NDIA Accountability Project

Lack of transparency around economic modelling and assumptions

‹ PrevPage 1 of 3 · Source p. 1Next ›

TO: LEGISLATIVE AFFAIRS COMMITTEE- NATIONAL DISABILITY INSURANCE SCHEME (NDIS) AMENDMENT BILL 2024

From : Sally Davison Occupational Therapist

I am a member of the NDIS OT Community of Practice and work with NDIS participants in a small practice in Melbourne. This individual submission adds to our original submissions, dated April 26th 2024 and 14th May 2024. The NDIS Occupational Therapy Community of Practice (NDIS OT CoP) is comprised of over 10,000 occupational therapists and was created to establish best practice and optimal outcomes for, and with, NDIS participants. We reiterate all feedback provided in both earlier submissions and express our concern that issues raised in these submissions have not been adequately addressed by recent amendments.

ONGOING KEY CONCERNS

1. Lack of transparency around economic modelling and assumptions

The assumptions within the economic modelling underpinning cost containment for the NDIS is essential to enable comprehensive evaluation of the proposals, to enable scrutiny of their impact on the lives of people living with disability and those who support them.

The vision for the future shape of NDIS, and the assumptions behind the economic modelling for any new vision must be made transparent. This is essential for all stakeholders including State and Territory Governments, current NDIS service providers and most importantly people with disability and their families.

Of particular concern to the author are the assumptions within the model that considers access for people with disability (without discrimination based on diagnosis) to high quality assessment processes and essential capacity building services – in line with insurance principles - from AHPRA registered and qualified allied health professionals such as Occupational Therapy.

Fundamental principles of assessment are not currently in the primary legislation

The following recommendations and suggested amendments to the primary legislation are provided to strengthen and safeguard the assessment process and ensure that NDIS assessments of support need are valid, fair and comprehensive.

Definitions

A definition of “assessment of support need” & a statement of key determinations to include in the ‘assessment report’.

Assessors

  • Clarify that assessors will be qualified allied health professionals working within scope of practice. Section 147 of the Act to be amended to include an allied health professional role on the NDIS Independent Advisory Council to provide expert input to NDIS assessments on an ongoing basis.
  • The assessors will be independent in the performance of their functions and assessment of need will be carried out in good faith, irrespective of the cost of identified support needs.
  • The Support Needs Assessment will consider existing assessments and information provided by the participants’ current support team.

Assessment Process

  • The assessment needs to include ‘whole of person’ support needs, focused on broader functional capacity, not limited to a single impairment (s).
  • Where the assessment finds identified supports to be the responsibility of another system (health, education), this is clearly stated in the assessment report and that these systems must have proven capacity to meet the identified need.
  • Both a draft copy, & finalised version of the full assessment report will be provided to the participant.
  • The right to at least one replacement assessment; and additional assessments if priors were found to be genuinely flawed.
  • The assessment report will include a review date.

There are very significant implementation risks accompanying this Bill with potentially far-reaching implications for the Scheme itself and participants. Delaying passing this Bill will allow an opportunity to develop:

  • Necessary foundational supports with State and Territories;
  • NDIS Rules
  • Rigorous codesigned new NDIS processes and service models

This delay will help safeguard participants and the NDIS during a significant transition period.

Sally Davison (Principal Occupational Therapist) B App Sci (Occ Ther) [Hons], MBA, Grad Cert Counselling and Psychotherapy

                                                                                   Ahpra Registered practitioner AHPRA OCC-2418218                     & National    Occupational
                                                                    -           Boards          Therapy, usr RALJA
  • Member Occupational Therapy 9495152