| write this submission as the family carer of several adult NDIS participants, the CEO of a Support Coordination company, an advocate and NDIS supporter who wants to see the scheme and it’s participants thrive and be supported by Australian society.
Sunday March 28“, 2021
e. the development, modelling, reasons and justifications for the introduction of independent assessments into the NDIS;
The justification for introducing IA’s to reduce future NDIS budget blowouts has been made without opportunities for co-design or understanding with disabled people, families, carers and the sector — given that a vast proportion of the scheme’s budget is spent on SIL (in home shared supports for people with significant support needs), for example demonstrates that there are many ways to skin this cat, if indeed, the cat needs skinning — | remain unconvinced and somewhat angry with a Minister who shares apples with oranges when comparing plan budgets between rural and metro participants, for example. There are many reasons why those plans would be expected to be lower — with thinner provider availability, rural folks simply don’t use as much of their plans, therefore don’t request more — what’s the point? And people with profound disabilities and exceptional support needs very very rarely live in rural areas, but rather live in metro areas near supports, services and high level health facilities and specialists.
| understand and accept that well executed IA’s potentially have a positive impact in supporting potential participants who do not have the capacity (financially and/or organisationally) to gain the needed reports to gain access to the NDIS. | agree with this use and that they should be funded using taxpayer dollars.
However, | believe they should be a MediCare funded item (much like the Better Start initiative for children under 13 who require assessment), which allows for potential participant’s choice and control over the AHP who conducts this assessment, and not funded through the NDIS by assessors employed through conglomerate corporates with hidden vested interests (as currently stands with the awarding of the tenders to date).
b. the impact of similar policies in other jurisdictions and in the provision of other government services; see i. for further info
c. the human and financial resources needed to effectively implement independent assessments;
As the founder CEO of a moderately sized Support Coordination company, | am acutely aware of the thin market for therapists across the country. There is no way that quality experienced allied health practitioners will accept relatedly poorly paid assessment roles while demand is so high for relatively well paid (and far more rewarding) service delivery. those who accept these roles will no doubt be very early career professionals with little no experience (as demonstrated by one successful tenderer’s recruitment advertising for graduates, despite clear requirements in the tender NOT to have such inexperienced assessors). Or they will simply be the lousy Allied Health Practitioners that no-one else wants to employ.
d. the independence, qualifications, training, expertise and quality assurance of assessors; Addressed partially in a and c.
-
e. the appropriateness of the assessment tools selected for use in independent assessments to determine plan funding; | am not an allied health practitioner, nor a person who can technically assess these tools’ suitability, but the NDIA’s own report clearly states that no one tool is sufficient, and that there has been no testing of using a combination of tools, nor how accurate and/or successful the grouping of these tools might be.
-
f. the implications of independent assessments for access to and eligibility for the NDIS;
-
g. the implications of independent assessments for NDIS planning, including decisions related to funding reasonable and necessary supports;
This question is loaded — we know that “reasonable and necessary” disappears if the current draft legislation is passed through parliament. However, should the legislation remain, then I|A’s may help contribute to an overall picture to help determine what supports are Reasonable and Necessary, along with reports from known professionals, as well as communications with the disabled person and/or family and unpaid carers as appropriate. | think the long history of disability related funding being so scarce prior to NDIS, and with the scheme being in a place where disabled people are families are finally seeing the light at the end of the tunnel, finally able to work, to breathe to have a halfway decent life, it feels like the “bad old days” where every disabled person and family was told to always talk about “worst day” when speaking to those in power, determining funds. We were finally starting to breathe (I am also a family carer to disabled adults) and think “Wow, we finally have the support we need to life a decent life”, and are now, quite frankly, frightened of where this will leave those we love. Elderly parents are especially terrified of what will happen once they die.
-
h. the circumstances in which a person may not be required to complete an independent assessment; The premise here is that they will be a requirement for most — | am not willing to accept that at this stage.
-
i. opportunities to review or challenge the outcomes of independent assessments;
The NDIA appears hell bent on making the IA’s result unable to be challenged or appealed, and to be the major driver that determines funding levels. This is dangerous territory and will be highly unlikely to increase equitable funding outcomes, as Savvy carers and disabled people will simply present their worst picture on the day of the assessment — medications will be withheld, children will be wilfully sleep deprived and parents will (painfully and deliberately) trigger poor behaviour and lower abilities as best they can, to try to ensure appropriate plan funding. The inability to see draft assessments and to make corrections to even basic errors is a gravely dangerous flaw that will likely lead to plan underfunding and potentially serious participant harm or death, as occurs with regularity in the UK since their introduction of Independent Assessments (https://www.independent.co.uk/news/uk/home- nnews/benefits-uk-disability-assessment-company-report-finds-government-cuts- a8208271.html) as an example) As a support coordination company we suggest to all our clients that we review the reports made by therapists who know clients very well, as even they still make frequent major factual errors in their reports. These people are human. Mistakes will be made.
- Our own support coordinators also frequently make mistakes — those with and without allied health qualifications. This is why our reports also always go back to participants/families for their review before we submit. To not have that opportunities in the proposed NDIS |A’s program is somewhat terrifying. People lives are actually on the line here.
j. the appropriateness of independent assessments for particular cohorts of people with disability, including Aboriginal and Torres Strait Islander peoples, people from regional, rural and remote areas, and people from culturally and linguistically diverse backgrounds;
| am not an indigenous person nor of CALD background or regional, rural and remote and other respondents will be better placed to speak to this. Common sense and a general experience of working with this cohort tells me that the interpreter won’t turn up and the assessment will go ahead anyway — this happens with our clients, ridiculously and inappropriately on at least a weekly basis with NDIS planning meetings, and is not adhere to the NDIS Act Principles, not one bit.
k. the appropriateness of independent assessments for people with particular disability types, including psychosocial disability; and
As a support coordinator, | can say we have some clients with psychosocial disabilities who did not allow us into their homes for more than a year, until a strong relationship has been established. | don’t believe an IA’s assessor could be expected to get an accurate picture, or even to meet some of these participants without causing major trauma and triggering dangerous episodes (and risking self removal from the scheme, self harm, or worse).
l. any other related matters The NDIA have made grave errors in their process launching IAs.
-
The problems (inequity of access, and potential budget blowouts) were not presented to disabled people, families and carers and the sector to seek advice and potential solutions.
-
The awarding of the IA’s tenders three days after submission on the process ended shows a lip service rarely so obvious.
-
While practically all of the submissions that were shared publicly on the IA’s process said the same thing, and suggest a pause, if not a halt, there appears to be no will to listen by the Agency, who are steam-rollering ahead.
-
| believe there are a multitude of ways that both the problems of inequity of access and possible budget blowouts can potentially be solved with a range of other measures which will also increase quality of life for disabled people — just ask them.