Submission 2770 - Supplementary Submission
What are some ways that the NDIA can save money and improve outcomes WITHOUT harming participants in the process?
A group of NDIS Occupational Therapists discussed this - and it didn’t take them long to brainstorm some suggestions.
We think that NOIA should look INWARD, at how they can improve cost effectiveness through changes to their own internal procedures - and NOT jump straight to cuts that will harm people with disabilities.
“When people apply to the NDIS and gain access, use the same evidence and point of time to formulate their first plan - don’t make people wait again, and go t hrough another meeting. They already proved their disability, level of function, and identity at the point of access - use that dat a.”
“Meet the participant face t o face where possible.” You’ll be able t o understand people and their situations and needs better.
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Submission 2770 - Supplementary Submission
“Work with therapists to co-design shorter templates”. NOIA could work with therapists to co-design much shorter forms, that take therapists less time to fill in, and NOIA staff less time to read.
For example, the current template for requesting high cost assistive technology (AT) such as custom powered wheelchairs is 18 pages long even when it’s blank (and it’s repetitive), and the CHM form is 14 pages when blank. The longer the form is, the more hours therapists need to spend typing, and the higher the bill for our time is.
“READ our reports, and only ask for additional detail if it’s not there”.
“Read applications thoroughly and listen to the expert opinions of the trained professionals who have done assessments and written comprehensive reports and justification.”
“Co-design an FCA template with OT’s, with expandable text boxes for customisation. Then NOIA staff will know exactly where to find key information, rather than having to sift through a different report format from each therapy provider, which would save time. Having a consistent format for reports would help ensure the necessary information is covered, without the report needing to be overly long. Currently we seem to have continually moving invisible goal posts instead!”
“None of this needing new Functional Capacity Assessments (FCAs) every year. I feel like our OT reports have gotten so long (because we just have to keep adding more and more justification to be able to get the outcomes our clients clearly need). Let’s listen to the clinical expertise of information in a shorter report, fund plans accordingly, and let therapists focus on therapy.”
Submission 2770 - Supplementary Submission
It’s important to add that, although most if not all OT’s would be happy to spend less time writing reports, we nonetheless have significant concerns regarding NDIA’s plan to move to Support Needs Assessments completed by NOIA staff, including:
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That assessments will be done by mostly non-health professionals, who don’t know the participant, don’t plan to meet them face to face, and won’t be able to observe interactions between the person, activity, and environment the way OT’s do.
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That a single assessment won’t be validated for use across all diagnostic groups - and that validity will be further reduced by NOIA modifying the assessment.
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Robo-planning: The use of an algorithm to determine plan budgets - especially if it is set up to UNDERestimate support needs (like we’re seeing in aged care), and if the results can’t be changed by a human (like in aged care), and especially if plan budgets can’t even be changed at tribunal level.
“Assign NOIA staff to work in teams responsible for diagnostic groups (e.g. spinal cord injury team, autism team, progressive neurological conditions team, psychosocial team etc), and then a “complex presentations team” for those with multiple diagnoses interacting. Provide training by clinicians with relevant expertise to help staff build knowledge in their specific area, to help them understand complex reports and make sensible decisions about funding requests, which would then be less likely to need slow and expensive appeals processes.“
“Make good use of the allied health professionals you do have on staff in the NOIA, although they are in a minority there. Have expert panels staffed by clinicians with experience and expertise in specialist areas (e.g. wheelchair and seating, prosthetics, assistance animals, vehicle modifications, communication devices, etc). Planners could consult panel members when they receive particularly complex requests, rather than skim reading, misinterpreting information, and unfairly declining requests. Panel members could contact the health professional who wrote the report when there is information that needs clarifying, or if they’d like to discuss whether a cheaper alternative is feasible. This would reduce unnecessary time and cost being spent on appeals against decisions by planners that make no sense.”
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Submission 2770 - Supplementary Submission
When NDIS was first rolled out (from 2013), it was described as being like “a jumbo jet being built in mid flight”. But now that we’ve had more time to see what does and doesn’t work, why not look to other insurance schemes for quality improvement ideas, for example:
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“TAC in Victoria have a very simple on line method of provider registration that is FREE. NDIS could use a similar short webform to register members of allied health professions who are already regulated under AHPRA.”
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“In the OVA Vocational Rehab model, there are planners and therapist advisers who you can speak to who know their stuff. Short report templates. Tick box AT templates. Therapists case managing and determining budgets that are then approved by planners. Travel fully remunerated. Decent hourly rate. Quarterly reports against goals”.
“Cut the legal bill!”
NOIA spent $60 million on legal costs last financial year, fighting long battles against NOIS participants who were appealing their decisions. Sometimes, the legal costs are higher than the cost of the requested support. And in most cases, the tribunal rules that the NOIA made the wrong decision - so NOIS has to fund the requested support at the end of it all anyway!
Instead of using a rigged algorithm to making planning decisions and reduce access to appeals - put processes in place to help NOIA staff make better and fairer decisions, that don’t need appealing!
“Contact therapists to ask questions if something needs clarifying (like you used to), rather than denying the funding request, which means the participant has to put in an internal appeal request, seek more reports, and wait months longer for an answer.”
“Maintain the existing ‘Value for Money’ definition when considering which supports can be funded.” Removing the consideration of comparative benefits of options, to leave only comparative costs (as proposed in the NOIS Amendment Bill) risks participants being approved unsuitable supports. Would you give someone who needs a wheelchair a walking stick instead, because it’s cheaper? (until they fall)“
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Submission 2770 - Supplementary Submission
“Understand that Capacity Building funding, i.e. funding for therapy that improves functional capacity, can increase independence and decrease the cost of formal supports.”
“OT is about managing environments as well as being person centred, hence the need for home-based services within the community. Support and fund travel for holistic assessment and management of the participant needs, and to boost access to supports in remote areas”.
Environmental factors also shouldn’t be written out of the definition of function as is proposed in the NDIS Amendment Bill!
Learn from previous ART outcomes and make changes accordingly. For example, t here was a tribunal outcome t hat ruled that “mainstream appliances” can be considered disability related if they have features that meet a disability specific functional need. This should be edited as such in the NDIS Supports list. Something doesn’t have to be sold by a disability supply store to meet a disability related need - and can be a lot cheaper and more readily available elsewhere.
“Collaborate to clearly define the responsibilities of different agencies (e.g. NDIS, education, housing, healthcare and hospitals). This will help avoid people being hand balled between different agencies, which causes delays and frustrations, and increases risk:’
“Have planners leave a return phone number so their calls can be returned, rat her than ‘t wo strikes you’re out’ if you miss t heir phone calls!” When NOIA staff phone a participant, they don’t leave a phone number. They text first then call a couple of times within minutes. If you miss that text and those calls there’s no way to return contact. Calling the call centre is fruit less, because it won’t be the same person or even a person employed by t he agency at all - it will be someone from Serco who has to pretend they are an NOIA employee!* And replying to an email from a LAC often results in an auto reply saying ‘sorry, case closed.’
The NDIS Amendment Bill seeks to allow plans to be suspended where the agency “cannot contact” a participant. This is concerning because it fails to consider people who can’t answer the phone for disability related reasons (eg speech, upper limb, or hearing difficulties) or other reasons - and because suspending supports is a safety risk. That’s not ok. *https://www.theguardian.com/australia-news/2026/jan/25/ndis-outsourced-call-centre-pretend-government-workers 15
Submission 2770 - Supplementary Submission
Total remuneration N DIA Management roles “The CEO of the NOIA is paid (Salary + benefits)
$808,000 (as at 2023-24, and CEO $808,689including base salary + benefits).
Deputy CEO Enabling Services
That's more than t he prime / Chief Operating Officer $556,105m inister earns.
Deputy CEO Partners, Providers and
$541,689 Perhaps it ’s time for t he tax Home and Living payers funding t his to ask - Deputy CEO Integrity Transformation and
is this value for money? Fraud Fusion Taskforce $530,883Deputy CEO Governance, Risk and Legal $510,820
Source of figures: Australian Scheme Actuary $504, 978Government Transparency Panel
“Process requests for urgent assistive technology and home modifications promptly to reduce risks.”
There is no system currently to process urgent requests promptly. When a participant has an urgent need for equipment or mods to improve their safety, those needs don’t just go away if you ignore the report for 6-12 months! It shows up in other ways.
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The cost of equipment hire while waiting for the purchase approval can be higher than the purchase cost itself. And the purchase is still needed after t hat.
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Or, there may be no temporary fix available, and impacts can include reduced functional capacity, increased risks (incl. of falls, carer burnout, and manual handling risks), and a greater need for formal support and capacity building support from NDIS.
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The lack of the equipment or modification sometimes results in an injury and a hospital admission - which is obviously a poor outcome for the person, and can also cost ten or twenty times more than the equipment would have. 17
“Declining a support request that is clearly needed costs NDIA more in the long term. Some participants have to try 3 or 4 times to access a needed support, such as gaining access for a second diagnosis. This means updated reports from allied health professionals and N DIA staff reviewing reports multiple times - all of which costs time and money. Meanwhile the participant’s functional capacity continues to decline and they require a higher level of support than they did initially.”
“Add the NDIS accepted disability or impairment category to NDIS plans for transparency and clarity for service providers to make sure that we are addressing what the client has met access for. And bring back home and living decision letters and outcome letters for AT and home modifications, to improve transparency and accountability.” 18
Submission 2770 - Supplementary Submission
“Work with OT’s to review the Complex Home Modifications Process”
Trial a conditional pre-approval process for unusual situations, when it’s ‘iffy’ whether the NOIA will approve the request or not, on the basis of an initial summary of information and a rough estimate of cost - instead of NOIA only being able to say yes or no after the OT has already done 15-30 hours of work on it (assessments, home visits,
liaison, modification diagrams, specifications, and report). However, it would beessential for NOIA to respond promptly, and for people to retain access to appeals.
“Include funding for builder consults in participants plan consistently when they need home modifications, or give OT’s clear advice about how t his can be funded, e.g. from core supports. Or if you’re no longer funding this at all, tell OT’s and builders, rather than having us waste our time chasing answers for individuals separately.”
“Introduce a system for donating and loaning or re-issuing equipment like adjustable beds and power wheelchairs, rather than participants selling the equipment or leaving it in the corner to gather cobwebs when their needs change and they no longer need it.”
Yes, there would be practicalities to sort out, like storage, cleaning, maintenance and deliveries - discuss these with the state based systems who have managed to overcome those hurdles (e.g. SWEP, MASS, ACTES). Or, broaden the use of the existing state-based equipment systems to include NOIS participants.
“Rethink your stance against sole occupancy SDA.”
As is pointed out in our reports time and time again, although SDA* might cost more in an apartment than a group house, the opposite is true for SIL** costs - and SIL costs a lot more than SDA.1:3 SIL in a three-share SDA house is typically a lot more expensive than 1:10 on call support+ part time regula supports in an SDA apartment, for those who are suited to and wish to live in an apartment. So, making everyone who seeks sole occupancy SDA go through the tribunal to get that rather than a group home costs a lot more in total (SDA + SIL) cost - as well as in legal costs. SDA decisions should also uphold people’s right to choose where they live and who they live with - as per Australia’s Disability Strategy and the UNCRPD.
*SDA = Specialist Disability Accommodation (the bricks and mortar) **SIL= Supported Independent Living (the program of care)
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Submission 2770 - Supplementary Submission
“Recognise that funding skill building and early intervention can improve functional capacity, reduce difficulties, and reduce the cost of supports down the track for many participants (such as autistic children)”.
“Acknowledge that “Thriving Kids” is not ready for implementation, is severely underfunded, and that only a portion of the funding will go directly to services to support kids - with a large chunk retained for governance. There are going to be a lot of upset voters when they realise how little therapy and support their kids will be able to access! Call it what it is - a significant defunding of supports for kids with autism or developmental delay. (And kicking thousands of kids off the NDIS before TK is even available was a particularly low act.)“
“Provide clarification that low cost sensory items can be NDIS supports when they fit an NDIS support category (e.g. helps with personal care and safety or household tasks), are disability related, are in line with the participant’s plan, are not standard indoor or outdoor play equipment, and are effective and beneficial, safe, and value for money.
Acknowledge that there IS evidence behind sensory processing differences and sensory supports. Denying this discriminates against autist ic people.
Allow participants and plan managers to make judgements about low cost sensory items, the way they do for other low-cost items. Don’t insist on an OT letter every time, as this just leads to situations where the OT time to write the letter costs more than the item we are writing about.
Support informal carers. All t he unpaid care work that people do out of love for their part ner or family member must save the NDIS billions! But if family caregivers are pushed to the point of burnout or mental or physical injury (which can even create new disability), it can affect their ability to sustain their caring role into the f uture. Providing formal supports (support workers), and capital supports where needed, complements informal support and can help set people up to succeed. It can help sustain relationships. It can help family members return to the workforce, and contribute to the economy. It can help a spouse feel like a partner, not ‘only’ a carer.
Acknowledge that children with a disability often have much greater care needs than other children their age. Don’t brush all parents’ requests for support work off as “parental responsibility” especially in cases of children with high support needs (some need 24/7 care!), and in cases where denying support places the child or their caregivers at risk. Don’t change the definition of parental responsibility in the bill t o avoid providing the necessary support . And definitely stop stooping to using dirty t ricks like threatening to call child protection services if a parent says they need help!
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Submission 2770 - Supplementary Submission