Submission 50 — The Australian Psychological Society Limited — Market Readiness | External submission

Joint Standing Committee on the National Disability Insurance Scheme (NDIS)

Inquiry into Market Readiness for the NDIS

        **APS Response**

          February 2018

Dr Louise Roufeil FAPS Executive Manager Professional Practice

Dr Tony McHugh Manager Professional Practice

Table of Contents

Summary of Recommendations …………………………………………………………………. 3

Introduction .............................................................................................. 3

Response to Inquiry Terms of Reference …………………………………………… 4

ToR A. The transition to a market based system for service providers ………………………. 4

ToR B. Participant readiness to navigate new markets ………………………………………….. 7

ToR C. Development of disability workforce to support the emerging market ……………… 9

ToR D. The impact of pricing on the development of the market ……………………………………. 10

ToR E. The role of the NDIA as a market steward ……………………………………………………………..13

ToR F. Market intervention options to address thin markets, including in remote indigenous communities……………………………….….….….….….….….….….….….….….….….…………… 13

ToR H. The impact of the NDIS Quality and Safeguarding Framework on the development of the market ……………………………………………………………………………………………………………………….14

Conclusion ............................................................................................... 16

Summary of Recommendations The APS believes that for NDIS clientele to successfully transition to this “market- based system”, the NDIA must:

 have processes in place that better-guard against:  the potential for failure to or continue to provide necessary professional services to NDIS clientele  delay in the commencing of the provision of such services as individuals transition into the scheme and  potential mismatches in the supply of and demand for the services of skilled health professions through service delivery substitution by an unskilled workforce.

 review its communications around market navigation and workforce development for the emerging market and make use of professional associations to better inform practitioners and participants about this

 act to introduce and maintain pricing mechanisms that ensure quality service delivery and a market places that acts to preserve competition which promotes participant freedom of choice

 take an active role on stewardship that mitigates the risks that will derive from an a market that acts against quality interventions for NDIS participants  consult with the peak bodies of the professions, the APS included, as a matter of urgency to identify solutions to thin markets  act to financially support smaller organisations or those operating in areas of the Scheme where there is the risk of market failure  act to protect the safety of NDIS participants with self-managed plans and  better-implement safety and quality checks and balances while acting in a red tape minimising, not multiplying, fashion.

1. Introduction

The Australian Psychological Society (APS) welcomes the opportunity to provide a submission to the Australian Parliament Joint Committee Inquiry into Market Readiness for the NDIS. The APS is the largest professional organisation for psychologists in Australia representing almost 23,000 members, of whom a significant portion deliver evidence-based psychological services to consumers, including those in the disability sector and/or participants in the National Disability Insurance Scheme (NDIS/Scheme).

This submission is based on feedback sought from members who are providing or have provided services to consumers of the NDIS as sole providers or as a member of a service provider entity. The submission addresses the Joint Standing Committee’s Terms of Reference (TsoR), where relevant to psychology and APS

member feedback.

2. Response to Inquiry Terms of Reference

ToR A. The transition to a market based system for service providers The operation of the NDIS is underpinned by a philosophical approach that places participant autonomy in decision making about services at its centre. In practice, it decentralises service delivery from past state/territory government departmental and agency providers to the non-government and private sectors via various purchaser-provider fee-for-service mechanisms that are outcomes based.

Consequently, the NDIS is a “landscape-altering” scheme for the provision of care to Australians with a physical, intellectual sensory or psychosocial disability. The “market-based system” under which it operates has potentially profound consequences for participants and practitioners who receive or provide NDIS services. There are several issues which government needs to recognise and address for this “transition” to work successfully for participants:

 Initially, there is the issue of the impact on NDIS participants of the wind-down of the historical, state/territory-funded and delivered disability service delivery systems. As previously outlined by the APS in its February 2017 submission to the Joint Parliamentary Standing Committee Inquiry into the provision of services for people with psychosocial disabilities resulting from mental health conditions under the NDIS, this problem is illustrated by the transfer of NSW disability services provided under the Ageing, Disability and Home Care area of the Department of Family and Community Services to the non-government sector. Similarly, in Victoria, Mental Health Community Support services (MHCSS) and Early Childhood Support (ECS) services are currently being transitioned to the NDIS before the implications of the administrative arrangements necessary for the appropriate delivering care have been understood or consulted around.

Evident of this lack of proper planning, the APS has been informed by members that the withdrawal of state/territory-funded services is occurring before clients of such services have been assessed for their eligibility to receive services under the NDIS. The APS, consequently, perceives a grave risk that such services will have closed without appropriate plans being in place for all NDIS participants, due to the extent of the transition. This view is supported by estimates demonstrating that in 2018-2019, around 850 care plans need to be

approved and 1,100 plans need to be reviewed nationally per day. This is double the rate at which such plans have been approved to date.1

 There is also the need to untangle disability and health-related issues, especially regarding mental health, in the Scheme. Psychosocial disability, by its very nature, requires a mixture of evidence-based psychological interventions and broader social support for individuals. Some individuals will also require a psychiatric response. Equally, it is important to recognise that many psychosocial disabilities have their roots in physical disabilities; for example, a person with a severe physical disability is likely to experience psychosocial disability (e.g., depression and anxiety) directly related to their physical disability. In both cases, it is challenging (and in many cases not possible) to identify the components of disability which warrant a health- response as opposed to those that merit an broader approach such as NDIS response. To maintain the original intent and integrity of the NDIS in relation to the distinction between disability and health will require applicants with psychosocial and physical disability to be assessed by skilled, appropriately trained and qualified assessors with considerable expertise in mental health and a familiarity with the needs of individuals transitioning into the Scheme.

Under the NDIS, ‘health-related’ services are to continue to be provided from the health system. Yet the APS is aware, for example, that there are many former clients of the state disability service in NSW who previously received psychological services as part of their care. These individuals have not been offered equivalent services under the NDIS and, instead, have been directed to obtain these services from mainstream health services. However, due to the difficulty in accessing such services in the health system, these individuals are now obtaining considerably less psychological support than was previously available to them under state/territory-funded services and it is not provided in a coordinated way which would recognise the inter-relationship between severe physical disability and a person’s experience of psychosocial disability.

 The Government has already indicated that “one third of the 690,000 Australians with severe mental illness have chronic, persisting illness and most have a need for some form of social support, ranging from low intensity or group-based activities delivered through mainstream social services to extensive and individualized disability support”.2 There is also

https://static1.squarespace.com/static/57c65af5cd0f68b1295663dc/t/586988ae6b8f5b18108843be/1483311324994/Letter-by-Bruce-Bonyhady-to-Christian-Porter.pdf 2 Australian Government (2015). Australian Government Response to Contributing Lives, Thriving Communities - Review of Mental Health Programmes and Services.

acknowledgement that there are gaps in services for people with severe mental illness who are not supported by existing state-funded mental health services nor by the NDIS, but have complex needs and require specialist clinical coordination of services.3

 There is also evidence that where individuals have transitioned into the Scheme, they are at risk for the consequences of potential market failure, via:

      purchaser-provider mismatching
     service supply and demand imbalance and
     over and/or under-servicing and the delivery of poor quality services.

Feedback to the APS from members indicates that NDIS “transitioned” participants have also been receiving less-than-optimal quality care, poorly coordinated and possibly unnecessary services or, alternatively, not receiving required services or services provided before the scheme’s commencement.

The APS believes the cumulative effect of these issues and the enormity of such problems will become apparent due to the planned significant uptake of NDIS participants in the next two years. This will lead to perhaps unintended but predictable negative effects of an unsophisticated market mechanism that will, contrary to the original intent of the NDIS, result in lesser standards of care (see further comments regarding Term of Reference “D” regarding pricing and the market below).

The requirements the NDIS has created for practitioners also should not be underestimated for their impact upon transition to the Scheme. There are, according to psychologist practitioners (with extensive relevant capabilities, experience and expertise) who replied to an APS survey about the intended operation of ECS in Victoria, a multitude of audit, review and reporting requirements for practitioners to complete in relation to participants receiving services. The private health professional workforce that has the potential to work under the NDIS is neither currently arranged nor has the capacity to easily or without significant cost become NDIS providers. This has the potential to dissuade practitioners from providing services under scheme. For example, over 90% of those surveyed in the APS’s Victoria ECS survey have indicated they will not pursue registration due to the cost of independent auditing/third party verification (TPV) of qualifications. This is of grave concern to the APS, as in their absence, the market will inevitably operate to meet the need for the NDIS workforce via

http://www.health.gov.au/internet/main/publishing.nsf/Content/0DBEF2D78F7CB9E7CA257F07001ACC6D/$File/response.pdf 3 ibid.

for-profit organisations and large NGOs using a lowest-cost, poorly trained and low capacity workforce.

The APS has previously raised its concern over these issues with the National Disability Insurance Agency (NDIA) and other government departments taking actions in relation to the Scheme. There, however, remains scant appreciation of the difficulties encountered by solo practitioners and small practices on transitioning to the different business models required by the NDIS. The APS reiterates its concerns regarding the potential ramifications of this impending supply and demand mismatch for skilled, professional interventions. It argues that the NDIS is required to identify and act upon such supply gaps to ensure the sufficient availability of practitioners capable of meeting participant needs and, thereby, meet best practice standards in the delivery of the necessary services.

In summary, the APS believes that for NDIS clientele to successfully transition to this “market-based system”, the NDIA must have processes in place that better- guard against:

 the potential for failure to or continue to provide necessary professional services to NDIS clientele  delay in the commencing of the provision of such services as individuals transition into the scheme and  potential mismatches in the supply of and demand for the services of skilled health professions through service delivery substitution by an unskilled workforce.

ToR B. Participant readiness to navigate new markets

Based on the operation of the NDIS thusfar, there appears to be an assumption in the NDIA’s administration of the NDIS that current and potential participants and their families, carers or guardians have an equal capacity to navigate the NDIS and its markets. Feedback from members and publically available comment from consumers highlights the significant variability that exists in the capacity of participants to navigate the NDIS and knowledge of the NDIS system.

Evidence indicates that the knowledge base of participants about the Scheme is unpredictable and inconsistent. As further elaborated upon in Terms of Reference ‘D’ (relating to the impact of pricing on consumer behaviour), this navigational inequity will vary according to individual’s level of disability, the incidence of disability within families, variation in the capacity of families to negotiate care plans and generally traverse the system [because of the various impacts of Socio Economic Status (SES), such as fiscal impoverishment and attenuated educational levels]. This may result in participants and their families and carers being differentially successful in obtaining favourable incomes based on their capacity

and level of readiness to navigate the new markets.

It can also be demonstrated by the significant logistics involved in the transition to the Scheme. Indicative of this, 450,000 individuals across Australia are currently eligible to apply for the Scheme, but a considerable segment of this population has not yet made application to join the Scheme. Fifteen per cent of this population are people living with a mental health condition.

Consumer advocates have to date reported that only 47 per cent of NDIS participants have their plans approved by NDIS within 90 days. This lengthy delay is unnecessarily caused by NDIS seeking to approve items in plans that properly are the prerogative of the participant and their family and supporters.

There remain significant concerns regarding the intersection of the health and disability sectors around psychosocial disability. In addition, and as previously indicated by the APS in its submissions to government, the gaps in services for people with psychosocial disabilities appear to be widening and may continue to do so with the transition to the NDIS. This is an area that will require significant ongoing attention in the coming years to ensure people who may not meet the NDIS eligibility requirements do not miss out on critical service provision to meet their needs.

A further area for concern is the quality of the plans developed for NDIS participants. As people are being enrolled into the Scheme, the issue of quality must be identified and addressed early using a high skilled professional workforce with expertise in a range of psychological skills. These include working with intellectually, sensorily, behaviourally and physically disabled participants. This will, in turn, require the NDIA to invest in staff recruitment and ongoing training to expand its workforce capabilities in dealing with people with psychosocial disabilities. This in turn, is critically linked to participant readiness to navigate new markets.

Many practitioners have commented upon lack of, too much or confusing and contradictory information being provided from the NDIS/NDIA about various aspects of the scheme. Examples include whether NDIS participants may avail themselves of funding for the treatment of health and disability-related mental health issues using both Medicare and the NDIS. Thus, members have commented upon the distress system dis-coordination it will cause participants and/ or their families.

In summary, the APS believes that it is important that the NDIA review its communications around market navigation and make use of professional associations to better inform practitioners and participants about navigation. These communications will be most effective if they are included within a targeted

communication strategy.

ToR C. Development of disability workforce to support the emerging market

The situation applicable to psychologist service providers under the Scheme also needs careful consideration. In its July 2017 submission to the Productivity Commission position paper on NDIS costs, the APS indicated that there are currently limited incentives for psychologists to provide services to consumers under the NDIS. It argued that this is unlikely to improve in the foreseeable future unless remedial action is taken by the NDIA. The psychology workforce is being forced out of the NDIS due to registration barriers (and associated cost and time factors involved in the protracted and complex registration process), bureaucratic red tape, remuneration that is under market rate and plans that prevent delivery of best practice.

Consequently, and observed in relation to Tore “A” (regarding the transition to a market based system for service providers), there is grave potential for the market operate to meet service demand via for-profit organisations and large Non Government Organisations (NGOs) using a low cost and capacity workforce. There is already evidence that psychologists are also choosing to not provide NDIS services because of the inability to deliver best practice interventions to participants. This occurs most frequently in relation to behaviour management, and is primarily due to the development of plans for NDIS participants that do not reflect what is needed to develop and implement a behaviour management plan for a participant with complex needs. This could be addressed by training for planners.

The NDIS has, to date, inadequately distinguished between the high-level knowledge, skills and experience of psychologists in assessing, planning, applying and monitoring and reviewing plans and interventions in behaviour support (especially complex behaviour management) and those of a generalist workforce that may subsequently implement such interventions. These different roles require different skills sets and it is vitally important that this is recognised by the introduction of fees that reflect this and, thereby, provide for the adequate supply of these important professional and worker roles within the NDIS.

There is also the potential for the consideration of a consultancy model whereby behavioural analysis and behaviour management is undertaken by expert psychologists and implementation is undertaken by workers with other qualifications, potentially under the supervision of a psychologist. Such a model would be relevant across Australia, but particularly for rural and remote regions.

In the absence of such supports, there is likely to be an attrition of psychologists

skilled in disability work as they move more and more into mental health reduce delivery due to insurmountable barriers to NDIS work. This will result in a medium-to-long term capacity of supervisors to train in disabilities. Given the high need for psychological services for many NDIS participants, this supply issue will inevitably impact on consumer outcomes.

The proper development of a disability workforce that provides for a matching of the supply of psychologist providers against demand for psychology services requires the NDIA to act on issues such as:

Cost absorption by government by addressing the cost of TPV, especially for small practices with small customers bases
Exemption from TPV based on existing regulation, expertise, specialist knowledge, peer acclamation/recognition (e.g., as evidenced by tertiary-level teaching)
Unnecessary red tape and burden of administration in service delivery and
The, already apparent, trend toward NDIS planners and Local Area Co- ordinators recommending against the use of registered psychologists (who have a minimum of 6 years training) in favour of lesser-qualified providers of psychology interventions.

The health professionals likely to work under the NDIS, are not ready for the types of market place NDIS wants. If they are to be retained, the APS believes that is a clear need for business

As indicated above, many practitioners have commented upon lack of, too much or confusing and contradictory information being provided from the NDIS/NDIA about various aspects of the scheme. The APS believes that it is important that the NDIA review its communications around workforce development for the emerging market and make use of professional associations to better inform practitioners and participants about this. These communications will again be most effective if they are included as part of a targeted communication strategy.

ToR D. The impact of pricing on the development of the market

The existence of a quality-sensitive pricing mechanism that appropriately reflects the nature of the services delivered and the skill level and capacity of the provider to deliver same under the Scheme is critical to its success. This mechanism needs to appropriately reward practitioners, while ensuring the supply of appropriate, necessary, evidence based and high-quality services to participants in the Scheme.

The APS views this as a complex requirement for several reasons:

 First, it is not simply an issue of scheduling the highest possible service-fee the market can bear. This because there is not necessarily a relationship between higher fees and better services, as service quality is not inevitably determined by the rate of remuneration.

Higher fee-for-service payments also have the potential to contribute to a de- professionalised service delivery system due to the operation of opportunity costs. This is because, although NDIS participants are entitled to the highest quality services possible, and practioners may reasonably expect to be appropriately remunerated for their services, participants and their guardians will inevitably face pressure to choose between plan items due to the fiscal constraints of care plans.

In the situation, many APS members have predicted that families will mostly likely access NDIS services through self-managed funds. This raises the distinct possibility that without effective oversight mechanisms, “for-profit” entities will focus their activities on “low demand cases” to the exclusion of “complex cases”.

Decision making based on economic factors is more likely to occur in self- managed rather than NDIS-managed plans. In what is already a complicated system, it also has the potential to impact most upon those individuals with significant needs or for whom their families are less able to negotiate (e.g., those from families that are impecunious or have multiply disabled members) will not be able to develop sufficient plans and funds for their needs whereas individuals and their families and carers who are more capable due to education or income will obtain more favourable incomes.

Thus, there is the potential for an income-discriminatory system in which there is the risk of a grey market of non-registered NDIS providers in a range of areas where consumers choose to self-manage all or a portion of their plan/entitlements. This will result in a loss of the universality that is implicit to the Scheme.

 As previously observed by the APS in its April 2015 submission to the NDIS Public Consultation Paper on the Proposal for A National Disability Insurance Scheme Quality and Safeguarding Framework, it has significant concern around the impact of a marketplace culture on the ability to ensure quality services. To meet participant needs, service provider organisations are required to engage the right person with the right knowledge and skills for the task at hand. There will be considerable pressure on providers to recruit a cheaper workforce with inadequate knowledge, skills and experience to deliver the complex services that might be required by a person with a disability. For example, moving

complex behaviour management interventions typically provided by senior highly experienced psychologists in state-based disability services to an open marketplace has the potential to reduce access to quality services given new organisational service providers may seek to deliver such services by not- appropriately qualified staff who may or may not be under the supervision of an experienced and regulated health professional. Such actions would place consumers at risk from receiving an inadequate service that does not provide effective outcomes.

 As stated above, ECS services in Victoria are in the process of transitioning into the NDIS with requirements that practioners not already registered as state or federally accredited practitioners, do so for that purpose and undergo and self- funded external audit (third party verification or audit) for that purpose. Many members have indicted to the APS they will not be seeking third party verification to provide ECS services because of the expense involved. Many of these providers have a great deal of specialist experience in the delivery of early childhood services and expressed concern about the impact on participants of psychologists declining involvement in the NDIS to deliver ECS services due to that cost.

Several stressed that Australian Health Practioners Regulation Authority and third-party funder systems have stringent requirements to practice as a psychologist and that the meeting of those requirements should be sufficient in a highly regulated profession. Feedback has indicated that the NDIS registration process was already complicated and that this was yet another unnecessary barrier that would deter them from providing their expertise to this client group.

A market mechanism with insufficient safeguards that unwittingly fails to adequately support health professionals will lead to Scheme de- professionalisation. It also carries with it the risk of both over and inappropriate-servicing, and is contrary to the needs of NDIS participants. This is because the leverage of large NGOs and for-profit entities, with significant economies of scale, will operate to compromise the market through the collapse of competition on the basis of service unit delivery costs and prices that can neither be absorbed nor met by smaller enterprises and solo- practioners. This relates to both the income (pricing) and expense (via registration and administration cost) sides of the business equation.

In summary, the APS believes that the NDIA needs to recognise and act upon the need to ensure the existence of level playing field that preserves and protects the interests of NDIS participants. This cannot be achieved without intervention to introduce and maintain pricing mechanisms that ensure quality service delivery and a market places that acts to preserve competition which promotes participant

freedom of choice

ToR E. The role of the NDIA as a market steward Market stewardship is an incredibly important function that needs to be given due attention by the NDIA. This will inevitably involve the NDIS Quality and Safety Commissioner and Commission.

As noted throughout this submission, concerns have been expressed about the rapid rollout of the NDIS and its implications on the disability workforce. In particular, there is a lack of a clear picture about the true nature of the market. How many participants will be involved in the Scheme and the number, type and skill level of the practioners required to meet participant demand has not been actuarially calculated. Consequently, it is not known if the demand for specialist support services for people with physical and psychosocial disabilities can be adequately met.

Additionally, the NDIA has acknowledged that there are already many instances known to it of over or highly inappropriate servicing driven by the profit motivation. It is the understanding of the APS, that some of these practices may result in prosecutions.

The APS contends that these types of risk can only be minimised by the NDIA taking an active role on stewardship. The failure market stewardship will have detrimental consequences to participants and their families.

ToR F. Market intervention options to address thin markets, including in remote Indigenous communities In its submission to the Productivity Commission, the APS observed that it was concerned about thin markets, especially in rural, regional and remote areas and for Aboriginal and Torres Strait Islander or Culturally and Linguistically Diverse (CALD) communities. The current predicament, in which there is already evidence of demand and supply mismatch, is likely to increasingly problematic as rollout of the NDIS occurs across Australia and state/territory-funded disability services are increasingly withdrawn and untrammeled market forces take the effect.

Psychologists are already struggling to provide services to thin markets due to inadequate remuneration, especially for travel, and administrative burden. Registration costs are also impacting on mainstream providers to thin markets as small, niche private psychology practices (e.g., that specialise in working with CALD communities) cannot afford NDIS registration. Complex service requirements for participants from, or belonging to, regional, rural and remote locations and/or membership of the refugee, indigenous or CALD communities or low SES segment of the community can present with a complexity of demand that need to be addressed by market mechanisms that provide additional payment as

an incentive for uptake.

The APS contends that to have all such interventions in place would have protected vulnerable Australians with disability against the kind of risks outlined in its response to this ToR and across this submission. It is concerned that a move to direct commissioning in thin markets would have a negative impact on existing private psychological workforce in these areas. It is imperative that the existing workforce in these regions is not threatened, but rather activated and supported to develop capacity to deliver services under the NDIS. For psychology practices, there are several mechanisms to expand capacity if practices were assisted to take interns and registrars.

The APS strongly recommends the NDIA consults with the peak bodies of the professions, the APS included, as a matter of urgency to identify solutions to thin markets. Such consultation has not been undertaken by the NDIS despite there being capacity for private psychology practices to take more of a role in such markets if existing barriers were addressed. It is important to note that the barriers for private psychology practices are not only more realistic remuneration (market-rate) and facilitated registration, but also capacity to deliver services to best practice standards (i.e. more appropriate plans).

ToR H. The impact of the NDIS Quality and Safeguarding Framework on the development of the market In detailed submissions to various governmental inquiries, the APS has previously emphasised that under NDIS Quality and Safeguarding Framework (the Framework), agencies providing services must be accredited. It has argued that to be effective, the Framework needs to define the appropriate workforce for delivering service, so that the delivery of specialised interventions is confined to appropriately qualified health professionals.

Accreditation is necessary to avoid the potential disadvantages of operating in a competitive marketplace. Where there is market failure (e.g., in rural and remote regions), it is even more important to have accreditation to avoid ease of operation of agencies not providing services to a required standard.

Accreditation, however, has the potential to be burdensome to providers and to act a deterrent to small practices and solo practioners delivering services under the Scheme. This will have the reverse effect to that intended by the Safety and Quality Framework. It should not work against the viability of single or small group practitioners and the NDIA needs to act promptly to financially support such practitioners generally, but especially where they operate in market segments at risk of failure due to the costs incurred in accreditation (e.g., in early childhood, behavioural support and regional rural and remote areas).

This is already occurring. In the process of writing this submission, the APS

surveyed the profession around TPV, with specific reference to recently released requirements in relation to ECS in Victoria. Members indicated that the introduction of costly TPV has made it either unaffordable or not cost effective for individual/smaller/part-time practices to take on children under the age of seven years. They also made the point that children with significant intellectual disabilities - for example, Autism Spectrum Disorder - are much better suited to smaller practices with quiet environments, due to their typical sensory hypersensitivity. They made it clear that the need for TPV needs to be carefully balanced against the freedom of participants to choose their disability provider which is explicitly provided for in mission statement of the NDIS. Such unintended impacts of the Framework have been observed by consumer representatives who have specifically indicated their fears around negative outcomes inherent in small organisations being disadvantaged in relation to big providers.

Members have also indicted that they are currently able to work with participants under a variety of third party systems - for example, through Medicare, TAC, VOCAT, Employee Assistant Programs, health insurance and private funding. They emphasised that those parties accept their qualifications, yet the NDIS requires that they become audited - for example, in order to work with children with ECS needs. They also expressed their frustration with what they consider to be unnecessary red tape and inconsistent recognition of their qualifications and the service discontinuity problems that will result from the NDIS’s current accreditation requirements.

The APS strongly believes that for an accreditation process to achieve the stated aims of driving safety and quality, it must be accompanied by effective external monitoring with sufficient powers. This is particularly the case in areas of market failure where quality could be compromised without sufficient external monitoring mechanisms.

Members have repeatedly impressed upon the APS the need for the need clearer communications from NDIS about the quality and safeguarding framework and increased consultation with the professions. The APS believes it is crucial that the Australian Government through the NDIA works with the PAS and other profession to increase the effectiveness of communications around the Scheme.

The APS believes the NDIA needs to act to financially support smaller organisations or those operating in areas of the Scheme where there is the risk of market failure.

The safety of NDIS participants with self-managed plans must also be addressed by the Framework. As a minimum, consumers must have access to information on a nationally-held barred persons list and be able to seek advice on service appropriateness for issues and quality. The latter is important to avoid consumers

inadvertently choosing ‘cheap’, but low quality or inappropriate providers who fail to provide adequate service.

It also believes that the NDIA needs to better-implement these and other checks and balances while acting in a red tape minimising, not multiplying, fashion.

3. Conclusion

In summary, the APS has a range of concerns about NDIS market readiness issues. It contends that if these issues are not addressed, they will severely impact on the capacity of the scheme to improve the quality of life for people with a disability and hence act as a barrier to the achievement of the vision and goals of the NDIS. It is imperative that issues relating to new markets, the disability workforce, the impact of pricing, the required interventions to address the problem of thin markets and the impact of the Quality and Safety Framework on transition into the Scheme are addressed in order to prevent ongoing NDIS implementation failures. It is important to recall the stated intention of the NDIS and for the NDIA to act in a timely and consultative fashion with key stakeholders to address existing and emerging concerns so that the Scheme’s goals can be effectively realised.