Victorian Autism Specific Early Learning
and Care Centre (Vic ASELCC)
Submission to the Joint Standing Committee
on the Market Readiness for NDIS
Febuary 2018
CONTENTS
-
SUMMARY OF RECOMMENDATIONS 1
-
INTRODUCTION 3
-
THE TRANSITION TO A MARKET-BASED SYSTEM FOR SERVICE PROVIDERS 4
Recommendations 4
-
PARTICIPANT READINESS TO NAVIGATE NEW MARKETS 5
Recommendations 5
-
THE DEVELOPMENT OF THE DISABILITY WORKFORCE TO SUPPORT THE EMERGING MARKET 6
Recommendations 6
-
THE IMPACT OF PRICING ON THE DEVELOPMENT OF THE MARKET 7
Recommendations 8
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OTHER RELATED MATTERS 9
Recommendations 9
REFERENCES 10
Contributed to by:
Jessica Feary (Parent Coaching Program Coordinator)
Gabrielle Toscano (Autism Playmates Program Coordinator)
Kristy Capes (Social Participation Program Coordinator)
Katherine Pye (Vic ASELCC Senior Coordinator)
Summary of Recommendations
-
Summary of Recommendations
I. Provide a structured learning program or offer grants to small ECEI service providers to assist in the development of business capabilities required to succeed in a market based system. Similar to the Australian Government’s ‘New Enterprise Incentive Scheme’ (1), which supports new small businesses, a program that provides business mentoring and support during the first year of operation under the market-based system would enable small ECEI service providers to succeed. II. Develop national guidelines for service provision of early childhood intervention in the NDIS, detailing the model and providing practical examples of how to uphold evidenced based intervention principles such as how an ECEI Service Provider can implement ‘collaborative teamwork’ within the NDIS Price Guide. III. Families be provided with support to seek out information about evidence-based interventions prior to their NDIS planning meeting to enable them to advocate for their child/ren. This could be provided through a website such as the ‘Raising Children’s Network’ that provides simple, easy to read information about each intervention and the research underpinning it.IV. The ECEI partners be provided with additional training on ASD and evidence-based interventions to enable them to support families to make good decisions.
V. Prior to their planning meeting, vulnerable families be offered the opportunity to meet with an impartial party who understands the local market and the evidence-based interventions available.
VI. Develop a funding stream in the NDIS price guides for ECI practitioners and services to fund staff PD. This dedicated funding stream may encourage ECI practitioners to access PD.
VII. Develop guidelines for ECI practitioners and services accessing the dedicated PD and on-site training and supervision funding streams. Guidelines should reference the ECIA Best Practice Guidelines (2) including the key principle that ECI practitioners are accessing PD that supports practitioners to work “from a base of evidence informed by the latest research and practice”.
VIII. Remove NDIS price controls as soon as possible
IX. Complete a Joint Standing Committee Inquiry into Autism and the NDIS.
X. Undergo a formal evaluation of the price guide’s appropriateness for a wider range of services/providers in the ECEI context, including autism-specific early interventions. Consult with providers in this process.
XI. Enable a wider range of services to be developed and offered (through ending price regulation, or increasing flexibility in pricing), along with routine assessments of the evidence base and effectiveness of supports offered (to be built into the Quality & Safety Framework). Enable providers to account for the cost of these assessments in their pricing.
XII. Share and respond to the independent pricing review (IPR) as quickly as possible, identifying its relevance to the ECEI and autism-specific field.
XIII. Provide clear communication about changes to the pricing caps/system to providers so that they can plan appropriately (e.g. a notification in the MyPlace portal, or email direct to primary contact for each service provider).
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Summary of Recommendations
XIV. Review the NDIA’s recommendations for provision of intensive intervention funding to children with
ASD, increasing access to these programs (and therefore supply of these programs in the market) to
younger children, with an increased range of support needs.
XV. Review the ECEI pathway and timeliness of commencement of intensive interventions for very young
children at risk of ASD.
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Introduction
- Introduction
The Victorian Autism Specific Early Learning and Care Centre (Vic ASELCC) welcomes the opportunity to provide a submission to the Joint Standing Committee on the Market Readiness for NDIS.
As one of the six federally funded Autism-Specific Early Learning and Care Centres, the Vic ASELCC is committed to addressing the needs of young children with Autism Spectrum Disorder and their families through providing best practice early intervention, contributing to the evidence on effective early intervention and disseminating knowledge and training.
The Vic ASELCC provides a range of early intervention options for young children with ASD using the Early Start Denver Model (ESDM) including:
- Centre-based group delivery
- Autism Playmates (an in-home intervention program)
- Parent Coaching
Our early intervention programs are accessed by a diverse range of families; we prioritise providing a service to the most vunerable members of our community. Our transdisciplinary team of educators, teachers, occupational therapists, speech pathologists, psychologists and researchers are dedicated to collaborating to provide a comprehensive, highly specialised, individualised intervention program for each child.
The Vic ASELCC is committed to advancing knowledge and contributing to the evidence base on effective early treatment for ASD. We have research partnerships with organisations including the Olga Tennison Autism Research Centre (OTARC), Gowrie Victoria, Griffith University, National Disability Insurance Agency, the Department of Social Services and the University of California, Davis (UC Davis). We have published a number of papers in peer-reviewed journals and have presented our findings at a range of national and international conferences.
We believe that the dissemination of training and research is of utmost importance. The Vic ASELCC is recognised by the MIND Institute at UC Davis as the Flagship site for the group implementation of the ESDM, an evidence based intervention for young children with ASD. We are a training site for the ESDM, and provide training to professionals both nationally and internationally. We value inclusion and work locally with early childhood educators to capacity build their knowledge and skills on the successful inclusion of children with ASD in mainstream early childhood settings.
Vic ASELCC and NDIS The Vic ASELCC has been a registered NDIS provider since 2016. We have supported a number of families through the NDIS planning process, including appeals and reviews. The Vic ASELCC is currently in the process of transitioning from block funding to NDIS. In addition, we have conducted various research projects with grants from the National Disability Insurance Agency. We feel that this experience puts us in a good position to provide comment on the market readiness for the NDIS.
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The Transition to a Market-Based System for Service Providers
- The Transition to a Market-Based System for
Service Providers
Current Situation Challenges In order to survive and succeed in a market-based • Managers of small ECEI services are required to system, early childhood early intervention (ECEI) develop business skills, or invest and engage service providers are required to develop skills private contractors, to prepare the organisation outside of the typical realm of allied health or to survive in a market-based system. Small ECEI education professionals. Service providers have not service providers cannot absorb this cost as received support or structured opportunities to seamlessly as larger service providers can. develop vital capabilities such as financial • ECEI NDIS service providers are not management, marketing and legal compliance. As a consisistently implementing evidence-based result, small ECEI service providers have been intervention principles as per the model of required to engage and invest in private contractors practice under the NDIS. to facilitate a successful transition. • It is difficult for ECEI providers to fund professional development opportunities for staff. The Early Childhood Intervention Australia (ECIA) National Guidelines for Best Practice in Early Childhood Intervention identify ‘Collaborative Teamwork Practice’ as a key principle where “the Recommendations family and professionals work together as a 1. Provide a structured learning program or offer collaborative and integrated team around the child, grants to small ECEI service providers to assist in communicating and sharing information… with one the development of business capabilities team member nominated as a key worker and main required to succeed in a market based system. person working with the family (p.13) ” (2). In Similar to the Australian Government’s ‘New contrast, the implementation of NDIS ECEI approach Enterprise Incentive Scheme’ (1), which supports has indirectly encouraged families to engage a range new small businesses, a program that provides of professionals who work independently with the business mentoring and support during the first child and have limited interaction with one another. In year of operation under the market-based system addition, ECEI service providers have been hesitant to would enable small ECEI service providers to communicate and collaborate with other ECEI service succeed. providers as it is unclear what is billable under the NDIS Price Guide. 2. Develop national guidelines for service provision of early childhood intervention in the NDIS, detailing the model and providing practical examples of how to uphold evidenced based intervention principles such as how an ECEI Service Provider can implement ‘collaborative teamwork’ within the NDIS Price Guide.
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Participant Readiness to Navigate New Markets
- Participant Readiness to Navigate New
Markets
Current Situation Challenges Families are not receiving adequate information to • It is difficult to ‘protect’ families from making assist them to identify evidence-based interventions poor choices or to differentiate between services. Families have • Some families with less knowledge/resources reported that Planners and Early Childhood Partners are less able to request and advocate for have been unable to assist as they have often had evidence-based supports limited knowledge on both ASD and interventions for • Some families do not have the understanding ASD. As a result, families who are highly educated required to choose between being plan- managed and more able to advocate for themselves have and self-managed received better supports and funding to access • Some families do not have the skills required to higher quality, evidence-based services. manage money and relationships with service providersFamilies have reported that they are unsure of the advantages and disadvantages between plan- managed and self-managed NDIS budgets. Some families have chosen to self-manage to enable them Recommendations to access services that are not registered with NDIS. 1. Families be provided with support to seek out However, many of these families have not been information about evidence-based interventions provided with support to build skills in managing prior to their NDIS planning meeting to enable money and relationships with service providers. them to advocate for their child/ren. This could be provided through a website such as the ‘Raising Children’s Network’ that provides simple, easy to read information about each intervention and the research underpinning it
2. The ECEI partners be provided with additional
training on ASD and evidence-based
interventions to enable them to support families
to make good decisions.
3. Prior to their planning meeting, vulnerable
families be offered the opportunity to meet with
an impartial party who understands the local
market and the evidence-based interventions
available.
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The Development of the Disability Workforce to Support the Emerging Market
- The Development of the Disability Workforce
to Support the Emerging Market
Current Situation Challenges The ECIA Best Practice Guidelines (2) emphasise • NDIS price guide does not adequately allow for evidence-based intervention as best practice early PD childhood intervention (ECI). The guidelines • ECI practitioners are not engaging in PD recommend that ECI Practitioners engage in ongoing • NDIS price guide does not adequately allow for Professional Development (PD) to develop and on-site training and supervision maintain skills and knowledge of evidence-based • ECI practitioners require ongoing support and practices. The NDIS price guide does not allow for training to effectively ‘capacity build’ the funding of staff PD, therefore currently many ECI • There are no guidelines in place supporting ECI Practitioners are either not accessing PD or are self- practitioners and services to determine how to funding PD. fund their PD and on-site training and supervision in the NDIS price guides i.e impact, costs and Previously, ECI services have provided on-site benefits to individual families training and supervision to staff. This practice is supportive of the ECIA Best Practice Guidelines (2) recommendation that ECI practitioners engage in ongoing review and monitoring of their practice. Recommendations Currently, the NDIS price guide does not allow a 1. Develop a funding stream in the NDIS price direct way to fund on-site training and supervision, guides for ECI practitioners and services to fund therefore it has been difficult for services to provide. staff PD. This dedicated funding stream may encourage ECI practitioners to access PD. The ECIA Best Practice Guidelines (2) indicate that capacity building is core to ECI service delivery. The 2. Develop a funding stream in the NDIS price guidelines also state that many ECI practitioners are guides for ECI services to fund on-site training not trained on how to deliver coaching to adults. and supervision. Consequently, this is an identified gap in the disability workforce that requires addressing through both PD 3. Develop guidelines for ECI practitioners and and on-site training and supervision services accessing the dedicated PD and on-site training and supervision funding streams. Guidelines should reference the ECIA Best Practice Guidelines (2) including the key principle that ECI practitioners are accessing PD that supports practitioners to work “from a base of evidence informed by the latest research and practice”.
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The Impact of Pricing on the Development of the Market
- The Impact of Pricing on the Development of
the Market
Current Situation regularly measuring the fidelity of therapists to ensure integrity of intervention implementation (4). The dramatic increase in funds available to people The ECIA Best Practice Guidelines and a report bywith a disability through the NDIS creates a huge rise Roberts & Williams (2, 5) also recommend thatin demand for services and supports. As stated in intervention be carried out in a naturalistic setting, bythe Productivity Commission’s report, a significant a team of well-coordinated clinicians/educators:aincrease in the “quantity, quality, range and transdisciplinary model. True transdisciplinaryresponsiveness” of disability supports is required to teamwork requires regular, formal collaborationmeet this change in demand(3). The disability sector among team members to share information andworkforce is needed to double in the period of 2014- skills, enriching each team member’s skill set. These2019(3). In addition, there is a higher number of critical features of a successful interventionchildren with autism and intellectual disability than approach for young children with ASD require timeassumed in the NDIA’s modelling of the Scheme(3). that is not supported by the current NDIS pricing, further limiting the range and quality of earlyThe NDIS model is based on the premise that an intervention services that are viable in the Scheme. open market will encourage competition between providers and effectively control the price of supports. Currently, while the market responds to the Some service providers (generally private and highly increase in demand, the pricing of the majority of specialist practices) have elected not to register as supports available under the Scheme is capped to NDIS providers, so that their prices need not be ensure that profit margins are controlled, capped. These organisations only provide supports accessibility is optimized and financial sustainability to participants who have chosen to self-manage their of the Scheme is enabled. This price regulation limits funds. This means the most vulnerable participants, market growth, as providers are forced to offer a who are not able to self-manage their funds, cannot limited range of services that are viable under the access the same range of supports that others can. price guides. For example, despite efforts to reduce costs, the Vic ASELCC’s home-based intervention The NDIA and Productivity Commission have both program may not be viable under the existing price agreed that communication, transparency and guide. timelines of the pricing process, including price regulation, must be improved(3). An independent In addition, the current pricing caps do not support pricing review (IPR) completed by McKinsey & Co in overhead costs necessary for high quality service 2017 will be released in March 2018, with 25 formal provision such as service coordination, recruitment recommendations. and training expenses. For example, more experienced therapists should be employed at a higher pay rate than new/recent graduates, but the pricing system encourages providers to employ less experienced clinicians to make savings. With the current pricing caps, businesses are likely to cut corners, limiting the quality of services available in the market.
Empirical evidence demonstrates that naturalistic, developmental and behavioural interventions (NDBIs), such as the Early Start Denver Model, are some of the most effective interventions for young children with ASD (4). These approaches share a number of common features, including a system of
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The Impact of Pricing on the Development of the Market
Challenges The current pricing caps: a) restrict the range of supports that can be delivered b) limit the quality of services provided c) reduce service providers’ capacity to deliver interventions that meet evidence-based standards d) may result in issues of increased staff turnover and reduced continuity of care e) create inequity for participants who are unable to self-manage their NDIS budget
Recommendations
1. Remove NDIS price controls as soon as possible
2. Complete a Joint Standing Committee Inquiry
into Autism and the NDIS.
3. Undergo a formal evaluation of the price guide’s
appropriateness for a wider range of
services/providers in the ECEI context, including
autism-specific early interventions. Consult with
providers in this process.
4. Enable a wider range of services to be developed
and offered (through ending price regulation, or
increasing flexibility in pricing), along with routine
assessments of the evidence base and
effectiveness of supports offered (to be built into
the Quality & Safety Framework). Enable
providers to account for the cost of these
assessments in their pricing.
5. Share and respond to the independent pricing
review (IPR) as quickly as possible, identifying its
relevance to the ECEI and autism-specific field.
6. Provide clear communication about changes to
the pricing caps/system to providers so that they
can plan appropriately (e.g. a notification in the
MyPlace portal, or email direct to primary contact
for each service provider).
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Other Related Matters
- Other Related Matters
Current Situation Research has consistently indicated that naturalistic Challengesdevelopmental and behavioral interventions are the state-of-the art treatment for young children with ASD • The NDIS funding packages and pricing guide (4). A significant body of research has also does not support children’s access to evidence- demonstrated that intensity of intervention impacts based early, intensive intervention on children’s learning and social outcomes, with • Only the most severely impaired children are able recommendations made to the NDIA that children to access funding for intensive interventions receive 15-25 hours per week of direct intervention, • Many vulnerable families are not able to delivered by trained clinicians 1:1 or in small groups advocate for intensive level funding for their (5). Children generally make the best gains when this child/ren intensive intervention is delivered early – from approximately the age of 18 months (5-7). Recommendations
1. Review the NDIA’s recommendations for
provision of intensive intervention funding to
children with ASD, increasing access to these
programs (and therefore supply of these
programs in the market) to younger children, with
an increased range of support needs.
2. Review the ECEI pathway and timeliness of
commencement of intensive interventions for
support children’s access to the most effective, early,
very young children at risk of ASD.
intensive intervention.
3. Remove NDIS price controls as soon as possible.
We are concerned that only the children who are most severely impaired are able to access intensive intervention plans. While it is appropriate that these 4. Complete a Joint Committee Inquiry into ASD children receive a high level of support, it is also and the NDIS. critical that children who are mild-moderately impaired also have access to these intensive 5. Undergo a formal evaluation of the price guide’s programs, as this is their best chance of closing the appropriateness for a wider range of gap between their developmental trajectories and services/providers in the ECEI context, including those of their peers. In addition, group-based autism-specific early interventions. Consult with programs are better able to facilitate peer providers in this process. interactions and peer-to-peer learning when there is a range of children’s skills and support needs in a 6. Enable a wider range of services to be developed group. Funding only the most impaired children for and offered (through ending price regulation, or (intensive) group programs would likely impact increasing flexibility in pricing), along with routine negatively on the effectiveness of those programs. assessments of the evidence base and effectiveness of supports offered (to be built into In our experience, advocating for a child to receive the Quality & Safety Framework). Enable intensive level funding requires strong providers to account for the cost of these communication and health literacy skills in family assessments in their pricing. members. The most vulnerable families (e.g. from CALD backgrounds, with poor literacy or coping with additional needs of their own) are the least able to advocate for the best intervention for their child/ren. This results in inequities in the Scheme.
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References
The Vic ASELCC Team is thankful for the opportunity to contribute to this important Joint
Standing Committee. We look forward to reviewing your findings and recommendations.
References
1. Australian Government: Department of Jobs and Small Business. Self-employment- New Enterprise
Incentive Scheme (NEIS) 2017
2. Early Childhood Intervention Australia. National Guidelines for Best Practice in Early Childhood Intervention
2016.
3. Productivity Commission. National Disability Insurance Scheme (NDIS) Costs. Canberra 2017.
4. Schreibman L, Dawson G, Stahmer AC, Landa R, Rogers SJ, McGee GG, et al. Naturalistic Developmental
Behavioral Interventions: Empirically Validated Treatments for Autism Spectrum Disorder. Journal of
Autism and Developmental Disorders. 2015;45(8):2411-28.
5. Roberts J, Williams K. Evidence based/evidence informed good practice for supports provided to preschool
children, their families and carers. National Disability Insurance Scheme 2016.
6. Rogers S, Dawson G. Early Start Denver Model for Young Children with Autism. Promoting Language,
Learning, and Engagement New York The Guildford Press 2010.
7. Vivanti G, Dissanayake C. Outcome for Children Receiving the Early Start Denver Model Before and After 48
Months. Journal of Autism and Developmental Disorders. 2016;46(7):2441-9.
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