Submission to the Senate Standing Committee regarding the National Disability Insurance Scheme

Amendment (Getting the NDIS Back on Track No. 1) Bill 2024.

Introduction

We write this submission as the Chief Executive Officer (CEO) and Chief Operating Officer (COO) of CDS of the Centre for Disability Studies (CDS). We are a not-for-profit organisation that provides rigorous research and translation, consultancy services, social inclusion programs, professional education and capacity building, and specialist clinical and allied health service delivery. We hold a research affiliation with the University of Sydney.

We are acutely aware of the need for urgent NDIS reform. We have closely followed the proceedings of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (DRC) and actively participated in the NDIS Review and DRC process.

Our submission will focus on 32L Assessment of participant’s need for supports.

Our proposal is to provide government with an already established, validated and Australian designed support needs assessment tool that can address many of the assessment tool related recommendations from the review and associated Amendment Bill. The tool has been adapted for the Disability Supports for Older Adults support assessment process by the Department of Health and Aged Care since 2020.

Context

As part of the NDIS Review, CDS consulted, on request, with the NDIS Review Secretariat and Prof Bruce Bonyhady (Co-Chair, NDIS Review) on several occasions about a needs assessment process for NDIS participants and the suitability of the CDS developed tool, the Instrument for the Classification and Assessment of Support Needs (I-CAN).

The final report from the NDIS Review (the Review) makes a suite of recommendations about the need for a fairer and more consistent participant pathway (Recommendation 3), including introducing a new needs assessment process.

This needs assessment process is recommended to be holistic and undertaken by a professional (e.g. allied health, social work, youth work or similar) with disability sector training and experience and extensive training in the completion of the needs assessment (Commonwealth of Australia (CoA), 2023a). These recommendations are welcomed by CDS.

The NDIS Amendment Bill introduces a new needs assessment process under section 32L that happens once a participant is deemed eligible for the NDIS. Central to this is an assessment tool that is “highly”

Instrument for the Classification and Assessment of Support Needs (I-CAN)

The Instrument for the Classification and Assessment of Support (I-CAN), developed by CDS, is based on extensive research into the need for an innovative, rigorous and robust system of identifying and classifying support needs (Arnold et al., 2014; Arnold et al., 2015; Riches et al., 2009a; Riches et al., 2009b). The tool has been in operation since 1998 and is currently up to version 6.

The I-CAN is conceptually based on the World Health Organisation’s International Classification of Functioning, Disability, and Health (ICF). The tool maps a person with a disability’s support needs to 12 whole-of-life domains. Three domains about health and well-being supplement the ICF’s Activity and Participation domains. In line with the ICF, the tool can be applied universally regardless of diagnosis or disability type.

The tool is person-centred, strengths-based and validated for use for people aged 16 and over. It can be used flexibly and captures the most relevant support needs for the assessment. Notably, the tool was developed and researched in Australia, meaning the language and terminology are relevant for use across contexts in Australia.

The I-CAN is administered by allied health professionals, registered nurses, enrolled nurses, educators, and NDIS behaviour support practitioners. Other professionals can apply to become I-CAN assessors but must demonstrate relevant skills and experience to be considered eligible. In 2024, CDS launched an online self-paced training course, this enables practitioners to complete the training flexibly and in their own time. Over the past five years, 304 clinicians across Australia have been trained to administer the I-CAN. The tool is also used in several international contexts, including the United States, South Korea and Singapore.

The I-CAN is administered via a semi-structured interview. Assessors enter this information into an online platform and score the support needs in frequency and type. The online platform produces a report based on this information.

In 2019, the National Disability Insurance Agency recommended the I-CAN tool for the Australian Government Department of Health and Aged Care’s Disability Supports for Older Australians program (previously known as Continuity of Supports). CDS worked collaboratively with the department to develop a custom version of the I-CAN, now known as the I-CAN version DSOA (Disability Supports for Older Australians), which has been in use by the program since 2020.

(i) I-CAN version DSOA

The custom version of the I-CAN mirrors the original I-CAN report but also incorporates a suite of custom questions, and a support calculator, which maps support needs to individual budgets within the remit of the DSOS Service and Price Schedule.

Suitability for the NDIS

A customised version of the I-CAN assessment tool would provide the NDIS with a robust, evidence-based Australian tool, conceptually based on the ICF and appropriate for use across disability types, to complete needs assessments. The tool would aid in developing a whole-of-person budget and be administered by professionals with relevant qualifications and experience.

We recommend a review of the I-CAN v6 and the I-CAN DSOA tool, to consider its suitability, with additional customisations, for the new needs assessment process for NDIS participants. As noted by the NDIS Review, the DSOA program is closely aligned with the NDIS (CoA, 2023b). Extensive work has already been undertaken to build a custom tool to determine participant needs for a program closely aligned with the NDIS. However, the DSOA program is a closed scheme and will eventually cease. It is timely for the NDIS to capitalise on this extensive work for its purposes before the tool is no longer used.

CDS recognises that the Commonwealth may want appropriate control of the assessment tool used for determining reasonable and necessary budgets for NDIS participants and would be happy to discuss suitable arrangements.

We would welcome exploring these opportunities further with the relevant parties.

Yours sincerely,

Associate Professor Mary-Ann O’Donovan Ms Laura Hogan Chief Executive Officer Chief Operating Officer

References

Arnold, S. R. C., Riches, V. C., & Stancliffe, R. J. (2014). I-CAN: The classification and prediction of support needs. Journal of Applied Research in Intellectual Disabilities, 27(2), 97–111. https://doi.org/10.1111/jar.12055

Arnold, S. R. C., Riches, V. C., & Stancliffe, R. J. (2015). Does a measure of support needs predict funding need better than a measure of adaptive and maladaptive behavior? American Journal on Intellectual and Developmental Disabilities, 120(5), 375–394. https://doi.org/10.1352/1944-7558- 120.5.375

Commonwealth of Australia (CoA). (2023a). Working together to deliver the NDIS: Independent Review into the National Disability Insurance Scheme Final Report. https://www.ndisreview.gov.au/sites/default/files/resource/download/working-together-ndis-review-final-report.pdf

Commonwealth of Australia (CoA). (2023b). Working together to deliver the NDIS: Independent Review into the National Disability Insurance Scheme Final Report, Supporting Analysis. https://www.ndisreview.gov.au/sites/default/files/resource/download/NDIS-Review-Supporting-Analysis.pdf

Commonwealth of Australia (CoA). (2024). National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024. https://parlinfo.aph.gov.au/parlInfo/download/legislation/ems/r7181_ems_f83281ef-0f46-4fbb-a59f- 2e19439dcacb/upload_pdf/JC012589.pdf;fileType=application%2Fpdf#search=%22legislation/ems/ r7181_ems_f83281ef-0f46-4fbb-a59f-2e19439dcacb%22

Riches, V. C., Parmenter, T. R., Llewellyn, G., Hindmarsh, G., & Chan, J. (2009a). I-CAN: A new instrument to classify support needs for people with disability: Part I. Journal of Applied Research in Intellectual Disabilities, 22(4), 326–339. https://doi.org/10.1111/j.1468-3148.2008.00466.x

Riches, V. C., Parmenter, T. R., Llewellyn, G., Hindmarsh, G., & Chan, J. (2009b). The reliability, validity and practical utility of measuring supports using the I-CAN instrument: Part II. Journal of Applied Research in Intellectual Disabilities, 22(4), 340–353. https://doi.org/10.1111/j.1468- 3148.2008.00467.x