Australian Music Therapy Association
Submission to:
National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 Via email: seniorclerk.committees.sen@aph.gov.au May 2024
Australian Music Therapy Association (AMTA) The Australian Music Therapy Association (AMTA) is the peak body for music therapy in Australia; representing nearly 900 registered music therapists (RMTs) and advocating for access to music therapy. Our mission is to enable, advance and advocate for excellence in music therapy. Music therapy is an evidence-based practice and allied health profession. In Australia music therapy is delivered by RMTs.
Music therapy is an evidence-based allied health profession that improves the lives of Australians each day
- in disability and mental health services, in healthcare settings, aged care, education, community and palliative care services. Music therapy is delivered by Bachelor and Masters-level qualified and accredited RMTs. AMTA is a member organisation of Allied Health Professions Australia (AHPA) and the National Alliance for Self-Regulating Health Professions (NASRHP). Membership of NASRHP requires all RMTs across Australia to meet 11 regulatory standards to ensure consumers receive quality and safe services from qualified and certified RMTs.
RMTs are recognised therapy service providers in the NDIS; delivering assessments for NDIS entry and plan review, and providing NDIS supports. Music therapy is a stand-alone therapy with a dedicated line item with the NDIS: 15_615_0128_1_3, and participants can access it as part of their therapeutic supports if reasonable and necessary. RMTs design and deliver individualised music-based interventions that support social, communicative, sensory, emotional, cognitive and behavioural skills. Music therapy provides crucial and life-changing supports for people with disabilities and their carers.
AMTA is often in correspondence with the National Disability Insurance Agency (NDIA) and the NDIS Quality and Safeguards Commission on behalf of our members. AMTA has recently submitted a response to the NDIS Provider and Worker Registration Taskforce consultation. We acknowledge and welcome the opportunity to engage in this consultation about the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024.
Our concerns
AMTA welcomes the greater focus on flexibility within the new Bill. However, the lack of detail combined with some new amendments makes it unclear how the Bill will be implemented, and if participants will be negatively or positively impacted. AMTA endorses the AHPA Submission to Senate Community Affairs Legislation Committee Inquiry into National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024.
Ongoing need for better consultation
NDIS has a fraught history when it comes to consulting with allied health. AMTA’s contributions to consultations have often remained unheard and unresolved. We were disappointed to hear about this Bill only when it was introduced to Parliament, without any prior consultation. This relationship echoes AMTA’s relationship with the NDIS at an individual participant level, where RMT assessments are not consistently valued, RMT expertise is misunderstood and the evidence base for music therapy under-recognised.
We trust this consultation will hear and value the voices and expertise of allied health, who in the NDIS often advocate for participants. Allied health peak bodies are highly qualified group with significant and specialist expertise to offer government, the NDIA, the Scheme and participants. We welcome any process that allows participant, carer, support people and provider voices to be heard, and urge government and NDIA to do better in this space.
Clause 10 Definition of NDIS support
At this stage, it is unclear if participants’ existing therapeutic supports will be maintained in the Scheme. AMTA supports a ‘whole-of-person’ approach where this truly enables participant choice and control. Sections 10(b) and 10(c) provide insufficient information to know if participants will be disadvantaged by the new rules. New rules for supports must be developed in consultation with participants, their support people, and allied health professionals.
AMTA notes the Explanatory Memorandum to the Bill which includes a statement about the evidence-base of therapies. AMTA welcomes a focus on delivering high-quality and safe supports via the NDIS and has engaged in numerous discussions with the NDIA about the evidence base for music therapy. We are cautiously optimistic that a stronger focus on evidence base for therapies would both acknowledge the value of music therapy, and recognise that allied health therapies often have limited investment (so may not be supported for example, by a systematic review relevant to an individual NDIS participant). Knowledge from available evidence must be translated in consultation with appropriately qualified and expert allied health professions, including music therapy. AMTA suggests this could occur via the AHPA Disability Working Group. We welcome guidance for participants on effective therapies and supports to ensure the delivery of high quality supports, improve outcomes, and make navigating the scheme for participants and their families easier.
Needs assessments – a rebrand of independent assessments?
There are serious concerns about Section 32L and what constitutes needs assessments within the Bill. Given the history of independent assessments, AMTA’s members along with their participant clients have serious concerns about what constitutes the new needs assessments and how these will be used to determine level of need, funding and budgets. AMTA urges government to engage and collaborate with us and our allied health colleagues to develop and design any needs assessment process, along with needs assessment training and accreditation.
AMTA has serious concerns about any assessment process that disallows a review as initiated by a participant, their carer or support people.
A ‘trust-based approach’ when trust has been eroded
AMTA is curious and cautiously optimistic about how greater funding flexibility will work in practice. However, a ‘trust-based approach’ only works when there is trust in the system. In an environment of limited trust of the NDIA or Scheme administrators, announcements around greater funding flexibility without details is causing significant anxiety on the part of providers and participants. AMTA often fields concerns from NDIS participants about unpredicted or seemingly unfounded limitations to their plan, cancellation of supports or providing misinformation about eligibility or supports. Two participants’ families have recently been incorrectly informed that their selection of music therapy supports is ‘fraudulent’. There is still little trust of the NDIA by participants, and some culture change required in NDIS administration to truly enable choice and control.
AMTA welcomes positive change in the NDIS as described in the NDIS Review. We acknowledge and welcome this opportunity to consult. We strongly believe in the potential of the NDIS for participants, their carers and support people.
We would welcome the opportunity to discuss any of the points raised in this submission, or collaborate to resolve some of the ongoing issues facing therapy support providers in the NDIS.
Contact: Bridgit Hogan (she/her) Chief Executive Officer Australian Music Therapy Association ceo@austmta.org.au