Submission: NDIS Consultation Paper: Access and Eligibility Policy with Independent Assessments
### 28th March 2021. \ ### To the Parliamentary Standing Committee,
Introduction: I am an Occupational therapist with over 25 years working in the field of psychosocial disability. I run my own private practice (operational since 2007), and also currently provide Occupational Therapy services to an acute private psychiatric hospital. I am highly experienced and specialise in the provision of person-centred, comprehensive, evidence-based assessment and treatment to individuals with psychosocial disability.
I am writing to express my deep concern at the NDIA’s proposed legislative changes to conduct assessment of NDIS participants through independent assessors using a prescribed format. I fundamentally believe the proposed changes:
- are not evidence-based and take the wrong approach.
- will significantly disadvantage people with psychosocial disability.
Two Key Concerns:
1. The Proposed Independent Assessments do not provide the specialised process which is required in an assessment of a person with disability and their unique needs.
As an NDIS provider since the inception of the scheme, I have been involved in the provision of comprehensive Occupational Therapy functional assessments for participants both in access applications and as part of ongoing treatment and plan reviews. Each assessment involves key Occupational Therapy professional and best practice components of which are omitted in the proposed independent assessment proposal:
a) The Independent Assessors are instructed NOT to gather other evidence – often despite past long-standing relationships with therapists, medical specialists and caregivers who know the person well. There is inadequate time given within the assessment process (estimated between 3-4 hours), to fully understand the context of which a person has already been assessed, treated, and supported (or not supported) to date to manage their disability. Best Practice: Liaison and collection of background information from caregivers, other health providers, medical reports, discussions with schools, workplaces, disability provider services or other stakeholders with the person’s explicit consent. All participants who I have worked with over the years are extremely keen for me to fully understand their needs from a range of different sources, so we can work together to identify the supports which best meet their needs. \b) The Independent Assessment process is prescriptive in assessors using four limited assessment tools, for all participants regardless of their disability, age, or the physical,
Independent Assessments
Submission 349
The psychosocial, neurological, sensory impairments they may experience. The assessment tools prescribed were intended for specific groups of people, such that when used incorrectly, the scoring and results become invalid. For example: \nThe Vineland 3 is not standardised for some of the populations that the Vineland 3 is proposed to be used for in the Independent Assessment process.\nPearson Website (which sells the Vineland 3) has the following information on the Vineland:\ \All Vineland-3 forms aid in diagnosing and classifying intellectual and developmental disabilities and other disorders. With Vineland-3 you can measure adaptive behaviour of individuals with:
- Intellectual and Developmental Disabilities
- Autism spectrum disorders (ASDs)
- ADHD
- Post-traumatic brain injury
- Hearing impairment
- Dementia/Alzheimer’s disease\nThe NDIS is planning on using the Vineland 3 to determine access to the NDIS. Yet the Vineland is not stated to be standardized for this purpose. The NDIS plan on using the Vineland 3 for people with psychosocial disability but this is not one of the Pearson Vineland 3 listed disabilities. Best practice: Careful consideration for the appropriate evidence-based assessment tools to best suit the person’s disability, impairments, age, and presentation.
c) The independent assessment process proposed does not take into consideration the need to adapt to the person presenting in the here and now. Assessors are under specific time constraints to assess and report on a person, regardless of their mental state, environmental barriers, supports available on the day and beliefs about the assessment process.\nFor example: In working in psychosocial disability, mental health specialists need to adapt sessions in response to a person’s mental state. For many, the demand of having to describe their disability and intricate details of their life to a stranger over a 3-hour period, is intensely anxiety provoking and overwhelming. Anticipated responses to this demand include heightened anxiety, panic, dysregulation of emotions, shutdown / dissociation or avoidance. Anecdotal reports from participants who have already gone through the trial independent assessment process describe feelings of overwhelm, exhaustion and humiliation at the gruelling and invasive nature of the questions.\ There has been a complete lack of transparency as to the purpose of the Independent Assessments in determining funding decisions - creating fear and distrust in the process by both participants and professionals. Without the foundation of a therapeutic relationship to hold the space, the assessment process has the potential of becoming a demeaning and potentially damaging experience for participants.\nBest Practice: A therapeutic relationship is based on developing rapport, being responsive to a person’s unique preferences and needs and providing a safe environment through an understanding of trust, openness, and non-judgement.
d) The independent reporting process does not include recommendations for treatment or intervention, thus making the process obsolete in terms of helping participants, caregivers, or their support providers in moving forward in building supports, managing their disability, or building a good, meaningful life.\nBest Practice: Reporting provides a key role in communicating clinical assessment, clinical case formulation, recommendations, and intervention. The assessment process is not done.
Independent Assessments
Submission 349
in of itself, without the clinical reasoning and justification for conducting them, and not for other purposes (i.e.: to justify funding schemes). People are not pawns.
2. The proposed assessments are being conducted by a range of allied health without consideration for their level of experience, areas of speciality or scope of practice. As an Occupational Therapist with over 25 years’ clinical experience in psychosocial disability, I would not deem myself to be the best professional to comprehensively assess someone with a primary physical disability. Neither would I expect a physiotherapist or OT who specialises in physical disability, to fully understand the complexities of someone with a psychosocial disability. And yet, the independent assessments are reportedly being done by any allied health professional, regardless of whether their experience matches the person they are assessing. Despite NDIA documentation stating assessors require 12 months’ clinical experience, recent SEEK advertisements for these positions have been recorded stating ’new graduates are welcome to apply.’ Best practice/Code of Ethics: To always work within scope of practice, with avenues for referring on as appropriate.
Occupational Therapist 28/03/2021