Alison Self Occupational Therapist www.alisonselfot.com.au
28th March 2021
Submission to the Joint Standing Committee on the National Disability Insurance Scheme
I am an occupational therapist with 30+ years of experience working in the UK and Australia in health services, social services and disability services. My experience is in the area of acquired neurological disability and specifically the area of cognitive disability which is often the result of head injuries, strokes, brain tumours, falls, assaults, concussion and whiplash. I am skilled in the completion of functional assessments, which in my experience take an extended period of time over days, weeks and often months to gather the level of detailed information to provide a comprehensive understanding of a person’s functional capacity and need for supports. This is particularly so for people who as part of their disability have poor insight and do not understand, acknowledge, recognise or able to describe how their disability impacts them. It takes time and patience to actively listen understand the lived experience of disability and I implore this committee to do the same and really listen to those with lived experience about the impact of Independent Assessments (IA) on their lives right now and into the future.
The NDIA has proposed using IA as a mean to gathering information to assess eligibility for the scheme. Where a person does not have a team of professionals and supports around them to provide this information, I would agree that there should be the option to choose to participate in an IA to assess eligibility.
Further there is the recommendation that the IA be utilised as part of ongoing planning decisions based on the premise that treating therapists will experience ‘sympathy bias’ towards clients that they know well, however the NDIA has provided no evidence that this is the case. International studies have in fact provided evidence of the potential for harmful outcomes when disability assessment is conducted via a point-in-time standardised checklist by a mandated assessor. These harmful outcomes include increased rates of suicide, increased mental health impacts and increased reliance on prescribed medication (Barr, 2015¹)
The links below are to articles reporting the serious and negative impact for people with disabilities in the UK being subjected to mandated independent assessment.
¹Barr B, Taylor-Robinson D, Stuckler D, Loopstra R, Reeves A, Whitehead M. ‘First, do no harm’: are disability assessments associated with adverse trends in mental health? A longitudinal ecological study. J Epidemiol Community Health. 2016 Apr;70(4):339-45. (https://pubmed.ncbi.nlm.nih.gov/26573235/)
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It is entirely predictable that many Australians with disabilities will experience some level of harm from being subjected to mandated assessments, which they have not been consulted about, are conducted by people they do not know and for which there is no appeal. It is entirely predictable that there will be people who die as a direct result of the impact of these assessments.
There are many opportunities to increase the equity of access and fairness of the funding provided by the NDIS which is the reasoning it purports to be introducing IA’s to achieve.
- Consultation with people with disabilities who are most impacted by the current proposals. It is an insult to say that the government is consulting the disability community whilst at the same time giving out the tenders to providers (who are in the process of advertising for staff with such low pay as to indicate that they are not looking for experienced professionals but rather new grads or very inexperienced professionals further compounding the likelihood of inaccurate assessment and stress for people with disabilities). The United Nations Convention on the Rights of the Person with Disability (UNCRPD), which Australia signed in 2007, and the National Disability Strategy 2010-2020 (2010), emphasise the inclusion of people with disabilities in decision-making, and active participation in designing systems that support them.
- Consultation with the representative bodies of allied health professionals to develop a functional capacity assessment template to ensure that reporting is consistent across current providers and includes all information required by the NDIA in decision making eliminating the need for IA as part of the plan review process.
- Choice to participate in an IA when being initially assessed for eligibility for the NDIS or to have treating specialists and therapists complete the prescribed FCA template. Choice and control being a central tenet of the NDIS Act 2013.
- Provision of compulsory training modules created by the NDIA in consultation with allied health representative bodies, for providers completing FCA to ensure greater consistency of assessment and reporting and increasing the equity and fairness in funding which the NDIA says it wants to achieve.
Thank you for taking the time to consider my perspective. I am happy to be contacted further if required.
Regards
Alison Self DipCOT, BSc OT Occupational Therapist
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