Proposed ‘independent’ assessment benefits bureaucracy over NDIS participants

Independent Assessments

Submission 335

in April 9th, 2021

to the Joint Standing Committee on the National Disability Insurance Scheme,

Re: Independent Assessments

I am writing this submission in my personal capacity. My areas of expertise and experience include occupational therapy practice in mental health services (2003-2009), refugee health policy advice (2009-2019), PhD research about the Convention on the Rights of Persons with Disabilities (2019- 2021), and as a family member of two NDIS participants.

Thank you for the opportunity to make this submission and for the extension of time to finalise its content. While not directly addressed, this submission accepts these two propositions that are often in tension:

• Being assessed is inherently stressful and alienating.
• Information gathering and measurement are necessary for determining the allocation of resources.

The key points raised in this submission are:

• Inequality in access to the NDIS and participant funding was expected; further examination of the proposed remediation is required.
• ‘Independent’ assessment, as currently proposed, benefits bureaucracy and adds an additional step or burden most NDIS participants and potential participants face.
• The proposed policy conflates standardised assessments with ‘independent assessors.’
• There’s little evidence supporting the role of ‘independent’ assessors.
• Policy aims could be met by providing standardized functional assessments to treating practitioners.
• Choice from a panel of assessors should be offered where individuals cannot otherwise access functional assessment services.
• Reports & resources exist highlighting needs/good practice when working w people w disabilities who have refugee backgrounds.
• DSS & NDIA/NDIS need facilitate more consultation + active involvement Disabled Persons Organisation before implementing standard functional assessments.

Response to the inquiry’s terms of reference

a. the development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS;

i. NDIS Access and Funding Inequality Is Not Surprising

Research has shown that higher socio-economic groups draw greater benefit from public services, such as education, and that this is because of the individual skills and resources at the disposal of groups, which help them to negotiate and advocate within service systems.ﺡ

in the paper quoted above, Malbon and colleagues described how personalisation schemes, such as the NDIS, are susceptible to ‘inverse care law’. They hypothesise that personalization schemes are more susceptible than other social services as they ‘put an unprecedented emphasis on individuals to navigate the care system and advocate for their own needs and rights’.ﺢ The findings regarding inequality in NDIS access and funding, therefore, are not surprising. We should ot expect that the introduction of “independent” assessors will impact the “inverse care law”. People with education and resources will continue to be more effective at advocating for their needs; they will bring additional support information and professional advocates to the assessment meetings to influence the assessment outcome.

ii. Shift From Person-Focused To Bureaucracy-focused Policy

Despite the promotion of this policy and practice change by the NDIA and NDIS as providing better access to assessment and equality in funding, the proposed remediation of these issues is placing a disproportionate burden on NDIS participants and potential participants while reducing responsibility and burden on the NDIS bureaucracy. The proposed

iii. Cost of assessments need not be a barrier for entry to NDIS

Evidence is required to demonstrate that a potential participant meets the eligibility requirements for the NDis. People without the resources to pay for private assessments often wait on long public health waiting lists, delaying their access to the NDIS. Notably, Tune pointed out in his review that:

Section 6 of the NDIS Act already provides broad powers for the NDIA to provide support and assistance (including financial assistance) to prospective participants and participants in relation to doings things or meeting obligations under, or for the purposes of, the NDIS Act. Taking into account that other supporting material may be required by the NDIA to support decision-making, the NDIA should consider whether there are other areas where increased use of this power would remove cost as a barrier to the NDIS, noting there could be interactions with other service systems, including Medicare rebates.

The NDIA already has the powers (and the government has other leavers) to improve access to assessments required for applying for the NDIS. There is no need to change the NDIS Act to fund asssessments for potential participants.

The cost of assessments is less of an issue for NDIS participants as ‘the costs of additional assessment requirements are generally included for in their plan budget’.’

iv. Diagnostic evidence will still be required

The proposed “independent” assessment is a functional assessment that only provides some of the information required to determine NDis eligibility and funding. It is not clear how the referral process will be simplified and streamlined with the addition of this assessment. The DSS and the NDIA, in their joint submission to this inquiry, stated:

…it is important to clarify that the results of the independent assessment are an input into helping the NDIA determine where a person’s functional capacity lies on a continuum in relation to the wider Australian population…

The above quote states that the ‘independent’ assessments will be ’an input’, inferring other inputs are accepted, even required. The Ndis has stated that:

an assessment of functional capacity for the NDIs will need to capture information on the following:

Independent Assessments

Submission 335

(1) A person’s ability to execute tasks or actions with and without assistive devices and personal assistance in a given domain at a given time.

(2) What a person does and their involvement in life experiences with and without assistive devices and personal assistance, in the context of the world in which they live including all aspects of the physical, social and attitudinal environment.

(3) Whether the environmental factors in a person’s life are barriers or facilitators of their function.

(4) Details of impairments and health conditions/diagnoses⁷ The fourth dot point raises questions. Specific expertise and tests are required to diagnose. These are often conducted by costly specialists who have long waiting lists, i.e., neuropsychologists and autism specialists. It is unclear how the new ‘independent’ assessment process will support access to this expertise and diagnosis—demonstrating further that the balance has shifted from participant- focused to bureaucracy-focused policy and practice by adding a tailored assessment to enable the NDIS to make decisions.

v. NDIS participants maintaining choice and control Personalisation schemes, like the NDIS was modelled on, aim to ‘put the individual at the centre of decision making;’ the goal of personalisation is to provide services which cater to a diversity of social and cultural needs, and enable people to make a choice about the services and supports they receive from governments’. ⁸ While the rhetoric is still very much about NDIS-participant choice and control; by implementing ‘independent’ assessments, the NDIS is taking control by directing a participant or potential participant to talk with a stranger about their disability. Choice and control must be maintained within the NDIS as it supports health and well-being, ‘[t]he connection between choice, control and health is well established in the literature.’ ⁹ But, it is also fundamental to a range of human rights. The information needs of the NDIS-bureaucracy could be met, and choice and control may be maintained by providing an NDIS standardised assessment tools to an NDIS-participant’s or potential participant’s selected treating practitioners to complete. Should an NDIS participant or potential participant not have a treating practitioner, the NDS could offer to fund a chosen practitioner, which may or may not come from a panel of assessors.

⁷ National Disability Insurance Scheme (NDIS), Independent Assessment Framework (NDIS, August 2020) 19. ⁸ Ibid. ⁹ Malbon, Carey and Meltzer (n 1) 1.

Independent Assessments

Submission 335 b. The impact of similar policies in other jurisdictions and in the provision of other government services; i. Job Capacity Assessments The Australian Government Disability Support Pension requires recipients to undergo an assessment intermittently to measure their ‘capacity to work’. This assessment is called the job capacity assessments (JCA).¹⁰ This assessment requires people to provide medical evidence about their impairment before the interview. Geiger and colleagues define the JCA approach to assessment as ‘expert assessment of work capacity’; they highlight that ‘there are longstanding concerns about the consistency and validity – and stringency – of such discretionary assessments’.¹¹ Geiger and colleagues noted the unvalidated rationale to use a government-appointed doctor to undertake these assessments: ‘the assumption [is] that the assessor will be less swayed by their existing relationship with the claimant’ .¹² Geiger and colleagues paper presents models from a range of countries but does not provide a definitive method to undertake work capacity assessments. An OECD report noted that verification of a person’s capacity to work by ‘independent’ medical examiners contributed to ‘growing costs and extended duration of the assessment process.’.¹³ Stafford and colleagues found that the JCA process ‘disables young adults, perpetuates stigma, and creates division between service users and service providers ’.¹⁴ Undoubtedly, it will be difficult for people with disability in Australia not to associate the proposed NDIS ‘independent’ assessment and their experience of the JCA. ii. Other resources A body of work that may be informative is that of Wadding and colleagues. They undertook a comparison of how disability is assessed ‘in the context of a variety of benefits and support schemes across European states’, where assessment ‘was used to determine eligibility for entitlements, services and benefits’.¹⁵

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¹⁰ https://www.servicesaustralia.gov.au/individuals/services/centrelink/disability-support-pension/how-we-assess-your-claim/job-capacity-assessment ¹¹ Ben Baumberg Geiger et al,‘Assessing Work Disability for Social Security Benefits: International Models for the Direct Assessment of Work Capacity’ (2018) 40(24) Disability and Rehabilitation 2962, 2966 (‘Assessing Work Disability for Social Security Benefits’). ¹² Ibid. ¹³ Organisation for Economic Co-operation and Development (ed), Transforming Disability into Ability: Policies to Promote Work and Income Security for Disabled People (Organisation for Economic Co-Operation and Development, 2003) 85 (‘Transforming Disability into Ability’). ¹⁴ Lisa Stafford et al, ‘Interpretative Accounts of Work Capacity Assessment Policy for Young Adults with Disabilities’ (2019) 34(6) Disability & Society 885, 885. ¹⁵ Lisa Waddington, Mark Priestley and Roy Sainsbury, Disability Assessment in European States: ANED Synthesis Report (European Network of Academic Experts in the Field of Disability, December 2018) 6.

d. The Independence, Qualifications, Training, Expertise and Quality Assurance of Assessors;

i. Weak Rationale for ‘Independence’

The assessment process is to be undertaken by an Australian Government contracted practitioner not known by the NDIS-participant or potential participant. The NDIS Independent Assessment Framework specifies:

This would require a health professional with no past and/or ongoing treatment or support responsibilities for a particular person to administer an assessment of functional capacity for Eligibility and Funding purposes in order to improve professional objectivity. ¹⁶

The reasoning behind this is an oft-quoted term from a Productivity Commission report in 2011, ‘sympathy bias’.¹⁷ What is ‘sympathy bias’? The Productivity Commission did not provide a reference for this term but points to medico-legal evidence provided at VCAT in TAC hearings.¹⁸ A quick search of the literature reveals it is not a widely used term. There are many recognised forms of bias in standardised testing – but ‘sympathy bias’ doesn’t seem to have been widely studied or theorised.

The NDIS Independent Assessment Framework used the term ‘sympathy bias’ four times without defining it, referencing the earlier work of the Productivity Commission. The Framework does try to add further rigour to this idea of ‘sympathy bias’ by referencing a single study of 29 participants who were assessed by their support workers more generously when seeking funding than for research.¹⁹ But, as suggested by Geiger and colleagues, the evidence regarding the consistency of government-appointed assessor is inconclusive;²⁰ and it is misleading to suggest otherwise.

ii. Training of Assessors

According to the Productivity Commission, evidence shows that training about an assessment tool produces higher reliability rates.²¹ The Commission provided no rationale for why this training cannot be offered to any NDIS registered practitioner with relevant skills and experience. Assessors should be trained in administering the functional assessment tool as well as trained in working cross-culturally, in facilitating interpreter mediated assessments and in trauma-informed approaches. This is discussed further in section j of this submission.

— References —

• ¹⁶ National Disability Insurance Scheme (NDIS) (n 7) 26.
• ¹⁷ Australian Government Productivity Commission, Disability Care and Support: Productivity Commission Inquiry Report (Volume 1) (No 54, 31 July 2011) 327.
• ¹⁸ Ibid.
• ¹⁹ Roma Guscia et al., ‘Rater Bias and the Measurement of Support Needs’ (2006) 31(3) Journal of Intellectual & Developmental Disabilities 156, 156.
• ²⁰ Geiger et al (n 11) 2966.
• ²¹ Australian Government Productivity Commission (n 17) 323–4.

iii. Quality assurance oversight should include people with disability

An advisory group of people with disabilities should form part of an oversight mechanism for any standardised assessment that determines access and funding. This advisory group should include, among others, representatives from the peak Disabled Persons Organisations.

e. The Appropriateness of the Assessment Tools Selected for Use in Independent Assessments to Determine Plan Funding;

The assessment tools should be strengths-based and rights-based. They should be sensitive to how people experience multiple and aggravated forms of discrimination and its disabling effects. Beyond functional capacity, the assessment tools need to consider rights realisation:

Disability assessments must be underpinned by both a social-contextual concept of disability and a human rights approach. Administrative attribution of disability status based on categorical diagnosis or individual functioning alone is incompatible with this approach.
²² Lisa Waddington and Mark Priestley, ‘A Human Rights Approach to Disability Assessment’ [2020] Journal of International and Comparative Social Policy 1, 1.

i. Opportunities to Review or Challenge the Outcomes of independent assessments;

People should be provided with the opportunity to have the functional assessment outcomes reviewed. A review of the functional assessment is not dissimilar to people’s right within healthcare contexts to request a second opinion. NDIS participants and potential participants should also be provided with a copy of their functional assessment and have an opportunity to correct errors in the assessment. This approach is congruent with Tune’s recommendation about:

…participants having the right to challenge the results of the functional capacity assessment, including the ability to undertake a second assessment or seek some form of arbitration if, for whatever reason, they are unsatisfied with the assessment.

²³Tune (n 4) [4.34(b)]. 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;

My response to this section considers assessments for people with disability from refugee backgrounds.

A family cannot be expected to sit down with a planner and talk about their goals and aspirations and dreams for their child when they’ve just arrived here.

Independent Assessments

Submission 335

A proportion of CALD families have no idea what services available, what their child even needs, what they’re entitled to. It’s just hugely problematic for CALD families. (MS06 SA H)²⁴

There is a lower uptake of the NDIS by Culturally and Linguistically Diverse people than the broader population.²⁵ The low uptake suggests continued access issues for this group. A proportion of the CALD community are from refugee backgrounds; the exact number of NDIS participants and applicants from refugee backgrounds is unknown.

People from refugee backgrounds who access the NDIS have arrived here through the Australian Governments’ Refugee and Humanitarian Program and are now permanent residents or citizens.

The People may have had a disability on arrival or may have acquired a disability post-arrival. In 2012 there was a significant change in the visa health waiver for refugee and humanitarian entrants, enabling pathways for people with a disability to receive protection through the Australian program.²⁶ People from refugee backgrounds may also come through other visa pathways, i.e., family stream. However, they are subject to the regular health assessment that places a high bar on visa grants for people with disability migrating to Australia.

Following the 2012 policy change, settlement and refugee health services noticed that the Refugee and Humanitarian Program entrants more closely reflected the Australian community’s diversity. More people with disability and older people were arriving through the program. Policies and services were not designed to meet the needs of this new demographic. Several reports were published documenting the service and policy gaps and highlighting innovations. ²⁷ These reports provide valuable insights regarding assessments for people from refugee backgrounds. Some key points the reports raised are included in the following dot points, but I encourage the DSS and NDIA/NDIS policy and practice designers to read the reports in full.

• Kostas Mavromaras et al, Evaluation of the NDIS: Final Report (National Institute of Labour Studies, Flinders University, February 2018) ²¹⁷.
• According to the NDis data, as of December 31, 2020, there were forty thousand three hundred ninety-one participants who were born overseas (in non-English speaking countries) or speak a primary language at home other than English. According to this definition nine point three percent of participants were Culturally and Linguistically Diverse. This was out of a possible four hundred thirty two thousand six hundred forty seven total participants. https://www.ndis.gov.au/news/5718-explore-ndis-data-new-interactive-data-tool
• For further details about this policy change see Philippa Duell-Piening, ‘Refugee Resettlement and the Convention on the Rights of Persons with Disabilities’ (2018) 33(5) Disability & Society 661, 670–672
• Federation of Ethnic Communities Council of Australia et al, Barriers and Exclusions: The Support Needs of Newly Arrived Refugees with Disability (2019); Victorian Refugee Health Network, Service Responses for People with Disabilities from Refugee Backgrounds in Northern Melbourne (Victorian Foundation for Survivors of Torture, 2018); Samantha Furneaux and Dina Korkees,‘We Need to Raise Our Voices’: Advice from People of Refugee Backgrounds Living with Disabilities and Their Carers (The Victorian Foundation for Survivors of Torture Inc. 2019, 2019);Philippa Duell-Piening, Response to a Discussion Paper of the Victorian State Disability Plan 2017–2020 (Victorian Refugee Health Network, July 2016).

Regarding People With Disability From Refugee Backgrounds

• Many people from refugee backgrounds will have experienced interrupted access to healthcare before arriving in Australia and almost certainly have been exposed to traumatic events.
• The Australian Government provides settlement support on arrival to Refugee and Humanitarian Program entrants. This support includes registration with Medicare and linking with a general practitioner who should undertake a Health assessment for refugees and other humanitarian entrants.
  ^[28] Comprehensive guidance materials have been developed to support primary care to undertake these health assessments.
  ^[29]
• Disability or activity limitations may be identified at the health assessment. Nonetheless, diagnosis of a medical impairment often requires a range of specialist practitioners.
• Humanitarian arrivals with disability may arrive with conditions that are undiagnosed, not formally diagnosed, or poorly managed. These conditions may or may not be familiar to Australian practitioners. Arrivals may also be an adult that presents with a condition that is typically diagnosed in childhood. Many people also arrive without necessary aids and equipment.
• Newly arrived humanitarian entrants with disability often have many services involved who don’t commonly work together:

    Many health and settlement service providers reported difficulties knowing about appointments their clients had attended, medical tests that had been done, results that had been obtained, recommendations that had been made and services that they had received…This was because of the numerous referrals, long wait lists and the number of different locations and appointments people had to attend in the early settlement period. In addition, informants reported that secondary settlement could create loss of links with services and difficulty in maintaining continuity of referrals.<br><sup>[30]</sup>
  

• People with disability from refugee backgrounds also experience the well-documented challenges of settlement: ‘negotiating access to housing, transport, income support, education and employment in a new country; typically trying to learn a new language; and communicating via interpreting services.’
  ^[31]
• People with disability from refugee backgrounds are not a homogenous group; however, they will likely face more significant disadvantage than other people from refugee

Independent Assessments

Submission 335

Backgrounds. Similarly, people with disability “are far more likely to experience discrimination and exclusion, especially when their identity is layered with a range of characteristics outside the ‘norm’ in terms of disability, gender, minority religious status,…migration“³² and language.

The diminished support network that some individuals may have due to dislocation associated with experiences as refugees can leave families separated or family members deceased; often no extended family are…in Australia to assist in caring for someone living with disabilities or supporting primary carers.”³⁴

Key access barriers for people with disability from refugee backgrounds:

• cost of travelling to appointments (for those without an established diagnosis, multiple visits frequently occur)
• distance between residences and appointment locations
• extended wait times for specialist consultations
• navigating unfamiliar environments
• language obstacles including completing forms written in English
• lack of formal diagnoses/documentation needed for accessing services
• diagnoses requiring assessment over time despite immediate need for assistance
• frequent relocation during early settlement periods leading to placement within different service areas & waiting lists
• delays resulting from reluctance among assessors working with low-English proficiency clients—including children
• newly resettled persons require trust building before disclosing any existing conditions – particularly if they fear visa revocation or community stigma
• Barriers exist regarding self advocacy: There are a number of barriers preventing advocates and the disabled themselves when it comes to advocating on behalf of their own needs. These vary but include language,

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note: Footnotes 32 and 33 refer to Soldatic et al., ‘“Nowhere to Be Found”: Disabled Refugees and Asylum Seekers Within The Australian Resettlement Landscape’. The reference cited is Dosa(2008) at page 514; footnote 33 references Ibid (page 508). Victorian Refugee Health Network, n 27 provides further information at p 45.

Independent Assessments

Submission 335

skills, knowledge and confidence despite the desire and need to advocate individually and systemically.³⁵

• service systems that are not responsive to cross-cultural understandings of the family: Community advisers [from refugee backgrounds] state that the NDIS model does not consider the whole family and the additional needs of families who are newly arrived from refugee backgrounds that impact on family functioning and resettlement.³⁶
• people with disability from refugee backgrounds face more significant barriers in accessing complaint and feedback processes

Recommendations for undertaking functional assessments of people with disability from refugee backgrounds

• clinicians need to be skilled in working cross-culturally and have an understanding of the refugee experience
• the following should be considered regarding interpreters:
• interpreters should be funded for all assessments required by the NDIS to determine eligibility, including administrative support to arrange assessments
• policies and procedures should be in place to assess whether an interpreter is required
• clinicians should be trained in assessing the need for an interpreter, how to access an interpreter and how to facilitate an interpreter mediated assessment
• clinicians should have suitable facilities and equipment to facilitate an interpreter mediated assessment
• choice and control about interpreters should be provided to participants or potential participants: ‘Service providers need to consider religious and cultural backgrounds of interpreters as well as dialect and gender.’³⁷
• interpreters need to be trained in working with people with disability: ‘Interpreters eed experience and sensitivity when working with people from refugee backgrounds living with disabilities and their carers’. ³⁸
• additional time is needed to allow for conversation to be interpreted during the assessment

35 Furneaux and Korkees (n 27) 5. 36 Ibid. 37 Ibid.⁴ 38 Ibid.

Independent Assessments

Submission 335

• developing trust requires attention to processes (humane rather than officious and bureaucratic), allowance of time, and clinical skill:

Accurate and thorough assessments require a trusting relationship between the person from a refugee background and the service provider… This applied especially to disabilities that may not be readily apparent and may carry some degree of stigma such as developmental delay, epilepsy and cognitive impairments… Informants reported some people believed disability was a punishment for wrong-doing. home visits priority access for people from refugee backgrounds assistance with service navigation, case management or advocacy exposures to traumatic events, English language proficiency, literacy and school experience may impact assessment results, as well as undiagnosed medical conditions and developmental delays; but these should not cause delays in providing assessment and necessary supports establish complaint and feedback process about the assessments that are accessible to people from refugee backgrounds

l. any other related matters The NDIA decision-makers need to hear directly from people of refugee backgrounds living with disabilities and their carers, and provide genuine opportunities for feedback and contribution to service and system improvements.

In response to the historical marginalisation and oppression of people with disability, the Convention on the Rights of Persons with Disabilities requires:

In the development and implementation of legislation and policies to implement the present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, State Parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organizations.

39 Victorian Refugee Health Network (n 27) 41. id Kaplan et al., ‘Cognitive Assessment of Refugee Children: Effects of Trauma and New Language Acquisition’ (2016) 53(1) Transcultural Psychiatry 81 (‘Cognitive Assessment of Refugee Children’). furneaux and Korkees (n 27) 5. Convention on the Rights of Persons with Disabilities, Opened for Signature 24 January 2007, 2515 UNTS 3 (entered into force 3 May 2008) art 4(3) (‘CRPD’).

Independent Assessments

Submission 335

This form of participation is not token but requires people with disabilities to be shaping policy and practice. There are significant issues that need tobe addressed regarding equality in NDIS access and funding, and thereare fiscal constraints that need to be considered; nonetheless, this should be worked throughin close consultation and with the active involvement of Disabled Persons Organisations. TheCommittee on the Rights of Persons with Disabilities’ General Comment 7 provides normativeadvice about how this may be achieved. The current process regarding proposed‘independent’ assessments has been widely condemned byDisabled Persons Organisations. This public condemnation strongly suggests the NDIA/NDISand DSS have to do further work in building a shared understanding of what is drivingthe inequality in access andfunding and how they should be remediated.

Thank you for the opportunityto make this submission. Please feel free to contact mefor copies ofthe reports I haver referenced throughoutthis submission.

Yours sincerely, Philippa Duell-Piening

Short Bio: PhilippaDuell-Pieningis a PhD candidate at the Melbourne Law Schoolwith support from theMelbourne Social Equity Institute. Her research primarily inhuman rights law with afocuson disabilityandre refugeerights. Before commencing herPhD candidature in2019, Philippaworked atthe Victorian Foundation for Survivorsof Torture, coordinating theVictorian Refugee Health Network.The focus of Philippaswork was onhealth sectordevelopment and government engagementtoreduce health inequalitiesandinprove accessto healthcare servicesfor peoplefrom refugee backgrounds. Shehas a Graduate Diploma inInternationalLaw, a Masterin Communityand InternationalDevelopment,anda Bachelorof OccupationalTherapy.She has publishedin Disabilityandsocietyabout refugesettlementanddisability andre RefugeHealth ina widerange of journals. Fulldetails of Philippaswork experienceand publicationsmaybefound onher LinkedInprofile.

43 Committeeonthe Rights of PersonswithDisabilities, GeneralCommentNo. 7(2018)ontheParticipationofPersonswith Disabilities,IncludingChildrenwithDisabilities,throughtheirRepresentativeOrganizations,intheImplementationandMonitoringoftheConvention9November2018. 44 PeoplewithDisabilityAustralia (PWDA),‘MEDIARELEASE: LeakedPlanstotoReformtheNDISLeadtoCrisesTalksAcrossDisabilitySector–PeoplewithDisability Australia’<https://pwd.org.au/media-release-leaked-plans-to-reform-then dis-lead-tocrisis-talks-across- disabilitysector/> (‘MEDIA RELEASE’); NationalEthnicDisabilityAlliance(NEDA),‘MediaRelease - N EDAExpressesConcernandOutrageoverLeakedNDISDraftLegislation’(26March2021).