Website: www.eciavic.org.au
Submission to the Joint Standing Committee on the National Disability Insurance Scheme: Inquiry into Independent Assessments.
March 2021
Sarah Riches - Chief Executive Officer
Early Childhood Intervention Australia Victoria/Tasmania Limited
ABN: 61 830 423 920 | ACN: 617 517 423 1
Website: www.eciavic.org.au
Introduction and Background
Early Childhood Intervention Australia Victoria/Tasmania (ECIA VIC/TAS) welcomes the opportunity to provide a submission to the Joint Standing Committee on the National Disability Insurance Scheme Inquiry into Independent Assessments. This submission will provide key aspects from the perspective of the early intervention sector.
ECIA VIC/TAS is the peak body for early childhood intervention in Victoria and Tasmania. We represent over 600 professionals and organisations providing specialised support and services for infants and young children with disability and/or developmental delay to promote development, well-being and community participation. Our vision is for young children of all abilities to fully participate in family and community life.
ECIA VIC/TAS members are ECI professionals working in community organisations, disability services, specialist ECI organisations, children’s services, and government departments – all of which reflect the diverse ways in which services are provided to young children and their families. Our members implement a best practice approach to ECI which is outlined in the National Guidelines for Best Practice in Early Childhood Intervention.1
ECIA VIC/TAS acknowledges the National Disability Insurance Agency (NDIA) for their ongoing commitment to best practice through the NDIS ECEI approach. There is genuine goodwill across the ECI sector and a real desire to collaborate with NDIA to help ensure that best practice is maintained.
ECIA VIC TAS note the concerns expressed by other advocacy organisations, peak bodies and service providers to the Independent Assessment approach and would like to take this opportunity to raise issues about the strategy for young children (0-6 years) and their families whilst this component of the program is still in the design phase.
We support the need for a more consistent and equitable approach to NDIS access and planning decisions and the need to focus on individual’s functional capacity and the influence of environment, health and other individual factors outlined in the Independent Assessment Framework2. However, there are particular issues that must be considered in relation to infants and young children with a developmental delay and/or disability and their families.
1 Early Childhood Intervention Australia (2015). ECIA National Guidelines for Best Practice Early Childhood Intervention. 2 NDIS (2020). Independent Assessment Framework. Retrieved from: https://www.ndis.gov.au/participants/independent-assessments/independent-assessment-framework
ABN: 61 830 423 920 | ACN: 617 517 423 2
Website: www.eciavic.org.au
Recommendations
We strongly recommend a thorough and separate review of assessment for NDIS access and planning decisions for children 0-6 years with consideration of the International Classification of Functioning, Disability, and Health: Children & Youth Version (ICF-CY)3 and the following issues.
1. A Family-centred and Strength-based Approach to Child Assessment
The National Guidelines for Best Practice in ECI4 highlight family-centred and strength-based practices as critical components of service delivery. In relation to assessment of young children’s development, family-centred and strength-based practices:
- Acknowledge the central role families have in their child’s life and the intimate knowledge they have about their child’s functioning, participation, and interactions.
- Involve parents/carers in sharing information with a known, skilled and trusted practitioner in order to develop a clear picture of the child’s development.
- Include professionals who are best equipped to provide a partnered approach to assessments. That is, those who know the child and family and have observed the child functioning within in daily routines, activities, and relationships.
- Ensure families of young children can engage local, trusted, suitably skilled and qualified paediatric practitioners for assessments.
- Provide opportunity for careful feedback from a trusted professional to ensure a shared understanding of the assessment findings and develop a plan for next steps.
- Ensure the focus of assessment is on child functioning, not impairment.
- Provide families with reliable information, support, and continuity of care from professional/s they have an ongoing relationship with.
2. Identification and Supports Early in Life
The insurance approach of the NDIS highlights the importance of investing in people with a disability early to build their capacity to achieve outcomes later in life. In relation to child assessment, this approach must:
- Ensure that infants with an identified disability (e.g. Permanent Impairment identified on List D 5) have immediate access to the NDIS, irrespective of whether they display a functional impairment at this early stage of life.
- Include a preventative approach that ensures easy, prompt access to suitable services and supports early in life, including for those children identified with emerging developmental needs.
3 World Health Organization. (2007). International Classification of Functioning, Disability, and Health: Children & Youth Version: ICF-CY. World Health Organization. 4 Early Childhood intervention Australia (2016). ECI Best Practice Guidelines. Retrieved from: https://www.eciavic.org.au/resources/eci-best-practice-guidelines 5 NDIS. List D - Permanent impairment/Early intervention. Retrieved from: https://www.ndis.gov.au/about-us/operational-guidelines/access-ndis-operational-guideline/list-d-permanent-impairmentearly-intervention-under-7-years-no-further-assessment-required
ABN: 61 830 423 920 | ACN: 617 517 423 3
Website: www.eciavic.org.au
- Provide emotional, informational, and material support to parents/carers as they navigate a new service system and adjust to being the parent of a child with a lifelong disability, recognising they will need new skills and knowledge in order to support their child’s development and wellbeing.
- Carefully review the proposed suite of assessments with an understanding that there is not any one reliable, high quality, valid, assessment tool for young children.
- New assessments (purpose built) will need to be developed to better identify and more accurately describe children’s functioning, participation, interactions, and the contexts in which they occur.
3. The Interface between Mainstream and Specialist Services
An integrated service system across all jurisdictions, levels of government and community services is critical. In relation to assessment of young children’s functional development, a coordinated approach needs to:
- Acknowledge that children and their families have typically been engaged with local mainstream services that have practice guidelines for developmental screening and surveillance. For example, Victoria’s Maternal and Child Health Nurses currently utilise the Pediatrics Evaluation of Developmental Status6 and Brigance7 as part of the key ages and stages framework8. These protocols support the identification of children’s developmental delays early in life and have given them prompt access to appropriate services. Approaches to child assessments for the purposes of NDIS access and planning decisions should utilise this valuable information.
- Ensure the suite of NDIS recommended assessments integrates with measures used in mainstream and specialist services wherever possible.
- Encourage coordination of child assessments and utilisation of assessment reports conducted for purposes other than NDIS access and planning decisions to avoid duplication and additional stress for children and their families. For example, the Vineland Adaptive Scales9 may be used for Victoria’s Department of Education and Training requirements for Program for Students with a Disability funding or may be a used as part of the diagnostic assessment for Autism Spectrum Disorder.
4. The ECI Workforce
An integrated service system requires a suitably qualified and experienced workforce. There is a national shortage of paediatric therapists and specialist teachers required to provide high-quality services for children with a disability and/or developmental delay and their families. This is a particular problem in rural and remote areas. Any additional services such as Independent Assessors will put additional pressures on this workforce shortage and needs to be addressed through the development of a workforce strategy as a matter of urgency.
6 Glascoe, F. P. (2003). Parents’ evaluation of developmental status: how well do parents’ concerns identify children with behavioral and emotional problems? Clinical pediatrics, 42(2), 133-138. 7 Brigance, A. H. (1978). BRIGANCE (TM) Diagnostic Inventory of Early Development Including Developmental Record Book. 8 Department of Health and Human Service (2019). Maternal and Child Health Service Practice Guidelines. 9 Sparrow, S. S., Cicchetti, D., & Balla, D. A. (1984). Vineland adaptive behavior scales.
ABN: 61 830 423 920 | ACN: 617 517 423 4
Website: www.eciavic.org.au
We urge the NDIS to work in collaboration with families of young children with a developmental delay and/or disability, advocates, service providers and peak bodies, in developing an approach to assessment that addresses the barriers to accessing the NDIS and provides a more consistent and equitable Scheme.
We strongly recommend a thorough and separate review of assessment for NDIS access and planning decisions for children 0-6 years
ABN: 61 830 423 920 | ACN: 617 517 423 5