RECOVERY IN MIND
OCCUPATIONAL THERAPY
Joint Standing Committee on the National Disability Insurance Scheme
Bianca Parsons (Recovery In Mind)
Occupational Therapist (AHPRA and NDIS registered)
BSocSc(Psych) GD(Psych) MOT(Prac)
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Joint Standing Committee on the National Disability Insurance Scheme
NDIS Independent Assessments
Introduction and Background
Recovery In Mind is a trusted Occupational Therapy Service, with a mission to empower individuals to experience optimal mental health and live fulfilling and meaningful lives. Bianca Parsons, founder and principal Occupational Therapist, has studied and worked in the mental health field for over 15 years. She has completed undergraduate and postgraduate degrees in both Psychology and Occupational Therapy, is a published researcher, registered with the Australian Health Practitioner Regulation Agency, a member of OT Australia and an NDS-registered therapeutic provider.
Role of Occupational Therapy
The role of Occupational Therapists is to enable clients to be as independent as possible and participate in meaningful and purposeful activities. Occupational Therapists are highly skilled in assessing client’s functional capacity, making recommendations and delivering interventions to enable capacity building. Due to the significant role and specialised training that Occupational Therapists have in measuring functional capacity, they provide services to many National Disability Insurance Scheme (NDIS) clients.
Purpose of submission
In August 2020, the Minister for the NDIS, Hon. Stuart Robert MP announced several proposed changes to existing NDIS arrangements. One of these changes was the introduction of independent assessors, to determine eligibility and access to the scheme and for NDIS plan reviews. The purpose of this submission is to highlight the concerns that Recovery In Mind has in relation to this proposed model. There are grave concerns for our vulnerable client groups who may not be able to advocate for themselves or for those who have no informal supports. These concerns have been echoed amongst many other Occupational Therapy and advocacy groups across the country.
Concerns with Independent Assessors
The Government commissioned an independent review of the NDIS Act. This review was carried out by retired public servant, David Tune and delivered to the Government in December 2019. Whilst reforms are welcomed, of particular concern to Recovery In Mind, is the rollout of Independent Assessors which was not a recommendation of the aforementioned Tune review.
One of the most concerning issues with the proposal of independent assessors, was the lack of any consultation with Occupational Therapists or OT Australia in the development of this model. This is of significant concern given that Occupational Therapist’s core skills is functional capacity assessments. We note that the NDIA maintain that independent assessments are not ‘functional assessments’, however they are both measuring the effect of disability and functional impairments, using tools designed to measure functional impairment. Recovery In Mind endeavours to bring to your attention to the following issues. These are written predominately from a psychosocial perspective:
Concerns with proposed Independent Assessor Model
Proposed assessment tools and suitability of assessors
Whilst the list of proposed assessment tools includes several regularly used and psychometrically sound assessments, there is no ‘one size fits all’ approach. These tools were not designed to be used in the way they are being proposed. They were not designed and developed to be used as a scoring system to determine funding. There are also many significant, psychometrically sound, assessment tools that have been omitted from this list.
Individuals with mental health conditions often experience fluctuations in their symptoms and there are a number of variables that impact on this. An appropriate assessment would be conducted over several occasions and the assessing therapist would choose assessments from an extensive, available suite, using their professional judgment and tailoring these to the individual needs of the client. These standardised assessments, on their own, allow no room for interview or exploration of ‘context’ which is vital in capturing the full picture of a client’s functional capacity. For example, two participants may score the same as each other on the standardised assessments, however require significantly different types of supports to enable social and economic participation.
These assessment tools can only be used by therapists with significant experience. Interpreting these assessments in a holistic manner alongside other assessments, observations and interviews, using clinical reasoning and experience in the field is a vital requirement. The proposed changes indicate that the assessment will be conducted on one occasion/meeting using standardised measures and an observation of a client performing a task. However, it is imperative that task observation/activity analysis only be completed by Occupational Therapists. This is a core skill of Occupational Therapists and it is concerning that they may be
Trauma Informed Care And Psychosocial Disability
Trauma informed practice is a strengths- based approach grounded in and directed by an understanding of the neurological, biological, psychological and social effects of trauma and their prevalence in individuals accessing mental health services.
One of the most concerning issues with the proposed Independent Assessor model is that there is a significant risk that these mandated, point in time standardised checklists may lead to harmful outcomes in some situations. This includes re-traumatisation, increased risk of suicide and increased reliance on medications (Barr et al, 2015). In turn, this will then impact the public mental health system and may result in increased acute hospital admissions and pressure on the health system as a whole.
Occupational Therapists with experience in psychosocial disability are trained to recognise the impact of trauma on an individual’s mental health. The expectation that a participant meets with a mandated assessor to compete standardised assessment tools carries a significant risk and may lead to distress and re-traumatisation. Recounting personal stories and highlighting deficits can exacerbate symptoms. Only highly skilled therapists with knowledge and training in trauma informed care should be conducting assessments for participants with psychosocial disability. It often takes time to develop a therapeutic relationship and for a participant to feel comfortable and build rapport with their therapist. There is no possible way that this can be completed in a once off, assessment. Participants with a psychosocial disability should have the right to select therapists who they feel comfortable with. This is imperative for the safety and wellbeing of participants.
Summary
Given the aforementioned concerns regarding the introduction of independent assessments, we ask that the NDIA reconsider the roll out of this model and seek further consultation around alternative models with skilled Occupational Therapists and their respective government bodies including OT Australia and AHPRA. We are deeply concerned for the wellbeing of people with disability and the significant risks that the independent assessor model poses for people with disability in our community.
Bianca Parsons Occupational Therapist (AHPRA and NDIA registered) BSocSc(Psych) GD(Psych) MOT(Prac)
References
Barr, B., Taylor-Robinson, D., Stuckler, D., Loopstra, R., Reeves, A. (2015). ‘First, do no harm’: are disability assessments associated with adverse trends in mental health? A longitudinal equological study. Journal of Epidemiology and Community Health Vol 70 (4). BMJ Publishing Group Ltd.
Rosamond, H., Glozier, N., Fortune, N., Dyson, M., Gilroy, J., Bundy, A., Llewellyn, G., Salvador- Carulla, L., Lukersmith, S., Mpofu. E., Madden, R., (2015). In search of an integrative measure of functioning. International Journal of Environmental Research and Public Health Vol 12 (5).
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