e BRE Carrington
a sa ll Partner healthAbility
Submission to the Parliamentary Inquiry into the NDIS
T 039890 2220 F 039898 8010 E info@carringtonhealth.org.au W www.carringtonhealth.org.au
Level 2, 43 Carrington Road Box Hill VIC 3128
“*
Nitlumbik Community Health Service Ltd
ABN 32 180 310 839 trading as Carrington Health
Carrington
Health - Your Community Partner healthAbility
28/3/21
Submission regarding the Parliamentary Inquiry into the NDIS Independent Assessments
We are a Victorian Not for Profit Community Health Service whom have been providing services to our local community for over 30 years. We offer a broad range of health services, including each of the allied health disciplines, and currently provide these services under the HACC, CHSP, HCP and the NDIS funding streams. We have a long standing history of providing care to the most vulnerable members of our community, in particular people living with lifelong disability.
We would like to submit the following comments, concerns and suggestions to the committee:
a) The development, modelling, reasons & justification for the introduction of independent assessments into the NDIS:
We feel that the concern regarding a proposed conflict of interest/bias in the same allied health staff completing an Access Request assessment, potentially then being the ones to also carry out the recommended treatment is unjust. In our service we offer access requests to clients under the HACC PYP program, and therapy under the NDIS. We offer choice and control to our clients whom are successful in applying to the NDIS; they are in no way bound to continue on with our organisation for therapy, and for those participants whose needs are outside of our scope of care, are actively directed to other better suited service providers. Furthermore, in our organisation, and it would seem more broadly the demand for NDIS Occupational Therapy services far outweighs our capacity. In addition to these reasons, it would also be morally, and ethically inappropriate for clinicians to over prescribe therapy, or seek to retain potential participants, placing clinicians in breach of our AHPRA Code of Conduct, such as 5.2 Wise use of Healthcare Resources.
Clients seeking access requests from our service do often need to wait for a service to be provided. A system that offered another option for people experiencing extended waiting times (such as may be more likely in rural/ remote areas), or having to pay privately for an access request, to seek a fully funded assessment from an independent service of their choosing may be a good addition to the current model, rather than excluding all opportunities for participants to choose for their normal care provider to complete/contribute to these assessments.
It is our understanding that the independent assessments (IA) may take place in the participant’s home or via telehealth. We would strongly recommended that the assessments take place face to face and in the participants home where possible, due to the wealth of additional information that this can provide, for the comfort of participants, and due to the added barriers that completing standardised assessments via telehealth creates.
Carrington
Health - Your Community Partner healthAbility
Further clarity is required regarding the statement that the Independent Assessment will form, ‘one piece in a collection of evidence that the NDIS considers in access & planning decisions’. The nature of other opportunities for input (such as by a participants treating health professionals), has not been outlined.
It is our understanding that part of the ‘functional assessment’ process will involve the assessor observing the participant completing a single task. It’s proposed that the IA’s may be a qualified Occupational Therapist (OT), Speech Therapist (SP), Physiotherapist (PT), Social Worker, or Psychologist. SP, PT’s and Psychologists are not trained in the observation, assessment, reporting and interpretation of such tasks (other than discipline specific exceptions such as a PT observing mobility & transfers, or a SP observing chewing and swallowing). Other than those limited discipline specific tasks (which may not be relevant to a particular participants area of disability), all other areas of observational based functional assessments (ie the completion of daily living activities) remain the sole domain of OT’s. It is our view that it should remain this way, so that firstly the tasks are providing useful information to the IA process, and secondly so that other disciplines are not working outside of their scope of practice, and finally that the role/value of the trained OT is not overlooked.
We are concerned about the removal of choice and control for participants in being able to select workers of their choice to complete their access/ review assessments. Participants with higher levels of disability whom may be looking to access the NDIS, generally will have developed a relationship with an individual clinic and or service providers of their choice. These relationships are often long standing, with trust having been developed over time. The building of such relationships undeniably contributes to a therapeutic relationship in which participants are more willing to freely to discuss their concerns, issues and areas considered private matters, such as continence, difficulty in wiping their bottom after toileting, or an inability to don a bra. The discussion of such items is less likely to happen and may only occur after several meetings between the health professional and participant, sometimes after several episodes of care (spanning several years) before truly sensitive information is revealed. A virtual stranger asking the participant such personal questions is likely to leave clients feeling uncomfortable discussing these areas and may make clients so uncomfortable that the issues are not raised at all; the risk being that potential supports are never identified or offered to clients.
Furthermore we have concerns that shifting assessments to an independent clinician will result in the loss of valuable general information regarding participants. Prior knowledge of the client and the context in which they complete their daily activities (such as an OT known to them generally has), can be of great assistance when participants are considering their own situation and providing answers in standardised assessments. For example in the WHODAS a participant rates that they have no difficulty with a task.
Carrington
Health - Your Community Partner healthAbility
However when prompted by their OT to think further about the task, the participant is able to reflect and report that they have much more difficulty towards the end of the day in completing the task, or that it takes considerably longer/ more energy to complete than may be considered reasonable, and that it impacts on their ability to participate in more enjoyable and meaningful tasks in their day. The resulting answer may be quite different and discussion had provides further valuable information from the participant. It has been our experience that clients’ often need prompting to consider their own situation further when answering assessment questions in order to provide a more accurate answer, reflective of their true situation. Without this layer of client knowledge, an IA may easily take client responses on face value, not know when to delve deeper, and miss pertinent information/needs.
d) The independence, qualifications, training, expertise and quality assurance of assessors:
Recruitment of skilled/experienced Allied Health Professionals (as the NDIS pertains the IA staff will be) is difficult in the current environment. It is imperative that these IA roles are filled by staff with extensive life, and professional experience (in the field of disability), in order to provide the highest quality of assessment for participants, be able to recognise when they may be working beyond their scope of abilities, and when clients may require an alternative approach to the standard IA processes.
e) The appropriateness of the assessment tools selected for use in independent assessments to determine plan funding:
The small pool of (6) standardised assessment tools on offer to the IA process is of concern. OTs are trained and skilled in determining the most appropriate tools for assessment, taking into consideration clients presenting issues, cognition, mental health concerns, the need for other historians, and the limitations of the assessments target population; with this information we draw on a wide range of assessment tools in order to meet each individuals requirements. A wider pool of assessment tools is required to meet the breadth of participants needs than the 6 listed.
Single assessment sessions, are not likely to allow for adequate information gathering for many participants (notably those with intellectual disability, reduced insight, etc). A thorough assessment must allow for multiple perspectives to be included so that a true reflection of the participant’s abilities is obtained; from our clinicians experience sometimes it can take a few sessions (across multiple environments such as home/ school/ work/ our service, etc) to find out what clients’ can and cannot do. Obtaining an accurate picture of the client also often involves corroborating with their carer/family member, etc, to understand any discrepancies between the clients report during interview, the outcomes of any standardised assessment and what may be seen in the observation of functional tasks. It seems unachievable to conduct a thorough and accurate assessment of a client in a single point of contact across one setting.
Nillurnbik Community Heaith Service Lt
ABN 32 180 310 839 trading as C.
Carrington
Health - Your Community Partner healthAbility
g) The implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports:
Further clarity is required on what outcomes will be obtained from the IA process, and how this relates to participants funding. We have concerns that the IA (for all of the reasons previously outlined) such as the restricted range of assessment tools available, and potential lack of functional information/history gathered during the IA process to provide contextualisation for scores obtained, may under represent the clients’ actual needs, and result in underfunding of clients plans.
k) The appropriateness of independent assessments for people with particular disability types, including psychosocial disability:
We have concerns that the IA model will not be appropriate and may be detrimental to participants with particular needs such as those with psychosocial and intellectual disabilities. Our experience has been that often these clients’ require a phased and individualised approach that is sensitive to their needs. The use of the proposed standardised assessment tools may not be possible for example with clients’ with intellectual/learning difficulties who may be unfamiliar with or unable to grasp what is required of them during a standardised assessment.
Please see the client scenarios in the attached CONFIDENTIAL Appendix A, which provides further demonstration of these issues.
Without adequate support and a tailored assessment approach, we have strong concerns that some participants will be placed under significant stress by, or will withdraw from the process, and not receive the support that they require.
We thank you for the opportunity to provide feedback on the proposed IA process, and look forward to hearing any further adaptations to the process that may eventuate or opportunities for further input.
Yours Sincerely,
The Carrington Health & Health Ability Occupational Therapy Teams