National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill

2024 [Provisions] 12 July 2024 Dear Legislative Affairs Committee

RE: NDIS Bill

I am writing to you as a Mental Health Clinician/Occupational Therapist who works with people with psychosocial disability many of whom are currently on the NDIS. I request that the current proposed reforms do not pass into law. I am very concerned for the future of the participants that I work with, for people with psychosocial, neurodevelopmental and neurological disabilities in particular and all NDIS participants more broadly. I am concerned that there will be less Occupational Therapists working in the NDIS scheme which would be a significant loss due to the skill set being so well matched to increasing functional capacity. The current changes do not express value in our profession and have not included us in key consultation processes such as psychosocial early intervention design and this is very concerning.

I am concerned that the proposed reforms will place unnecessary stress and burden on people with psychosocial disability. I do not support the NDIS legislation in its current form even with the recent amendments.

This includes:

• Being assessed by an unknown person
• Being assessed by someone who may not have suitable qualifications or experience e.g. may not understand dysregulation/meltdowns and dissociation. If they do not understand these concepts, then they will be unable to accurately assess their needs.
• Having an unknown person assess their needs when their whole NDIS budget depends on this assessment going well. For most people I work with meeting an unknown person is very stressful and, in that context, they find planning meetings very stressful, and some choose therefore not to attend those or “freeze” and are unable to advocate for themselves. meetings. With me having been able to do initial applications and FCA’s for some families I already work with and to advocate/attend meetings with them when needed has brought great relief and support to these already stressed families/individuals.
• Being allocated an early intervention pathway which appears to have less choice and control and less options for the person overall.
• Most people I work with have multiple disabilities hence why they are under NDIS – for autistic individuals the list of comorbid health issues is very long – resulting in significant functional impairment for those individuals. The NDIS requests that the primary disability is registered under the NDIS and that funding is for this and not the other ones – this is unfeasible and unreasonable.
• It is not clear what ‘classes’ are but I would hope that it would not result in different rules for people based on their disability group.

Recommendations

• Allied Health professionals that are known to the person with a disability completes a designated assessment and document the person’s needs. This person needs to have suitable qualifications.
• Streamline the assessment process so that it is clear the information that is required. This will save money.
• Occupational Therapists need to have input into the development of functional capacity assessments needs assessment and also program design. We are a key profession in assessment and also have key knowledge that could benefit the government.

I have also recently received disturbing information from Animal Therapies Ltd https://animaltherapies.org.au/ Animal Therapies is the national organization for animal interventions (therapy, education, activities) that I am a member of in the context of my extensive experience and training incorporating work with animals in therapy sessions that also include CBT and mindfulness, and activity-based therapy as standard methods in mental health OT practice. For many clients I see with neurodiversity and/or anxiety, this is the only therapy session they will attend/can manage to attend due to their sensory/anxiety issues. Therapy incorporating animals is an internationally recognized and regulated practice with extensive and growing research and ethical guidelines for practice – not a “fringe” modality to be thrown in with “alternative” and questionable practices as indicated below as ATL has informed us yesterday: As you would be aware, Bill Shorten is leading an NDIS funded services review. As part of his review, he has stated in parliament that services that include animals, except assistance animals, will be excluded from future NDIS funding. He has also stated that somatic therapy will also be excluded.

Shorten is asked a question at the 2h:46m:40s mark in the video. Then at 2h:49m:26s he lists things that NDIS funding should not be spent on. He gets interrupted by the opposition and then continues where he says Somatic Therapy should be banned. Bill Shorten says they want to rule out the payment of “strata fees, fines, steam rooms, gambling, legal cannabis, cruises, trips to Japan, non-assistance animals, taxidermy, weddings, gift cards, the Liberal favourite sex toys, crystal therapy, cuddle therapy, clairvoyants and taro… (interruption)… We want to ban somatic therapy, mastermind coaches and crypto-currency”.

Recommendations

There are some types of clinical evidence that are based on recent neuroscience and other research findings that will take time to develop enough solid research to meet the threshold to be a NDIS support. I would recommend that emerging research also be considered and that lived experience voice also be considered. This would include sensory interventions including sensory modulation (which has an evidence base in hospital environments but not as established in the community).

Workforce

Some of the proposed changes seem to rely on block funding models without considering the impact on the workforce. The disadvantage with using these models include:

• Small businesses and sole traders are unable to apply. These small businesses are often very well suited to people with disabilities, and to people with caring responsibilities.
• Block funding models reduce choice and control of selecting providers.
• Block funding providers tend to employ people with inexperience, as they are cheaper. People with disabilities often have complex needs and benefit from those with experience.

Recommendations

• Do not create block funding only options in the NDIS. I understand that block funding may be required in some remote communities but even in this instance I think that the community needs to be consulted prior to implementing this. And it may instead be an opportunity to set up small businesses and employ local people rather than a national company.
• Do not allow large corporate organisations to have more input than people with disabilities or allied health organisations.

Most families and individuals that I see are under significant financial stress as a direct result of their disability – i.e., adults who are unable to work or can only work casually/from home or parents unable to work due to the demands of a special needs child (or often more than one child when the disability is a genetic condition) plus the extensive costs of supporting the individual through e.g., therapy, and AT. As a mental health OT, I see firsthand everyday what a difference NDIS funding has made to these individuals – they are generally able to access the support, therapy and AT they need, with great results e.g., being able to return to school, able to emotionally regulate better and able to achieve daily tasks/goals better, from both early intervention and ongoing support in the context of lifelong disability. As an OT my goal is always for clients to become increasing independent and to have the chance to meet their life goals like every human has a right to. Without NDIS funding including choice and control over whom they see, and sufficient funding, nearly all individuals I see would be unable to access therapy or support. I also see clients

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under Medicare but I usually bulkbill due to their financial stress as outlined. Medicare sessions are both extremely limited in number of course which is not suitable for lifelong conditions. Additionally, it is not sustainable as an allied health therapist in private practice to only bulkbill under Medicare with the current rebates, yet it would be my only option with most individuals I see due to their financial stress. This leaves a system where OT’s would be unable to sustain practice and clients would have less if any access to the services they require. This is gravely concerning.

I am not against changes to the NDIS and creating efficiencies for long term economic sustainability - this certainly needs to occur - but the current focusses do not seem to address the real issues. In this context, the current legislation needs to be stopped and revised to do proper consultation and incorporate the concerns that innumerable participants and practitioners are submitting and look at the best way forward for service provision for people with disabilities.

Yours sincerely Madeleine Flynn

Occupational Therapist