frequency of plans
Annual plans are usually not necessary. In general, clients’ diagnoses and circumstances do not change annually. It would be reasonable to assume that a competently designed plan would suffice for a number of years. This would save money on acquiring reports, l safe the NDIA from the expense of revisiting plans so often and save the family from the distraction and anxiety of having to go through the planning process so often. f) Lack of resources in far flung places. covid has shown us that we can use the internet to work together no matter where we are. Some clients need hands on therapy and assessment but that will not change with the type of assessments proposed at present. Distance clients have found that they can be guided and supported at a distance by therapists who are quite remote from them. Personally I have clients in 5 states and work successfully with them. There is no need for an ‘equal plain’ to address this supposed problem which does not really exist. g) Anxiety
The secrecy, unknown requirements, lack of communication, poor training of staff and frequency of assessments add to already difficult and challenged lives so that participants relate to the NDIS from a background of anxiety.
Independent Assessments
Submission 334
If the NDIA is there to improve the lives of people with disabilities , it must be aware that interacting with the NDIS, can in itself, be detrimental to the lives of those coping with disability. I suggest there is much that can be improved within the NDIS, at relatively low cost, which would achieve a much better life for those with disabilities without subjecting participants to a new assessment system which will, no doubt, have within its’ structure, further challenges those with disabilities will need to deal with. Thank you for the opportunity to offer my thoughts.
Jo Fokkes Senior Certified Practicing Speech Pathologist Relationship Development Program, Certified Consultant
The NDIS gives people choice and control over how their disability related services and supports are delivered so that they can pursue their goals
The current access process requires people with disability to seek information about the impact of their disability from a variety of health professionals, including doctors and specialists. This can often involve long wait times. Appointments to see doctors and specialists can also cost a lot of money. Access to the NDIS should not be determined by a person’s ability to gather and pay for enough evidence to demonstrate reduced functional capacity. We estimate Australians with disability are curently spending between $130 million and $170 million per annum on assessments associated with accessing the NDIS.
This has impacted on participants across the NDIS, and in particular, those with psychosocial isability, due largely to the wide variability in assessment tools used to capture information on mental health conditions. Some assessment tools do not provide enough of the information that is eeded, which makes it difficult to achieve consistency and equity in decision making.
. This means the ability to be involved in different areas of life like home, school, work and the community and to carry out tasks. It also considers other factors in a person’s environment that may pact their day to day life.
This can be seen in the proportion of the population (0-64) receiving NDIS support with results that differ significantly by state and territory. NDIS data from our latest Quarterly Report, highlights inequity around accessing the NDIS depending on where a person lives. Population surveys on disability undertaken by the Australian Bureau of Statistics do not support these levels of difference.
As required under the NDIS Act, we need high quality and consistent information on a person’s unctional capacity so that we can make accurate and timely decisions. This includes environmental fctors which affect an individual’s support needs. The quality of the information needs to be sistent to enable fairer decision making processes. Independent assessments will provide this tconsistency.
Independent Assessments
Submission 334
The Training of planners across all of NDIS. Feedback to those who write reports if insufficient information. Inconsistencies across planners does not reassure there will be consistency amongst the independent assessor. No feedback to those supplying reports; all guesswork. Train the existing rather than reinvent the wheel with poorly qualified assessors. We are working to:
- Replace processes developed during transition with more consistent and fairer approaches to determining NDIS eligibility.
- Introduce independent assessments to better understand an individual’s functional capacity and environment, to support objective and fair access and funding decisions.
- Change the way we do planning to deliver personalised plan budgets and support participants to have greater flexibility in using their funding in ways that best suit them.
- Ensure we’re spending time with participants when it matters most and supporting them to use their approved budget effectively.
Independent assessments will be done by trained experts, for example occupational therapists, physiotherapists, psychologists and other health and allied health professionals. Medical diagnosis should not need to be repeated unless the medical condition changes so no need to wait for those appointments. Initial assessments perhaps could be independent but early intervention/medical assessments are sometimes available. Assess at least every 5 years.
The principles of this policy are that people with disability experience an access process which upholds the intent of the NDIS Act and associated international conventions. This includes that the process will: a) Be accessible, holistic and strength-based, recognising each individual’s life circumstances and environmental factors. b) Involve the individual in decision making processes that affect them to the fullest extent possible, and supports them to make decisions for themselves. c) Be based on nationally consistent tools and allows for approaches to be tailored to individual needs. d) Acknowledge and respect the role of families, carers and other significant persons in the individual’s life where applicable. e) Be inclusive and have safeguards that ensure the individual’s respect and dignity are upheld. Local Area Coordinators – training Claire, why have independent assessor p14 suite of assessment tools
Independent Assessments
Submission 334
Assessments are independent, meaning they are not conducted by a participant’s treating health professional or by employees of the NDIA. This is consistent with advice from the Productivity Commission about the way the NDIS should work.
Jacob page 17, what a tragedy he was not encouraged to develop his skills before he lest school so he could have been better prepared for an independent adulthood. The assessor factor.
Someone who knows them well can attend. Then why not listen to his therapists etc who are more qualified.
Wonderful … of small independent practitioners whohave worked for many years to establish fantastic skills in their areas of specialty. Why pay these big organisations when we have such skilled professional
Scripts Independent assessments are mostly about having a structured conversation and include a number of specific questions in order to complete the assessment tools. At the beginning of the appointment, there will time for the assessor and applicant to meet and to get to know each other. This may include sharing things you do every day.
Interrredacted: s24tion for Autism
The following bullet points describe how this process works:
- Tools used as part of the independent assessment process ask about how the person manages without any help, how they manage with help and/or supports, over a period of time, not just on the day of the appointment. The assessment tools use a combination of interactions, discussions and questionnaires that take into account different settings and different times. This is so we can find out what good days and bad days look like.
Vinelanredacted: s37not appropriate to Australian consitions, ABAS – is better.
In some circumstances other information may be needed to determine if a person is eligible for the NDIS. If required, we will request this information. We will consider all evidence provided in relation to impairment and the permanence, or likely permanence, of that impairment. Where appropriate, this information can be provided by the applicant’s treating health professional. Clinical information and reports from the applicant’s usual treating health professional can provide an understanding of the supports or interventions that have and have not worked in the past, as well as any barriers and proposed supports for the future. Independent assessments provide a holistic view of functional capacity at a point in time, and do not replace the clinical relationship and expertise that are important for achieving outcomes and supporting a participant throughout their life.
The suite of assessment tools used in independent assessments will enable us to make fair access decisions for the majority of people. There may be times when it will be necessary for delegates to request other specialised reports and assessments, ask more questions, or source extra information. Further information about the use of additional information in the planning process is provided in the proposed planning policy for personalised budgets and plan flexibility consultation paper.
Regardless of the access request outcome, all applicants will be provided with both a summary of their independent assessment results and an explanation of the access decision. Guidance to help applicants understand their independent assessment results will also be provided.
Applicants will continue to be able to access the information we hold on them via the our Participant Information Access Scheme.
Independent Assessments
Submission 334 The results of the independent assessment will be provided to the access delegate and will inform decisions about the applicant’s eligibility to access the NDIS.
We will use the results of a person’s independent assessment to determine whether they have sustantially reduced functional capacity to undertake any of the six activity domains in the NDIS Auct. This will include consideration of environmental factors, the presentation of their condition (i.e. episodic) and whether they were having a typical day for them. What about growth?
3.11 Appeal rights and complaints
We will not be changing the review process. The access decision remains a reviewable decision and the applicant can request an internal review and then appeal the decision at the Administrative Appeals Tribunal (AAT).
Independent assessment results themselves will not be directly reviewable by the AAT. This is because independent assessments are not a decision the delegate makes under the NDIS Act. Instead, the delegate will request that an applicant has an independent assessment for the purposes of informing an access decision under the NDIS Act.
a. Application of independent assessments for people with disability who have behaviours that require a complex response. 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 in dependent assessments;d. the independence, qualifications, training, expertise and quality assurance of assessors; e. the appropriateness of the assessment tools selected for use inindependent assessments to determine plan funding; f. the implications of independent assessments for access to andeligibility for the NDIS;g. the implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessarysupports;h. the circumstances in which a person may not be required to completean independent assessment;
Independent Assessments
Submission 334 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; andl. any other related matters
at present many Autistic clients have access to an informed, thorough assessmentby experienced medical and therapy staff who know the client on good days andbad, who know their challenges and their abilities and know their potential. This is a treasure of wisdom which this scheme appears to dismiss and wish to replace withunderexperienced, newly graduates who have no density of experience. In seeking equitable access , why not foster the development of support teams behindindividuals who do not have them at present? The Covid Pandemic has shown us that many distance clients can be supported by qualified experts via the internet. I myself see clients in 5 states because they chose to seek out expert help, not available in their own area.