Submission 27 — Aspect — Market Readiness | External submission

Building 1, Level 2, 14 Aquatic Drive Frenchs Forest NSW 2086 PO Box 361, Forestville NSW 2087 T 02 8977 E mdonnelly@autismspectrum.org.au www.autismspectrum.org.au

ABN 12 000 637 267

Written Submission to the Joint Standing Committee on the National Disability Insurance Scheme

Thank you for the opportunity to provide a written submission with respect to Market Readiness for the National Disability Insurance Scheme.

Autism Spectrum Australia (Aspect) is Australia’s largest not-for-profit provider of services and supports working with people with autism and their families. At Aspect, we believe people on the autism spectrum are a different brilliant and this shines through in our work. We believe every person, of any age, with a disability, has the right to make age appropriate choices, to have full participation and inclusion in society, to have respect for difference and acceptance as part of human diversity, and to have equal opportunity. Our Mission is to provide person centred solutions which are flexible, responsive and evidence informed. In our work, we focus on the strengths and interests of people on the spectrum and we work in partnership with them, their families and their communities. We work to understand people on the spectrum from their perspective. Our approach is autism-specific. Our research focuses on best practice. We expect positive change and progress towards positive outcomes. Aspect provides services to participants across all age ranges in New South Wales, Victoria, South Australia, Queensland and the Australian Capital Territory.

The transition to a market based system for service providers:

Aspect were in a unique position having already experienced the transition of the Helping Children with Autism and Better Start Initiative Packages. Aspect was well versed in transitioning to a market based system, and how reputation and choice of families/clients drives clients to opt for services.
Aspect historically had placed significant emphasis on branding and market presence, so were well positioned for the transition.
Aspect had already invested in a client management system at the commencement of the NDIS. However, with the evolution and increased complexity of the NDIS portal and self-managed clients, Aspect has made a significant commitment to a new system to further increase our efficiencies.
Aspect is also investing in a new website, undertaking extensive work on how we communicate with clients, building strong collaborative relationships.

Recommendations:

There is no funding available to support providers with the mechanics that are required for organisations who have traditionally been block funded, to transition to a market based system. Across the sector there was limited knowledge of the infrastructure required and the hidden work essential to building not only reputation but also communication strategies. This issue includes the necessary work required to navigate the NDIS portal, and the challenges of how to be a profit for purpose business if organisations do not have the financial reserves required when there are significant issues with payments, and parent carers’ understanding of how payments are made. Overall, the sector was not ready for these changes, and some providers were not in a position to make the step from a financial perspective.

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It should also be noted that initially providers were very protective of their clients, resulting in reduced collaboration in trying to secure ongoing relationships. This issue has decreased as awareness of the large volume of clients and increased funding has evolved.

Participant readiness to navigate new markets:

Clients who were participants of the Helping Children and Autism and Better Start Packages were better versed in the skills required to navigate the market, as well as understanding self-managing packages. However, clients older than these participants were used to using one provider, and did not have the knowledge or understanding of best practice service provision, and as a result were not in a position to make informed decisions.
The expectation that families/carers could make these decisions, without support, was challenging. Some families had vastly unrealistic expectations of the providers and the level of funding they would receive.
There was a particular failure for families from cultural and linguistically diverse backgrounds, with only recently announced support for interpreters. The haphazard basis of families being pushed towards self-management, when they do not have the appropriate skills, caused great frustration. NDIS portal managed should be the default, and only families requesting self-managed should be supported as self-managed.
The manner in which families can search for providers on the NDIS portal is fraught with errors if the organisation is a state-wide provider. Organisations have to employ staff to go into the NDIS portal and add all suburbs, so services are available for clients to view. This results in families unable to see the scope of providers available.
Whilst many organisations have presented information sessions, there is still considerable work to be done to ensure individuals have the knowledge to make choices. There is no funding to support pre planning meetings with individuals to provide informed knowledge and support decision making. Whilst a percentage of individuals receive support co-ordination funding, this should be available as a one-off for all new participants to support navigation of new markets.

Recommendations:

Review the allocation of support co-ordination and supporting families to the market and navigate the system.
More support for CALD and ATSI families.
Review how self managed, plan managed and portal managed is allocated.
Organisations funded to build individuals capacity and understanding of the market should be the role of LACS and Access Planners. However, they are overwhelmed with access request, plans and plan reviews to support individuals to understand the market.

The development of the disability workforce to support the emerging market:

In the capacity building cluster of the NDIS there is a significant workforce issue with recruiting allied health professionals. Aspect Therapy has invested heavily in new graduate recruitment and have developed a strong support and supervision model and a year long online training program with fortnightly learning modules. This is at a significant cost to the organisation. Whilst we are strong believers in growing the sector and building staff capacity there is a shortage of staff in regional areas. As a national body we have a strong reputation and are able to recruit staff but it is becoming more competitive and there is no funding available to upskill staff so they can provide ongoing high quality services.
Within the current NDIS pricing model, there is minimal funding available to provide support, supervision and training for workers who are delivering one to one support in the community. There is minimal scope within pricing to pay for the support and supervision costs that providers incur to training and develop staff.

Recommendations:

Funding opportunities should be available to support sector development and ensure organisations can put the infrastructure in place to ensure high quality person/family centred services are provided which meet the objectives of the NDIS.
The NDIS or Commonwealth Government should either increase prices to allow for a sufficient level of support and supervision for employees, which should factor time required for staff to be paid

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whilst away from face to face work and funding. Alternatively, the government might consider an annual professional development funding pool, which organisations can apply for each year to cover the support, supervision and training costs for employees.

We support the Productivity Recommendation for price setting to be moved to the Quality and Safeguarding Commission to ensure the regulation of safety is appropriately calculated and factored into NDIS prices.

The impact of pricing on the development of the market:

Aspect supports the development of a fair market price. At present, we support a disability sector view that the current core support pricing for 1:1 support is not sustainable and is placing unsustainable financial pressure on organisations.

Recommendations:

Pricing must be increased with CPI and costs associated with providing best practice services in an environment of choice which covers staff kilometres and costs.
It is financially unsustainable to deliver services at the current 1:1 rate being set by the NDIA to deliver core support services. We believe this rate must be adjusted upwards to ensure there are sufficient funds to cover this service offering and to ensure there is enough incentives for organisations to build supply for this service offering.

The role of the NDIA as a market steward:

The NDIS requires significant collaboration with disability experts as there is no doubt that the agency is lacking in knowledge of the market and the skills and expertise to make informed decisions for the autism community. There are significant knowledge gaps in the agency with particular to those answering 1800 calls and planners who do not have disability expertise. The NDIA has provided limited data on the market and does not update this data. Quarterly reports on different age groups and disability type provide aggregated data rather than year on year data, which makes it very difficult to calculate trends to predict how much support and the type of support that people may need.

Recommendations;

The agency needs to be open and transparent and access training and support from providers who have extensive knowledge to make informed decision around the market and services.
The agency needs to provide real time data to organisations to help them understand the specific level of need for different age groups and the level of need applicable to different disability groups.

Market intervention options to address thin markets, including in remote Indigenous communities:

Aspect Therapy has developed innovative service options to support both CALD, ATSI and at risk communities. For our services to be successful we need to not only provide tele therapy options, we also need support to complete fly in fly out services in these areas. Aspect Therapy has a history of providing services in regional and remote areas. However, under individualised funding this is no longer able to be funded. This should be viewed like the HCWA package where providers are given a regional allowance to cover these services.
We are also keen to explore directives from the agency of regions needing support and would provide inclusive collaborative services if approached by the agency.
Aspect has a reconciliation action plan that includes a benchmark to ensure we are measuring the inclusion of people from an Aboriginal or Torres Strait Islander background across our services.

Recommendations;

Implementation of a funding option for organisations willing to provide services in regional/remote areas to ensure best practice services across all environments are provided. This would involve working with relevant liaison officers to get the best service innovated in these areas that meets all individual needs.

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The provision of housing options for people with disability, with particular reference to the impact of Specialist Disability Accommodation (SDA) supports on the disability housing market:

There is a significant problem in this area. There is a shortage of SDA housing which limits individual’s options due to challenges concerning damage to rental properties. There is an ongoing shortage of bricks and mortar and specialised accommodation and without appropriate accommodation choices, individuals do not have choose and control, as they have to stay in properties with a provider, as there are no options available.

Recommendations:

There needs to be a significant investment in SDA housing for clients to be able to move from their home or current setting. It is a significant failure that clients cannot move to Supported Independent Living because of a lack of accommodation. New Providers do not have the funds to invest in properties and need financial support to build custom housing to support individuals. Grants should be available to demonstrate best practice quality housing setting for new providers in the accommodation space.

The impact of the Quality and Safeguarding Framework on the development of the market:

This is a requirement and Aspect strongly supports this framework and believes this must be adopted so all providers are accountable.
We believe that the decision to apply more stringent compliance to registered providers and less compliance over non-registered providers, is a judgment driven by a fiscal and market development agenda, and is not giving enough attention to the substantial risks non-registered providers will face in the NDIS, which will not be safe without strict compliance. Aspect has and always believes in innovation and the development of services where people with a disability can take more control of their services and make the most of their funding. The NDIS should afford people with a disability the dignity to take risks in the interest of greater choice, control and independence. However we firmly believe that with the significant changes in jurisdictional regulation, risk assessment and risk management of known risks to vulnerable people will be outsourced to individuals who will have minimal understanding or experience of how to manage these risks. These risks will translate directly to well-being and safety risks for scheme participants. We strongly recommend any worker, whether employed by a registered provider or directly by a participant, must have the same check process in place. If this is not applied, workers who have been found to pose a risk to vulnerable people will exploit loopholes in order to gain work, or in a worst-case scenario, seek work to prey on vulnerable people.
There is significant differences in compliance across the different states. In comparing current requirements across NSW and Victoria, the cost of compliance costs in Victoria are significantly higher. We are yet to see whether the different states will seek to retain some controls within their jurisdiction. However the NDIS prices in Victoria and NSW are the same and do not factor in the different costs for different jurisdictions.
We have recently received new advice that the NDIS will not require organisations to be compliant with the National Disability Service Standards and will instead roll out a range of NDIS practice standards. Organisations across Australia have been investing significant funds and human resources in preparation for compliance with the National Standards. There is a lack of consistency in our understanding of how compliance will be applied in the market. There is no public information on the web regarding the proposed NDIS Practice Standards and we have no way of knowing how these will be applied.

Recommendations:

Apply a consistent level of regulation and compliance across all service provision and adjust prices to reflect the true costs of service provision.
Provide consistent advice to the market on compliance requirements to ensure organisations receive clear and accurate advice on how they should prepare their transition to national compliance.
Organisations should receive funding to make the transition to a national compliance system.
Ensure all workers or volunteers who are associated with the fulfilment of NDIS Plan goals undergo the same pre-employment/probity checks.

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Provider of last resort arrangements, including for crisis accommodation:

This is a significant area and there are no providers available. Aspect has first-hand experience at trying to find accommodation for clients who are relinquished or need crisis accommodation. As a result these clients end up in hospitals, particularly psychiatric settings, that are not appropriate. As a member of NDS, we have been advised that this particular area is experiencing market failure.
A significant factor that impacts the decision making of a provider as to whether they will support a person with complex support needs is the availability of suitable housing and security of funding to sustain that housing. For staff to provide an appropriate level of support, providers need housing that is designed to provide safety for the person and for staff working with them.
Many providers who have provided crisis accommodation need the ongoing backing of regulators to support them in times of crisis. The work is high risk and must be remunerated appropriately to ensure these risks can be managed.
The NDIS was designed to mitigate the need for ongoing crisis supports. Any person in crisis should, as a priority, have an NDIS Plan with short, medium and long term goals, each with an indicative budget, backed by the NDIS, that enables longer term planning for that person, as soon as possible. Any offer of service should be contingent on providers committing to the implementation of that longer-term plan. If the plan is simply to alleviate the crisis, it is likely to result in the person experienced a prolonged period of crisis support.

Recommendations:

The agency work with first responders to these cases, and listen to the benefit of setting up some interim accommodation in many LGA’s that can work, not only as crisis, but also respite. The agency needs to provide the funding to set up these services (perhaps in collaboration with state health agencies) and listen to provider experience and provide facilities in collaboration with multiple providers as a last resort that then works to get clients into supported independent accommodation. This is at crisis point and a solution needs to be found. Aspect Therapy has a case study which is in the final stages of being documented and reported to the agency with recommendations around supports needed.
Whilst state governments were often limited in their ability to forecast and apply funds beyond the immediate crisis, the NDIS should ensure that any person in crisis is supported with a plan that ensures a provider of last resort is also a provider that is committed to supporting that person to transition from crisis to one that is stable. Providers that can see a longer-term commitment to a participant, beyond the crisis, are more likely to consider offering a service.

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