Submission 63 — The Royal Australian College of Physicians — Market Readiness | External submission

From the President

22 February 2018

Mr Gerry McInally Committee Secretary Joint Standing Committee on the National Disability Insurance Scheme P O Box 6100 Parliament House CANBERRA ACT 2600

Via Email: ndis.sen@aph.gov.au

Dear Mr McInally

National Disability Insurance Scheme - Market Readiness

Thank you for the opportunity to contribute to the Joint Standing Committee’s review into market readiness for the National Disability Insurance Scheme (NDIS).

The Royal Australasian College of Physicians (RACP) represents over 20,000 specialist physicians and paediatricians, many of whom work with patients who are living with or have recently acquired disability. We fully support the goals of the NDIS and are open to working with legislators, the National Disability Insurance Agency, and other stakeholders to help ensure the Scheme’s success.

Please find enclosed the RACP’s recently released Position Statement on the National Disability Insurance Scheme. Additionally, I have provided a copy of our submission to the development of the Productivity Commission’s report on the costs of the NDIS, which was ultimately released in October last year.

I would ask that the Joint Standing Committee consider both these documents, as well as the Productivity Commission’s report, as it conducts its inquiry. I have highlighted some of the key points that our members feel are significant in the remainder of this letter.

The NDIS in general:

The rollout of the NDIS should be slowed as necessary to ensure that each participant receives an effective and comprehensive planning process to match their supports to their needs;
Information, Linkages and Capacity (ILC) services should be fully funded throughout the NDIS rollout transition period; and
The rollout of the NDIS will have workforce implications for disability and other mainstream services, thus collaboration to improve outcomes and avoid cost shifting is needed.

145 Macquarie Street, Sydney NSW 2000, Australia • Tel: +61 2 9256 5444 • Fax: +61 2 9252 3310 Email: racp@racp.edu.au • Web: www.racp.edu.au • ACN 000 039 047 • ABN 90 270 343 237

All of the above points were supported by the Productivity Commission’s October 2017 report into the NDIS’ costs. We specifically support the Productivity Commission’s recommendation that ILC funding be increased to $131 million per year from now through 2019-20. This will allow the NDIA to invest in the appropriate level of ILC activities and an ILC Framework, which in turn will maximise the impact supports have on the ability of individuals to achieve their goals. It is important that these are additional funds, and not drawn from existing funding of the Scheme.

On the issue of mainstream services working together, the Productivity Commission has recommended that a standing item on the NDIS be included at each COAG Council that is responsible for a related mainstream service, to address gaps in and barriers to service provision. The RACP supports this approach.

Early Childhood Early Intervention (ECEI):

The RACP supports the Early Childhood Early Intervention (ECEI) approach taken for children aged 0-6 years old, as well as plans for an ECEI approach for the 7-14 year old cohort;
The growing disability workforce and planners in particular must have the expertise to understand the types of supports needed by children with high or complex needs, particularly those with developmental disabilities or challenging behaviours; and
Expert resource teams should be introduced to support services where the needs of children are highly complex, and will ensure providers can meet a child’s unique support needs.

The Productivity Commission noted that the ECEI process is relatively new, and is vital to ensuring that children can access the NDIS quickly where they are likely to need supports. With that said, the RACP supports the Commission’s recommendation that a process for quickly changing the lists of eligible conditions as new information comes to light be established to ensure streamlined access.

It is also important that sufficient safety nets are in place for particularly vulnerable children and families who may not be well served by a market-based system which may not sufficiently emphasise engagement with consumers.

Aged care and the NDIS:

The NDIA must work with aged care services and their funding bodies to ensure a two-tiered system of care standards for people living with disability over the age of 65 does not emerge; and
Clarification of the NDIS eligibility status for people living with early-onset dementia is important.

Though related to our above feedback on the NDIS and its interaction with other mainstream services, the aged care system merits specific mention. There are currently uncertainties around the likely level of NDIS participation above the age of 65 (eligibility will, in general, cease once a person enters residential aged care). It is important that these two key sectors collaborate with each other and with the health system, to ensure smooth transitions and appropriate support.

The health system and the NDIS:

Physicians and paediatricians already play a significant role in diagnosis and assessment, particularly for ECEI and acquired disability;

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The capacity of the health system to provide initial and follow up assessments will be important in facilitating the efficient and effective development of plans that help individuals meet their goals;
There is a need for greater clarity around the division of funding responsibilities between the NDIS and the health system;
Hospitals and primary care providers need a strong working relationship with the NDIS to ensure the smooth transition of NDIS participants to and from inpatient and outpatient settings when necessary; and
Health providers have a role in working with NDIS disability care providers to ensure they have the skills to maintain or improve the health of NDIS participants living with disability.

The Commonwealth Government has a role in ensuring that the NDIS and health systems are able to work together effectively. That includes coordinating with the States and Territories through COAG and other facilities where they have shared responsibility for delivering health care. Insufficient availability of appointments for assessment will result in delays to NDIS planning. Additionally, NDIS providers and their employees need the appropriate skills to manage the health needs of NDIS participants. Changes in these areas will ensure that NDIS providers, the health system and those who access the NDIS will have access to a more collaborative and tailored system which appropriately supports the needs of Australians living with disability.

Concerns linger around the division of funding responsibilities for various supports. For example, RACP members have reported their patients face significant challenges in receiving funding for home modifications after they have acquired a disability. It is the RACP’s understanding that such supports should be covered under the NDIS, however this experience has not been consistent.

Quality and the NDIS:

There is a need for a strong system of accountability for providers, who must demonstrate that they facilitate appropriate training for carers;
A robust process for dispute resolution in circumstances of disagreement over the level and nature of supports; and
Protections against the NDIS being ‘gamed’ by unscrupulous providers, as has been seen in other sectors such as child care and education.

Quality control and management is likely to be closely linked to the success and financial sustainability of the NDIS over the long term. Clear guidance on the expectations of market participants is important.