NDIA Accountability Project

Impact of NDIS Bill reforms on speech pathology workforce and assessment processes

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Speech Pathology Australia

Level 1/114 William Street T 61 3 9642 4899 office@speechpathologyaustralia.org.au Melbourne Victoria 3000 F 61 3 9642 4922 www.speechpathologyaustralia.org.au

                                    Speech
                                        Pathology
                                           Australia

Ms Jeanette Radcliffe Committee Secretary Senate Standing Committees on Community Affairs Sent via: community.affairs.sen@aph.gov.au

12 July 2024

Dear Ms Radcliffe,

Speech Pathology Australia thanks the Committee for the opportunity to make a further submission in relation to the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 (the NDIS Bill) amendments.

Speech Pathology Australia is the national peak body for speech pathologists in Australia, representing more than 15,000 members. Speech pathologists are university trained allied health professionals with expertise in the diagnosis, assessment, and treatment of communication and swallowing difficulties and as such provide crucial supports for NDIS participants.

We provide additional feedback on the following areas of the NDIS Bill:

  • Section 32, regarding the lack of consultation with the allied health sector and the Needs Assessment (in particular Section 32K).

  • The continued lack of detail regarding the implementation of the Needs Assessment and possible unintended consequences upon workforce.

  • Our concerns regarding the future of NDIS registration should this be incorporated into future versions of the NDIS Bill.

  • The speed of the approach to this major legislative reform and concerns regarding the implementation timeline of the reforms made as a result of the NDIS Bill.

A new Needs Assessment

Speech Pathology Australia continues to have concerns regarding the proposal for a new Needs Assessment within the NDIS Bill that the amendments have not addressed. Namely, that the wording of the amendments are such that there are no guarantees that the determination of the assessment tools will be made in consultation with the allied health sector. The probability that these tools will therefore not be fit for purpose, particularly with regard to determining communication and swallowing needs and not communication accessible is of grave concern to the Association.

We reiterate our call to specify that the allied health sector, in particular speech pathologists must be consulted to ensure these assessments are fit for purpose, communication accessible and will not cause harm to participants.

Concurrently, the working method to determine funding from the Needs Assessment is still not yet determined as per Section 32K. It is unclear if the input from allied health professionals already involved in the team around the participant will be sought, and incorporated into determining the supports that will be funded. It is our view that additional wording should be drafted within this section to specify that a participant’s budget will be determined from the Needs Assessment in addition to pre-existing information and input from a participant’s professional team, including allied health providers.

Potential unintended consequences on workforce

Speech Pathology Australia has concerns regarding the unintended consequences that may transpire should the NDIS Bill reforms pass and be implemented. In conjunction with the Needs Assessment not being specified, the workforce that will undertake these assessments is also unclear.

Certain tools may only be used by workers with specific qualifications; it is therefore likely that these workers will need to be from an allied health background. However, at present there is a workforce shortage of allied health providers including speech pathologists. Thus, there is potential that the implementation of a Needs Assessment for every participant will put additional strain upon an already strained workforce.

Speech Pathology Australia released a Workforce Report in 20231 that showed a large unmet workforce demand for speech pathologists across all sectors. Currently there is a thin market for speech pathology supports under the NDIS. Survey data gathered in February 2024 indicated that only 3% of respondents providing speech pathology services under the NDIS were able to employ additional speech pathologists when they were needed.

One of the reasons that was identified within the qualitative survey data for hiring difficulties was the increase in wage expectations with cost of living, but without an increase in the hourly price for NDIS therapy supports. The price for these supports has remained stagnant for the past five years, affecting the willingness of allied health professionals to establish or maintain their NDIS businesses.

Implementation timeline of changes

Speech Pathology Australia has significant concerns regarding the speed with which the NDIS Bill was introduced to Parliament, without the time and consideration given to proper consultation with the disability sector. Many of the aspects were specified to be in force 28 days following the NDIS Bill being passed. Furthermore, the implementation of the reforms made as a result of the NDIS Bill is unclear. We are therefore apprehensive that the development of Rules, upon which so many of these amendments rely, will be similarly rushed.

There is a significant risk that due to the haste around the tabling, consideration and subsequent implementation of these reforms, that further consultation will not occur. Additionally, if these changes are rushed, particularly those regarding access, and the determination of the funding of supports, the necessary infrastructure to support them will not be in place. For instance, currently Foundational Supports are not established and what they will entail, and who will provide them has not been agreed. The NDIS Bill is silent on Foundational Supports and early intervention supports, possibly as they may be planned for the next tranche of legislation.

It must be noted that it is critical to take adequate time to develop and implement these changes that will drastically alter the Scheme. Foundational Supports, the Early Intervention pathway and the Needs Assessment must be developed over time, with ongoing consultation with the disability sector. In particular allied health professionals should be consulted regarding best practice in the design of these three reforms to ensure that supports are not simply removed from participants, without the necessary infrastructure and planning in place to fill the gap.

The future of NDIS registration

There is also significant concern within the sector regarding the likelihood of NDIS registration becoming mandatory. The process is currently overly burdensome and expensive, meaning that speech pathologists are reluctant to be registered. Unless the future registration process for speech pathologists resembles the current Medicare Provider Number process that is free, quick and involves limited administrative burden there will be mass exodus from the NDIS provider market.

It has not been specified if the workers conducting the Needs Assessment or professionals contributing information to the determination of a participant’s needs must be registered. It is critical

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that the expertise of speech pathologists is considered with regard to the Needs Assessment, iresspective of if they are registered or not. This is especially pertinent in the face of the uncertainty regarding NDIS registration. Similarly, self-regulated professionals such as speech pathologists should be seen as equal to other Ahpra registered professionals within any subsequent legislation regarding input to the Needs Assessment, or the future requirements of NDIS registration, including mutual recognition agreements.

Speech Pathology Australia is keen to engage with the NDIA to improve health outcomes for people with disability.

Yours sincerely

Jodie Long Chief Executive Officer