Submission Regarding Independent Assessments in the NDIS

I make submission as a participant in the NDIS with complex needs, the partner and mother of two other participants with different disabilities. Please find my thoughts against each of your points below.

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

I believe that the government has correctly identified the issues of inequity in access to the scheme, planning participation and plan funding. However I strongly believe that the independent assessments are not the correct solution, but just another system that will have the same issues, if not more. Independent assessments maybe funded by the NDIS and thus removes only one of the many barriers to a fair and equitable scheme.

It funds for reports was the only barrier to equity then a simple funding line could have been provided along with proforma reports for existing treating professionals to use. allowing participants’ rights for choice and control. All participants now already have the funding to get these reports and yet the agency is still finding inequity in planning outcomes. Different report template, done by a stranger, is not going to improve this.

The other barriers to entering the scheme and to correct planning outcomes, include and are not limited to: ability to participate in the process, the ability to understand the process, the ability to self advocate and the ability to communicate. The IAs do not address any of these factors. In fact a 1-2 hour planning meeting is now looking like a 4 hour face to face independent assessment. Many people with disabilities will not be able to participate in such a long meeting. As someone with full cognition and high level of education, I find it a scary thought to think I won’t be able to fully advocate for myself over the course of 4 hours. My disability prevents me from being stationary, causes significant pain and prevents me from holding paper, writing and I can only use a computer with voice control. All these challenges combined mean I will be distracted and not able to provide full and appropriate answers. This will inevitably result in a poor outcome. A professional who knows me, would be able to do the report without having to do a full assessment as they would have had consultations with me for the whole year prior.

- the impact of similar policies in other jurisdictions and in the provision of other government services;

- the human and financial resources needed to effectively implement independent assessments;

The cost to effectively get to know someone in a short space of time of an IA means that the IAs will grow in length and reporting time. The agency will not be able to gather the information it needs without the substantial background existing treating allied health professionals have of the participant. This will lead to poor planning outcomes, plan reviews and the agency having to spend more money to fix up poor quality plans.

- the independence, qualifications, training, expertise and quality assurance of assessors;

• Many conditions are rare and are not well understood.

I personally have a disease that is rare and have an even rarer presentation. It’s a challenge for many professionals to understand the impact of this presentation has over several sessions, let alone one IA.

• the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding;

Currently there is a lower limb assessment tool included in the set of tools. However there is not the equivalent for upper limb (the DASH is usually used for this). How can the agency sufficiently assess those who only have upper limb disabilities fairly? why seek further information on those with lower limb challenges and not those with upper limb? This is particularly important when you consider how lower limb disabled bias the world is. Most assistive technology is for lower limb issues and assumes some hand function e.g. wheelchairs, hand controls on cars, accessible bathrooms and it should be noted SDA property categories do not cover those with no upper limb use and working lower limb. Those with upper limb disabilities cannot be discriminated against by not having a true and complete assessment of their daily challenges. The IAs are perpetuating the view that lower limb disability is more important than upper limb, not all people with disabilities have equal rights.

• the implications of independent assessments for access to and eligibility for the NDIS;

• the implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports;

It is not possible with the currently proposed independent assessments to determine funding. The scale of a challenge doesn’t proportionately relate to the funding needed. For example I can walk, however it takes weekly physiotherapy and exercise physiology to maintain this ability. If you simply tick that I can walk how will know what is needed to maintain this function? If I tick I can’t drive, how will you know that a modification to my vehicle could allow me to do this independently again?

IAs only give an indication of function and functional challenges. They give no quantitative or qualitative measures of supports needed as a result and thus provide no basis of evidence for funding supports.

-the circumstances in which a person may not be required to complete an independent assessment; opportunities to review or challenge the outcomes of independent assessments;

• 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;

• the appropriateness of independent assessments for people with particular disability types, including psychosocial disability; and

• any other related matters

• Dealing with the ever changing NDIS policy,
• coming to terms with your disability,
• managing significant funds and staff similar to that of a small business, alcome at a physical and psychological cost to people with disabilities and their families.

We cannot be forced into even more traumatic situations where we must discuss our challenges with a stranger in even more detail than we do today.