24 January 2013
Committee Secretary
Senate Standing Committees on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
Dear Senators,
Assistive Technology Suppliers Australasia (ATSA) welcomes the opportunity to comment on the Exposure Draft of the National Disability Insurance Scheme Bill 2012. The introduction of the Bill into Parliament on 29 November 2012 was a major milestone for the nation, and when implemented the NDIS will transform the lives of many people with significant disabilities and their families.
ATSA was established in 2000 to represent the interests of assistive technology suppliers who manufacture, import, distribute, service, and hire equipment. ATSA members range from small, family owned businesses to international companies.
Assistive technology, also known as aids and equipment, is a primary enabler and is central to minimising long-term costs and improving the lives of people with disabilities. Effective assistive technology provision will help ensure that the NDIS is affordable and economically sustainable.
ATSA believes that the architecture of the Bill is sound, but that some parts require alteration, and broadly supports the points raised in the submission by National Disability Services.
In relation to the provision of assistive technology there are three points in the Bill that warrant particular attention: Chapter 4, Part 3 (registered providers of support); and Chapter 6, Part 2, Division 2 (Appointment of Board Members); and Chapter 6, Part 3 (Appointment of Members of the Advisory Council).
Registered Providers of Supports
Chapter 4, Part 3, sections 69-73 deal with issues of registration of providers of support. Many assistive technology products such as wheelchairs (manual and power), hoists, home care beds, pressure care, mobility scooters, and bathroom aids are classified as Class 1 Medical Devices, and as such are required to be listed by the Therapeutic Goods Administration.
In relation particularly to Class 1 Medical Devices, ATSA believes that suppliers and prescribers (often allied health professionals such as occupational therapists, physiotherapists, speech pathologists, orthotists and prosthetists) should be required to be registered with the NDIA. This will be vital to ensure that people with disability can find the appropriately qualified suppliers and prescribers to
meet their needs. We note that registration requirements will be dealt with in detail by the Rules, and we are also making a more detailed submission on this issue as part of the consultation process on the Regulatory Impact Statement. Importantly ATSA has also been funded through FaHCSIA’s NDIS Practical Design Fund to develop an options paper on the establishment of a national accreditation system for assistive technology prescribers and suppliers.
Members of Board
Chapter 6, Part 2, Division 2, Section 127 – Appointment of Board Members, item (a): this refers to the appointment of someone with knowledge in relation to disability service provision. Given the significance and complexity of assistive technology, we believe item (a) should be expanded to include the statement referenced to assistive technology, so that it would read:
‘the provision or use of disability services, including assistive technology’
Advisory Council
Chapter 6, Part 3, Division 2, Section 147 – Appointment of Members of the Advisory Council, item 5.b.iii, currently states that membership will include:
at least one of the members is a person who has skills, experience or knowledge in the supply of equipment, or the provision of services, to people with disability
There is a very real danger that insufficient understanding of the role of assistive technology will endanger the effectiveness, impact and sustainability of the NDIS if specific attention is not given to this issue within the Advisory Council (and the Board). ATSA strongly recommends that instead of keeping the above clause with its ‘either/or’ orientation, that a new clause is added specifiying:
at least one of the members is a person who has skills, experience or knowledge in the supply of equipment
This is vital given that: (a) assistive technology (aids and equipment) are a primary enabler for people with disability; (b) approximately 12% of the NDIA budget will go to capital costs for assistive technology, including vehicle and home modifications; and (c) the inherent complexity of ensuring effective and efficient provision of assistive technology. With an Advisory Council of up to 12 members, surely there is room for someone very experienced in assistive technology provision, AND someone who is very experienced in service provision
Additional background key policy issues regarding assistive technology and the NDIS can be found in the attached ATSA policy statement.
Thank you again for the opportunity to comment on the Draft Bill, and should the opportunity arise, ATSA would welcome the opportunity to provide direct testimony to the Senate Standing Committees on Community Affairs.