Inquiry into Independent Assessments Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Parliament of Australia
Email: ndis.sen@aph.gov.au
30 March 2021
RE: Joint Standing Committee on the National Disability Insurance Scheme (NDIS) New Inquiry into Independent Assessments
The Royal Australian and New Zealand College of Ophthalmologists (RANZCO) welcomes the opportunity to respond to the Parliament of Australia Joint Standing Committee’s New Inquiry into Independent Assessments.
RANZCO is the medical college responsible for the training and professional development of ophthalmologists in Australia and New Zealand. Our mission is to lead eye care by setting and improving standards, providing lifelong education, promoting research and innovation, and advocating on behalf of patients, their communities, and our members. We recognise that delivering on our commitment to best practice and patient outcomes requires a diversified collaborative approach to ensure balanced methods of mitigating issues that affect the overall patient experience and outcomes.
In this submission, RANZCO addresses three of the National Disability Insurance Scheme (NDIS) Joint Standing Committee Terms of Reference: d, e and f:
d. the independence, qualifications, training, expertise and quality assurance of assessors;
- Noting the DSS commitment to a single point of contact, Local Area Coordinator, RANZCO recommends a collaborative care approach to the conduct of independent assessments to ascertain an NDIS participant’s functional capacity. We recommend engaging multidisciplinary teams including a mix of optometrists, ophthalmologists, orthoptists, occupational therapists, psychologists and social workers as required.
- RANZCO recommends the NDIS includes in its selection criteria a requirement that independent assessors declare any relevant conflicts of interest to ensure independence and objectivity.
e. the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding
- Prevention and early intervention have a significant role in supporting health and well-being. Screening and education are important elements in prevention and early intervention. Given vision loss is a factor influencing the long-term independence of people with a disability, whilst often overlooked, regular screening for eye disease is essential.
- In relation to the proposed introduction of NDIS independent assessments, RANZCO recommends that the NDIA work with the eye health sector to develop screening tools, for example best practice assessment processes for measuring vision loss in the context of functional capacity. RANZCO note p.70, item 39 in the Independent Assessment Selection of Assessment Tools Report (NDIS September 2020), a rationale for the exclusion of the Royal Society for the Blind vision test was the requirement for specialist skills. However, as stated, at the very least, to ensure the efficacy of the screening tool, we recommend consulting ophthalmologists in the development of the vision assessment tool.
f. the implications of independent assessments for access to and eligibility for the NDIS
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A key strategic priority for RANZCO is to advocate for equity of access to ophthalmic services across Australia including among Aboriginal and Torres Strait Islander populations.
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RANZCO anticipates independent assessments will potentially facilitate access to funding to address service gaps including, but not limited to, the following:
Among NDIS participants, RANZCO recommends there is a requirement to screen for eye disease (see RANZCO response to e. above). RANZCO recommends NDIS make appropriate screening available to those in rural and remote areas. At the very least, by way of telehealth services, should a face-to-face visit not be possible. RANZCO recommends NDIS allocate specific funding and practitioner incentives to entice participants to register to screen through a standard best practice assessment tool for measuring vision loss as it relates to functional capacity. RANZCO notes a standardised screening tool used in independent assessments would expediate approval processes for assistive technology and home modifications for those experiencing vision loss. Noting the reported increase in Aboriginal and Torres Strait Islander NDIS participants in the second quarter of 2019 (from 5.8-6.5%), RANZCO recommends the introduction of independent assessments ensures due consideration of the cultural safety of Aboriginal and/or Torres Strait Islanders RANZCO recommends the introduction of independent assessments ensures due consideration of the cultural safety of Culturally and Linguistically Diverse (CALD) communities
Yours sincerely,
Dr David Andrews CEO RANZCO