NDIS Independent Assessments Concerns for Participants with Cognitive Impairment

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[♦] Office of the Public Advocate

    Safeguarding the rights and interests of people with disability

                                                  Wednesday 25 November 2020

OPA POSITION STATEMENT

 NDIS Independent Assessments

   The Office of the Public Advocate stands with the disability advocacy sector in
    requesting that the NDIA reconsider its proposal to introduce independent
    assessments.

   The NDIA has said independent assessments are to be part of the access process in
      early 2021. The assessments will at first be used to determine the eligibility of people
     applying for access to the NDIS as well as to determine reasonable and necessary
     supports to be included in a participant’s plan.

   The assessments will be fully funded by the NDIA but will be undertaken by NDIA-
    approved professionals in an effort to ‘deliver simpler, faster and fairer approach for
     determining a person’s eligibility’ to NDIS supports. It is expected that by the end of
    2021, the use of NDIA-approved independent assessors will be a requirement when
     undertaking access and plan review processes for all participants.

     Like many other disability advocacy groups, OPA is opposed to the direction being
    taken by the NDIA. OPA considers further consultation with people with disability and
       disability representative organisations is essential before taking this step. This
    should be done in addition to the pilots currently underway. The consultation and
     review process must focus on ensuring that all participants are enabled to exercise
     choice and control in the pursuit of their goals, as is required by the NDIS Act.

   The NDIA released its Participant Service Charter, which has five principles for
   engagement with participants. The Charter is a pledge by the NDIA to empower
    people with disability and to be respectful of participants by ‘recognising the
      individual experience and acknowledging that participants are experts in their own
        lives’. In OPA’s view, the NDIA’s proposed process for independent assessments
     contradicts these principles.

     Authority must remain in the experience of the person with disability, not a third party
   who does not have a direct connection with that person’s experience.

  OPA is concerned that the approach proposed by the NDIA will disproportionately
    impact participants and prospective participants with cognitive impairment. This
    stands at odds with the scheme’s ethos of providing people with disability with

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‘choice and control’ over their NDIS supports. Furthermore, OPA is concerned that the independent assessments could:

  • further entrench the insurance-based cost-control approach where assessors are biased towards reducing the supports a participant can access
  • undermine and devalue existing relationships that participants have with professionals of their choosing, who are likely to have a greater understanding of their individual circumstances and functional capabilities
  • serve to depersonalise participants by moving away from individualised and person-centred approaches
  • disadvantage participants who may not have supports available to them during an assessment or to advocate on their behalf
  • fail to incorporate appropriate engagement strategies that may be required to develop a shared and true understanding of individuals with cognitive impairment or complex needs
  • lead to a further thinning of the market of allied health professionals
  • lack transparency and accountability towards participants as to how decisions are made.

OPA supports the many calls being made upon the NDIA to revise its proposal of independent assessments to ensure that the NDIS delivers full benefits to all participants. The NDIS should, at every step of the way, deliver on its commitment to engage people with disability as equal partners in decisions that will affect them and recognise participants as experts in their own lives.

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