NDIA Accountability Project

Occupational therapist concerns functional capacity assessment

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Submission 2282

My name is redacted.

I am an occupational therapist who has worked in the community disability sector since graduating in 2017. My two years as an OT I worked across 3 funding systems - CAEP (WA), WANDIS, and then the introduction to the NDIS. During this time I have seen how the NDIS has increased opportunities for many of my clients to increase their participation with their local and wider community, and achieve goals that they thought were out of reach because of their disability. I am passionate about the system achieving the outcomes it claims to desire, and supporting the scheme to be sustainable for future generations.

Together with most in the allied health community, I have serious concerns for the proposed reforms. I don’t have many solutions to these specific problems, but

Submission 2282

would refer to the submission completed by OTSi and stand behind the recommendations provided by them.

Schedule 1: access and planning

  • Changing the definition of functional capacity.

Assessing functional capacity without consideration of the person’s environment and support systems does not provide an accurate picture of capacity and the impact of impairments on daily function. It neglects the globally accepted interaction between person, environment and occupation as outlined in the ICF framework from the WHO.

Neglecting these factors will have a disproportionate impact on persons with disability who come from a low income background and have limited informal supports.

Submission 2282

It is my recommendation that the current definition of functional capacity be maintained. Assessment of functional capacity should be more streamlined by way of a common document that can be used by all to outline the functional capacity of participants, recognising the difference between impairment types but allowing for interaction between impairments and recognising that a person’s functional capacity may be impacted by more than 1 disability.

  • Tightening the definition of permanence and “appropriate treatment” The rule does not indicate that it considers factors such as physical access, financial access, access to culturally safe services and many other valid reasons for people not to engage in treatment options. It also disregards bodily autonomy and informed consent if access is provisional on the trial
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of all possible treatment options.

Further to this, the evidence required to demonstrate access to these interventions is difficult to access for many, and may no longer exist for those who have been living with their disability for a long time.

It would be my recommendation to remove this proposed change, and maintain the current definition.

  • Plan reassessment and suspension powers.

The proposed extension of the decision timeframe for those requesting reviews places these people at significant risk.

Lack of access to appropriate supports increases burden on unpaid support persons, and increases risk of social admission to hospital, increasing strain on the hospital system.

It is my recommendation that there is a pathway for those requiring urgent

Submission 2282

reassessment of their funding to receive a decision within a reasonable time frame so that their personal safety, physical and mental health, and dignity are not compromised due to lack of response from the NDIS. The current timeline for reassessment requests should be maintained, with decisions made based on a case by case basis.The recommendation to provide power for plans to be suspended when participants cannot be contacted places those with communication difficulties at significant risk.Whilst communication preferences are requested by the NDIS, these are often not utilised and this leaves participants unable to interact with the contact from the NDIS.It is my recommednation that a system be created that ensures the preferred contact

  • Funding cuts and ministerial powers.

The ability to reduce funding for specific groups does not take into consideration individual assessment of reasonable and necessary supports. Further to this it does not consider the risk of funding reduction on individual participants, creating risk of catastrophic harm to some participants due to the reductions. It also does not reduce the functional need for participants. The supports which are taken away still need to be provided by someone, which increases the burden on informal supports and creates significant risk for those without informal supports to fill the gap.

Schedule 3: Governance

Pricing Powers

The ability for the minister to set maximum NDIS prices may result in federal budget reduction being prioritised over participant need and sector sustainability.

The last two price guide releases and the resulting closure of an increasing amount of large disability providers indicates that the sector is already under significant strain, which will place the sector under increased pressure and result in lack of access to supports for

Submission 2282

to ensure equitable access to supports.

Capping of home modification and assistive technology payments may also result in decreased access to these supports, or force co-payment for a cohort of persons who are typically low-income and do not have the means to self-fund supports. It is essential that home modifications and assistive technology be assessed on an individual basis, as not all items provide the same features and outcomes for participants. There are times when spending more on these items could significantly increase a participant’s independence, and times where it also results in a decreased reliance on supports. Pricing needs to allow for flexibility to pay more as a once-off cost to increase the positive outcomes for participants, and recognise the potential long-term funding reductions that may

Submission 2282

result. As therapists we don’t aim to recommend equipment with pointless features or the most expensive item, but rather what will be most suitable to achieve the goals of the participant. It is essential that the professional recommendations of the allied health community be recognised as such.

Pricing decisions within the NDIS should not be made with political agendas, and therefore should remain in the current format.

  • Automation and decision making.

Automation of systems used for functional capacity assessment, eligibility decisions, reassessment determination, and support needs decisions and funding allocation creates significant risk for the disability community. Snapshot assessments typically do not capture fluctuating disability, environments, cumulative

Submission 2282

Impairments, and many other factors well.

This results in inaccurate assessments and causes inappropriate supports being provided. It also does not provide opportunity for professional judgment and allied health evidence to support the assessment of complex needs to minimize risk of complex needs being underrecognized and unfunded.

Automation within the NDIS should be strictly monitored and not applied to funding and capacity decisions. Any Automation within the NDIS should be able to be overwritten by individuals within the system based on recommendations from ally health professionals.

Schedule 4: New Framework Planning

  • The proposed changes to the planning process do not capture complex disabilities, cumulative impact of

Submission 2282

impairments, or the interaction between

disabilities and places participants at

significant risk of inappropriate funding allocation.

Focus on expenditure control should not

come at the consequence of poor

participant outcomes including possible

death for participants who do not have

access to appropriate supports.

The new framework planning requires

further trial and allowance to be used in

conjunction with other reports to ensure

an accurate representation of individual

function is achieved.

Any proposed reforms to the NDIS

legislation should seek to strengthen

access to dignity, participation, safety and

equality for persons with a disability. The

proposed changes to the legislation do the

opposite.

Submission 2282

As an allied health preactioner working in the NDIS, I recognise that changes need to be made in order to ensure the scheme is sustainable for the next generation. Many allied health professionals have ideas and strategies that would streamline processes, increase efficiency, reduce waste, and reduce overall costs, while maintaining positive outcomes for the disability community. The positive impact of the NDIS on the disability community has been undeniable. The proposed changes limit the ability for the scheme to achieve its intended goal. Some of the reforms appear to actively reverse some of the positive impacts, such as increased access to the wider community for those with disabilities.

True co-design will result in a scheme that

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is both sustainable and effective. Please take the time to listen to recommendations from the sectors leaders such as OTA, Physiotherapy Australia, and OTSi, and show that you truly care about the needs of all Australians, not just able bodied people.

Thank you for your consideration.