SUBMISSION : Denise Redmond on behalf Nardy House Inc.
Plans and the Planning process
Plans are divided into three distinct areas
1. SIL- Supported Independent Living- only concerned with the care provided by
Disability Support Workers handled by the NDIS SIL TEAM
2. SDA- Supported Disability Accommodation handled by the NDIS SDA TEAM
3. Other Supports-everything other than SIL and SDA – this includes therapy
professionals, therapy assistants and Registered Nursing supports. These other
supports are then divided into areas and category items. The covering of funding
holes can be undertaken by using the word “flexible”. The Service Provider is given
funds and if the funding does not cover the actual cost the Service Provider (carer)
makes a decision about what will be given or not: despite the real need. So one has
the money to employ an OT to develop a program BUT then there is no money to
implement the program because the funds are exhausted
The plans are meant to be holistic and look at every aspect of a participant’s care however each distinct area seems incapable of communicating with the other areas. This means that a provider may take all the information to the LAC team and end up with only one part (3) of the Plan developed. Despite placing quotes well before the development date Nardy House has waited months for SDA and SIL approvals. The result on our bank account is a rollercoaster of highs and lows when the SIL and SDA payments are finally approved and outstanding amounts called in.
The introduction of Independent Agency Assessment of our participants is highly untenable. Despite copious descriptions of the disability and its results on individual participant’s really poor decisions and inappropriate funding (less) results from the present NDIS Planners. There is the constant claim that they (NDIS) haven’t received material (from the Service Provider) or they chose to leave out the descriptor because the plan was too lengthy. Nothing prepares the NDIS Planner for the complexity of disabilities that our participants have and the repercussions for their everyday lives. They cannot interpret the material before them and despite there being a complex care team to deal with their SIL and SDA even these team members struggle- mainly because they do not take note of the material sent by specialists or they cannot interpret that material; or maybe they have directions to curtail expenditure at all stages and so disregard real need.
Complexity of care requires a complex set of plan interactions and a further layer of assessment will not better manage these interactions. This will be further waste of money and an outpouring of Agency funds into the hands of (at times) dubious providers www.nardyhouse.org.au
Since the advent of NDIS there have been a plethora of new services selling their wares. It was obvious from the beginning that every spiv and charlatan would crawl out of the woodwork to grab at funds that should be going to servicing of people with disabilities. New office facilities opened by new services offering Plan management etc. are all over the regions but getting to see an actual NDIS officer at the local Centrelink requires the skill and patience of a burglar. Further the use of only NDIS registered personnel sets up a pricing of services that is prohibitive.
I include below some historical material related to the Nardy House experience with NDIS. The experience has not improved. Four of our participants are presently before the AAT because their daily hours of Registered Nursing supports have been cut. One participant requires four hours of RN support daily and she was granted four hours per annum … and this was not a typing error. It was then advised that NHI would be given the RN hours requested BUT the RN had to “train” DSWs to undertake the RN roles during these hours and then the participant would rely on Community Nursing from afar. How training was meant to be done during the hours of direct service delivery is a mystery in itself but it has wide ranging implications. This was a decision made by the LAC team… supposedly in the future to be made by an independent assessor and unchallengeable. These decisions will cost our participants their lives and cuts across industrial “ scope of practice” regulations.
Historical Interaction
SDA Nardy House quoted for SDA for all our clients in October 2016. Kothes, an auditing accounting firm, using the guidelines made available by NDIS at that stage, developed the quote. The quote was called for in 2016 and client documentation shows it was received. A quote was again called for in our clients’ plans in October 2017
A claim was made 9/2018 that quotes were not accepted for SDA and that there was a cap that was put in place by the Rules implemented in March 2017 under NDIS Legislation. Links provided by NDIS officials in correspondence did not indicate any such ruling.
Nardy House is a robust new build catering for people with the absolute highest level of physical need and the base recommended rate provided by the link for a new build for 5 people was over the cap imposed by someone in NDIS on our building. The guidelines do not appear to indicate that quotes are not called for and that design factors are not components of quotes.
The reality is Nardy House is a new build and it is 6 bedrooms. In order to comply with the 5 bedroom limit on new builds for SDA NHI enrolled as a 5-bedroom new build accommodation. NDIS is short of specialized accommodation and has further hamstrung itself in the provision of the same by not acknowledging new builds that 11520 Princes Highway, Qualm, NSW 2550 Phone 02 64938120 Fax 02 64938117 Email: denise@nardyhouse.org.au www.nardyhouse.org.au
were on the design table before NDIS was. This is a political problem and will need to be solved at that level.
There is a further problem. Under NDIS we are a five-bedroom accommodation. Our occupants at 9/2018 received the capped rate of $29595.35. The link shows the base rate of $31193 per annum as a guide for complex high level needs participants (our quoted price developed by Kothes using the NDIS guide is $58000) and two of our occupants at that time were children. They did NOT receive SDA and they received a rental component from the State of about $200 per week. Our children in their first plans received $35000 each in SDA funding from October 2016- July 2017. How this drop in funding is allowable or acceptable is a further political issue of extreme consequence. Further NDIS was not in receipt of the OT reports related to the children in NHI care, at that time, despite NDIS having paid for the OT report; the children were underfunded as the report confirmed. NDIS told NHI that the OT reports would inform “future” funding- funding shortfalls remained unacknowledged, unpaid and owing.
NDIS officers appear to interpret the Rules as they see fit. The development of the SDA quote using the guidelines has changed very little. It still requires the Service Provider to assess their dwelling and put a price on it via quote using the SDA guidelines to advise that quote- which is what Nardy House has done. If there is a Rule that says otherwise it has not been made apparent. There appears no cap set in the Rules or in the Guidelines. Someone in NDIS, who has interpreted the rule “reasonable and necessary”, has set the cap. A Rule for all seasons. A Rule that is open to interpretation by Planners with little knowledge of needs and a great deal of power. A Rule that allows for haranguing and bullying of Service Providers and results in a diminishing of service provision to participants, particularly children.
Quotes for SDA were called for all our participants in 2016. NHI received a manual SDA payment for 5 occupants in July 2017. This was NOT a mistake although the claim is made it was. The payment related to the quote and was the equivalent part payment of the same. The MISTAKE was that NDIS paid SDA for two children that were unrecognized as children. The MISTAKE was further compounded by a calling for SDA quotes for our 3 adults in October 2017- I have their plans available that called for the quotes and that acknowledged receipt of the same. NDIS claimed that the Rules “changed” and were set in March 2017. As noted NHI was paid in July (well after the change and the supposed set practice) and SDA quotes were required to be provided by NHI in October 2017 for our adult clients; also well after the date when quotes were required if the “rules” had changed.
In a letter dated 19/09/2018 I wrote:
NHI needs, in writing from you, the direction that NHI is not to supply a quote for SDA for our clients in October 2018, that NDIS has set a cap on SDA for ALL dwellings and no homes are supplying quotes- including Nardy House. Please quote the explicit ruling that allows NDIS to set caps and not call for SDA quotes- because this ruling as claimed cannot be found. Further in that written direction please state the
amount of that cap and the breakdown components of that cap as outlined in the NDIS guidelines- including the fire-rating levy. Our quote from Kothes gave a breakdown of each of the components asked for- your capped payment, as it follows the same guidelines, should provide the same. Kothes, as NHI auditors, needs a reasonable explanation of where their interpretation of your guidelines went astray and how the original SDA provisions differ as markedly from the first document that a cap is applied arbitrarily (after quote request) and a quote for SDA is no longer required. NDIS determines the level of payment via a cap component applied to all new builds.
Needless to say I did not receive a response
SIL
NHI is aware of our SIL obligations; however the determination of where our RN
costs will be drawn from needs your officers to make up their minds in this regard.
We know what our participants require. RN costs were included in their SIL last year
because we were directed to include them in SIL. If this is now not to be the case
your planners need to inform us. The first year of plan they were a separate item
2016- the plans devised by the Assistant Director of Planning- the second year they
were in SIL as directed by LAC team member, redacted They will be included
in 2018 so please indicate where they are included. RN support is “reasonable and
necessary” for our participants.
Same letter
Denise Redmond CEO Nardy House Inc.
11520 Princes Highway, Qualm, NSW 2550 Phone 02 64938120 Fax 02 64938117 Email: denise@nardyhouse.org.au www.nardyhouse.org.au