INDEPENDENT ASSESSMENTS (IA)

Referencing …

NDIS Consultation Paper of Nov 2020, V1.0 “Planning Policy for Personalised Budgets and Plan Flexibility”

We are the parents of a 24-year-old female whose primary disability is recorded as Cerebral Palsy. She also has significant Intellectual Impairment, is non-verbal and requires 1:1 support for all daily living and community activities.

Prior to NDIS commencing in Queensland, we were self-managing her funding package provided by DSQ (Disability Services Qld). Under NDIS, we have continued to self-manage our daughter’s funding package.

In the following pages, I have detailed two topics of specific concern that arise from the NDIS Consultation Paper referenced above.

However, our overriding concern is that shared by almost every NDIS participant …

• How can an Independent Assessor possibly capture the FULL picture of a person’s life and their individual needs, or their individual aspirations in such a short timeframe?

In respect of our specific circumstances as Aging Informal Carers…

• My wife and I do not believe that a total stranger can come into our home for a short time and properly comprehend the impact that the constant caring role has on both the physical and mental health of aging parents.

• If the Independent Assessor does not understand or accurately reflect this aspect of the participants “Environmental Factors” in their assessment, then the whole basis for the NDIA ’s funding decision will be flawed.

Thank you for convening this Committee Enquiry into these important changes.

Yours sincerely

Topic 1 – Accuracy of Independent Assessments (IA)

Concern: That the information contained in an IA presented to the NDIA Delegate may be factually incorrect or incomplete.

Context: That assessors will from time-to-time misinterpret what is said, mistakenly record details, confuse clients or press the wrong button and the like … the human error factor.

Many families, including ourselves, have received plans from NDIA Delegates that have their child’s name or other relevant details wrong in various places… perhaps confusion, impact of heavy workload or the result of "lazy or careless" cutting & pasting from other participant’s plans!

At higher risk for error is an assessor’s description of a participant’s "environment"… particularly as it pertains to the informal carers current and foreseeable capacity. This higher risk is because of the individual assessor's own subjectivity or misinterpretation in understanding an informal carer's capacity.

Impact: An IA is the basis or foundation report for funding decisions. Therefore, if the IA is not correct, then the Delegate’s funding decisions will be unsound.

Recommendation:

That participants &/or nominees have access to the written IA BEFORE the delegate develops or drafts the budget and plan. Any inaccuracies can then be highlighted prior to a budget being drafted.

Benefits: Less Reviews or AAT actions needed,

Less participant and family stress &
More consistent and fairer outcomes (the main objective of these changes)

Reference: Page 13 of the NDIS Consultation Paper of Nov 2020, V1.0 “Planning Policy for Personalised Budgets and Plan Flexibility” includes ONLY two circumstances where a change to the Draft Budget will be made. Neither of the circumstances include an inaccurate IA.

Topic 2 - Release of Funds – periodic release of funds

Concern: That the proposed periodic release does not take account of normal or predictable activity peaks and troughs. It is too restrictive and will create unnecessary admin for many clients and NDIA staff.

Context: Expenditure of funds can vary enormously from month to month and even quarterly depending on a range of factors such as…

           -   Public holiday clusters at Christmas and Easter
           -   School holidays and increased support needs to support working informal carers
           -   Closure of therapy services at peak holiday times
           -   Significant medical interventions for either participants or their informal carer
           -   Irregular STA (Short Term Accommodation) expenditure

Impact: As a self-manager for our 24yo daughter’s package, it would be an administrative burden and a huge time-wasting exercise to have to continually contact “someone” in the NDIS to try and release extra funds because of these predictable peaks that don’t fit neatly into a regular monthly or quarterly cycle. This is particularly the case if the plan commencement date coincides with a peak activity time and there has been no opportunity to accumulate “rolled-over funds”.

Recommendation:

             1. That Delegates, at the plan meeting stage, have the discretion to release six
        months of funding to participants &/or nominees who have a past track record of
           responsible budgeting.

             2.  That all participants receive SMS alerts when 50% and 75% of their periodic
          funding has been spent … similar to Telco’s with mobile data & phone plans. This
              will help mitigate over-expenditure by some who may not have good budgeting
                skills.

Benefits: Less potential disruption to support rosters due to monthly/quarterly funding limits, Less participant and family stress & Less workload for NDIA staff processing the release of funds for peaks and the like

Reference: Page 20 of the NDIS Consultation Paper of Nov 2020, V1.0 “Planning Policy for Personalised Budgets and Plan Flexibility” indicates funds will be released monthly or quarterly basis, with the NDIA Delegate having that discretion.