Joint Standing Committee on the National Disability Insurance Scheme
Senate Inquiry – NDIS ICT Systems
Submission by:
Bruce Nixon
Chief Executive Officer
Holocentric Pty Ltd
14 September 2018
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Digital Transformation and the NDIS
Introduction
Holocentric is an Australian SME that has created technology that enables the digitisation of business processes and generate digital models of businesses. This assists all participants in an organisation or a scheme to manage and navigate the complexity that is the reality of most organisations.
While Holocentric has traditionally worked with large, complex organisations to simplify and standardise operations, we have invested into the National Disability Insurance Scheme to help deliver better outcomes for participants via the service providers. We believe there is great opportunity to utilise digital approaches to make massive savings in the scheme and deliver far better outcomes for people with disability.
Background
The ambitious nature of the National Disability Insurance Scheme requires an effective means to roll out the scheme across the country in a consistent manner. ICT must play a key role in the scheme as this will be dispersed across a very broad geographical area, through many service providers and to many participants with a wide variety of needs. ICT is not just transactional systems such as payment systems and portals. The management of information and knowledge is a most important and often overlooked aspect of ICT.
As a new scheme, there is the opportunity to take advantage of the latest technology to provide a more efficient and affective scheme that operates in a very fair and consistent manner. The NDIA has commenced the journey with some excellent initiatives such as Nadia – the digital human and NDIA Knowledge – a central repository of information. While these initiatives have been trialled, they have not been used to maximum effect and there is a great opportunity now to capitalise on the significant investment, experience and success that has been achieved to-date.
The NDIS can only succeed if there are sufficient providers delivering quality services across the country in a safe and reliable manner. Investment is required to ensure that service providers are enticed by the scheme and can run a viable business. While it is not possible to remove all overheads from the scheme, these may be minimised by taking a digital approach to information dissemination and sharing.
Holocentric has had a central role in the implementation of NDIA Knowledge through a major commitment made by NDIA. This initiative captured the Service Delivery Operating Model (SDOM) in digital form so that it could be communicated easily and accurately to all involved in NDIA operations. NDIA Knowledge is a comprehensive knowledgebase that can provide information to different stakeholders in different forms, depending on specific requirements. Holocentric, as an Australian company, has worked with many large Australian organisations such as Department of Defence, Qantas and Westpac to help capture a representation of their organisations through similar techniques.
NDIA Engagement of Holocentric
Holocentric was engaged by the NDIA from February 2015 until December 2017. The technology can be deployed as a cloud based service and this offer was taken up by the NDIS. Thus all of the work was able to be done independent of the internal IT services supplied by DHS, other than browser support.
That engagement included the use of two of our technical consultants, working with NDIS and contracted subject matter experts, to use our technology to capture business models and processes as the agency was being designed for implementation. This work was endorsed by many executive committees over the course of the engagement and became the basis for the major piece of work which was the creation of a repository, NDIA Knowledge.
The NDIA Knowledge repository was informed by the Service Delivery Operating Model (SDOM). The SDOM represents the business operations and was designed by a small team of independent consultants with
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extensive senior management experience in the design, management and delivery of social services to the community.
Our technology enables the capture and connect of all elements of the SDOM and the detailed processes, process steps, systems, regulations, legislation et al, that the NDIS was required to operate within to manage and deliver services to the participants. The NDIA Knowledge repository also enabled the NDIA to be aware of and manage its governance requirements.
APS Leadership
In the initial stages of design very experienced ex APS staff were engaged as subject matter expert contractors to provide their experience to the NDIA in the design and pilot stages of the roll out of the NDIA. It made sense to have this group of experts with their APS experiences as there was a need to engage and coordinate with the participating agencies (DHS, DSS etc.) that were ACT based. Hence that approach made a lot of sense as the interests of the NDIA were able to be represented in the senior level negotiations and collaborations with experienced individuals to support and advise NDIA executives based in Geelong.
A project such as NDIA Knowledge requires guidance from senior experienced managers who are knowledgeable of the environment that drives the operational and governance requirements of an enterprise such as the NDIS. Given that that was the environment NDIA Knowledge was able to capture (digitise), their expertise in the technology ensured that it could be accessed by all managers and staff of the NDIA.
Essentially NDIA Knowledge became a repository of digital intelligence for the NDIA that was informed by the experience of many subject matter experts at all levels of the NDIA and was built to support new participants in the NDIA. It is also able to accommodate changes as the environment matures and people involved in the process contribute expertise to improve the processes that they work with.
NDIA Knowledge enabled the design team to present the SDOM as it evolved to senior management and other relevant forums in a way that could be understood and analysed to allow for suggestions of design changes to be made and tested against the intended operation of the full scheme. While this work required extensive consultation between the business architects and the executive, it also required similar levels of engagement with the operational subject matter experts employed by the NDIA.
A more detailed description of the NDIA Knowledge engagement and outcome delivered is attached in Appendix 2.
A number of reviews have been conducted into the NDIS implementation. The resulting reports from these reviews revealed that NDIA Knowledge was judged to be a significant asset for the NDIA and would assist management overcome some of the challenges that the organisation was facing as it moved to full scheme roll out in July 2016.
Excerpts from these reports are attached in Appendix 1
This work was undertaken by the small team and made ready to be made available across the organisation. This was the point at which the challenges emerged. The existing board and Executive management group had endorsed the use of NDIA Knowledge by the organisation and that it should be made available across the organisation. The NDIA then acquired the licenses to facilitate this migration.
Barriers
Essentially the barrier to implementation was the migration from a cloud based solution to being an application installed on the ICT platform that DHS supplied to the NDIA, along with the inability of the NDIA management to negotiate that change.
These barriers fell into two categories. “Technical” and “Other”
Technical
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Holocentric is capable of solving the technical issue and they were relatively minor. We have worked with several IT departments in large organisations to have the Modelpedia operational in large complex IT operations. The specific technical issues revolved around:
o Browser versions supported by DHS o Directory access and integration.
These minor technical issues could be easily addressed if the organisational issues were resolved.
Organisational
The NDIA was constantly undergoing a change of personnel at various levels and the consulting staff that were being used to fill the management roles. This environment was manageable as:
The core goals of NDIA Knowledge were well established The Board supported the vision for the programme The Executive team supported the programme of work.
However, at the point in time that the need to migrate to the DHS environment, the NDIA did not have access to a consistent and knowledgeable CIO. The contracted (NDIA) CIO had moved on and the individuals holding the CIO position were faced with the challenges of supporting the expanding presence of the NDIS and its reliance on IT services.
The occupant of the CIO position lacked the detailed knowledge to negotiate with the DHS IT management. The management of the DHS operational ICT environment is a very challenging task. There is little time for the allocation of resources that are required to understand any business requirement of a client agency that falls outside of the suite of products and services that make up the DHS operational system.
Holocentric’s investment in the NDIS
During 2018, Holocentric has also launched a major initiative, Centro, at our own expense, to assist service providers register, meet quality and safeguarding standards and improve the viability of service providers. Holocentric expects to invest about $1 million in the Centro initiative during 2018/19. This is an extension of the need to manage knowledge more effectively, to remove the confusion, reduce re-work and make the NDIS more attractive to service providers.
Centro commenced with a free solution to help service providers understand the nature of the scheme, including the pricing information, professions, registration groups and supports that may be provided. The information was presented in a digital form, available through a web browser. This is a vastly different proposition from providing a set of documents through a website. Holocentric does not consider the provision of documents online as a digital solution. Documents require a great deal of investment from each of the service providers to understand the relationships between many of the items mentioned in the documentation, cross-reference other documents which often results in different interpretations. Multiple documents as reference points are error-prone from creation and understanding perspectives.
As this activity must be performed by each and every person who needs to understand the supports provided, this results in a massive loss of productivity and threatens the viability of many service providers and may result in some of these opting out of the NDIS. This issue was raised by providers as documented in the report “Improving the NDIS Participant and Provider Experience” published by the NDIS on 26 February 2018.
As at 13 September, almost 1500 people have signed-up to the Centro Free product to help remove the confusion and obtain up-to-date information about the NDIS. Holocentric has committed to maintaining Centro Free at our own expense as we believe this helps to provide a simple and consistent understanding of NDIS rules, reducing the administrative burden of operating in the NDIS, as desired by the NDIA.
The technology underpinning the Centro Free initiative is the same as that used for NDIA Knowledge. While Holocentric is happy to continue to support service providers and ensure that the information remains current, there could be more effective means of managing and disseminating information. A more holistic approach to
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the NDIS will assist the NDIA, local area coordinators, the Quality & Safeguards Commission, auditors, service providers and, most importantly, participants and their families.
The second Centro initiative is the Centro Core product that delivers core policies and processes that need to be in place for all service providers in the NDIA. Again, these are provided in digital form to make navigation simple, increase the likelihood of processes being followed and ensure that current information is accessed. This is in stark contrast to the traditional form of providing a set of documents that are often printed, not maintained and may not meet the set standards. Rather than having compliant processes at the time of audit, Holocentric is committed to maintaining the accuracy, currency and reliability of information at all times.
The Centro Core product is offered at a very low cost, starting at $39 per month and is intended to reduce the heartache and cost for service providers to meet their compliance obligations, while raising the standards and looking after the welfare of participants. Rather than every provider spending many days and / or thousands of dollars to write a similar set of policies and processes, they can access a common set of information that may be supplemented with specialised content to complete their set of information. Using a digital solution enables organisation to verify that all employees have met their obligations and read the appropriate documentation. It is also easily accessible from mobile devices as and when required. In just 10 weeks, more than 120 service providers have taken advantage of this capability.
The NDIA should be applauded for commencing the digital journey with Nadia and NDIA Knowledge and should be encouraged to re-commence this initiative to improve productivity within the NDIA and to disseminate information consistently, accurately and in a timely manner.
Further Opportunities for Digital Knowledge Sharing within the NDIS
There are many opportunities to have information shared in a more digestible, less confusing and consistent fashion throughout the NDIS. While NDIA Knowledge provides the means to have information including the Service Delivery Operating Model shared within the NDIA, there are a great many opportunities to have information shared more effectively across the whole of the NDIS.
The standards that apply for quality and safeguards may be shared digitally (not through documents) between the NDIA, NDIS Commission, auditors, service providers and participants. At this time, documents result in different interpretations, inconsistent standards, increased costs and lower standards. Just on a cost basis, sole traders operating as service providers may be investing about $4,000 each to have policies and processes documented to meet registration and audit requirements. This is a massive waste that does not each the objectives of the scheme. With about 16,000 registered providers, this is a cost of about $64 million. This threatens the viability of many providers and reduces the supports available to participants. The actual cost is likely to be much greater as larger organisations spend far more to have their policies and processes documented.
The auditing process is also very inefficient with a great deal of time spent reviewing documents, having them modified and generally creating a lot of re-work. The additional cost of the auditing process may even exceed that of having policies and processes documented. Do all people in all auditing firms have the same interpretation of the standards? Could these be communicated more efficiently and consistently using digital technology rather than documents that need to be understood by all stakeholders? Do we really expect that all service providers will have the correct interpretation of the standards and their obligations? Holocentric has evidence from many providers that there is great confusion and concern about their compliance obligations.
There are a great many complexities in relation to the plans that need to be produced for participants in the scheme and there is much evidence that there is difficulty in having these consistently communicated throughout the NDIS. While many participants are benefiting greatly from the NDIS, there are many documented instances of planning inconsistencies and the need to re-work plans. While this may be considered a teething problem with the planning process, it is likely to continue as the NDIS will no doubt be subject to constant change as evidence is taken into account when considering new plans. The sharing of information digitally (not through documents) will enable a much more agile approach to be taken where one knowledgebase is updated and shared with all stakeholders.
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A holistic approach to knowledge management will enable all stakeholders to benefit including the NDIA, the NDIS Commission, LAC’s, planners, auditors and services providers resulting in far better outcomes for participants, their families and carers.
Recommendations
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NDIA Knowledge should be re-invigorated As NDIA has made a substantial investment in software to support a digital representation of operations as well as significant time through internal and consulting resources, there is a great opportunity to wreak huge savings through a relatively small investment to update the content and have this as a single source of truth.
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NDIS information should be shared digitally The NDIA Knowledge initiative was an excellent undertaking to capture NDIA information for internal use. This can be extended by sharing information digitally throughout the various stakeholders across the NDIS, perhaps commencing with the LAC’s.
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Review the Centro experience of service providers Over the last few months, there have been a number of service providers who have subscribed to their own digital capture of information and who can now provide insights into the effectiveness of these approaches.
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Appendix 1 - Comments from external reviews
Recommendation no.2 ANAO Report October 2017
3.55 The National Disability Insurance Agency should ensure that the business rules underpinning computer aided decision-making are clearly documented, aligned with legislative and policy requirements, and verified to ensure they have been correctly incorporated into the National Disability Insurance Agency ICT system.
National Disability Insurance Agency response: Agreed.
3.57 The NDIA is developing a systems-based tool (NDIA Knowledge) to integrate NDIS business processes, policies and guidance to staff via a central repository. When finalised, NDIA Knowledge will enable decisions to be tracked and traced to the point of origin e.g. legislation, policy, operational guidance. The system is being designed to become a single-source of truth and provide an appropriate audit trail.
https://www.anao.gov.au/work/performance-audit/decision-making-controls-sustainability-ndis
and from a report produced after a review by a PwC on the NDIS MyPlace Portal Implementation Review dated 31 August 2016
“NDIA operating Model and Business Processes”
The NDIA currently has not implemented a comprehensive Service Delivery Operating Model (SDOM). This has impacted on the successful execution of the Full Scheme Launch and put the existing organisational and put the existing organisational operating model under stress. A NDIA Knowledge tool is currently being developed with the intention to clearly define NDIA customer offerings, processes, technology, information, organisation structure ( including governance, roles and responsibilities), with mechanisms to understand the interaction between key components of the operating model.”
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Appendix 2 - NDIA Knowledge summary
The NDIA Knowledge project was undertaken within the IT structure of the NDIS and based in the Tuggeranong, Canberra. The scope of the project was to capture all business processes and associated artefacts that would be used by staff of the NDIS when it became operational. The processes would be those used internally for the management of corporate functions and all externally facing processes that involved participants and service providers. That programme of work ran for xx months and involved collaboration with many `subject matter experts to document and define processes along with the governance structures and operational activities, along with associated legislation, regulation, IT systems and services. Effectively anything associated with the processes that the NDIS would be undertaking.
This was designed by senior experienced ex APS staff including at least two ex-departmental secretaries. The team had extensive public administration experience in the design and delivery of social services to the community.
This became the basis for a small team of two Holocentric technical consultants and two APS staff team to deliver:
an enterprise repository for the Service Delivery Operating Model (SDOM) framework supporting processes, work practices, guidelines, and associated costs. The operating framework for the consistent delivery of services to achieve the core program outcomes. the NDIA Executive and Senior Leadership access to a management tool to assess comparative design for efficiency and effectiveness, the holistic impact of change, and to identify opportunities for service design improvement. be the single source of truth for staff to find information and learning material for how to do their job.
The NDIA Knowledge Project was to be delivered in two phases:
Phase 1 captured all key elements of the revised SDOM including end-to-end processes, governance, and organisation for: o the end to end service delivery processes and associated eLearning: Enabling referral to services (ILC type services); Making access requests; Making access decisions; Enabling plan development; Making plan approval decisions; Managing plan reviews; Managing Provider registrations; Implementing plans; Managing payments to Participants; and Managing payments to Providers. o linking the core legislation and regulations with each other and with the service delivery processes and learning and development material: NDIS Act; Privacy Act; National Standards for Disability Services; NDIS rules; Delegation; and Operational Guidelines. o role based view of the service delivery processes and authorisation and learning and development linkages for: Access service delivery positions; Pre-planning, Planning, and Implementation service delivery positions; Monitor, Review, and General service delivery positions; and
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NDIA Partners in the Community service delivery positions. Phase 2 included updating NDIA Knowledge with the remaining elements and processes of the revised SDOM as shown in below in Diagram A o Processes - end to end service delivery processes including the specific capture of all inbound and outbound information: Manage Capacity Building event (ILC type services); Administer Capacity Building grant (ILC type services); Manage Provider contracts; Optimise service delivery; and Administrative law reviews. o Efficiency: Cost, time, KPIs, throughput. o Organisation: Skills; and Skills based eLearning and self-assessment.
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Diagram A
Summarises the business architecture as derived from a value chain management perspective and categorises the services and level process.
The NDIA Knowledge team also consulted widely across the NDIA organisation including:
Transition Management Group
Operations staff, including o Regional Managers and other staff at the Preston, Corio and Barwon (NAT) sites.
Business Assurance Team
Governance, Risk and Legal teams People and Culture Finance
Community Linkages
Market and Providers.
These engagements were to populate the more detailed processes and systems and mapped them to the appropriate elements of the SDOM.
The executive management team saw this as providing the NDIA and NDIS with the ability to:
embed the SDOM across the Agency operationally and assist staff to perform consistently and effectively increase quality of service delivery work by providing staff with easy access to up to date information on best practice processes, and learning material increase levels of assurance through standardised business processes have a documented foundation for quality control and business assurance to increase point in time correctness of decision making, and to help drive sustainability of the scheme.
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Diagram B
Governance and Accountabilities for a particular obligation:
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Appendix 3 - A new approach to quality and safeguards
Who can deny the need for quality and safeguarding in the disability sector? With people very vulnerable and a history of abuse, it is a great thing to raise the standards of supports. While only a minority are offenders, there is a clear need for standards and to verify that these are being applied effectively.
However, an inefficient application of compliance obligations creates a great impost on all providers, particularly small organisations and this adds costs to the overall scheme. Some of the issues are that the standards are difficult to understand and that providers need to accumulate a lot of information.
The standard approach to applying standards is to focus on the definition of standards, rather than ensuring that all people are aware of their personal obligations, ensure that they are kept up-to-date and that they are being applied consistently. Some of the key attributes relating to compliance standards:
- Have appropriate policies and processes been defined?
- Are staff aware of obligations and are they kept up to date with any changes?
- Do they consistently perform in a compliant manner? It is most encouraging to see that standards within the NDIS requiring evidence of their application rather than just having policies and processes defined. Some questions to consider in relation to the NDIS:
How can we make the system more efficient while raising the bar? How can we have the Commission concentrate on removing offenders without adding a great cost onto the great providers? How can we encourage more providers by reducing their overheads? How can we assist organisations to detect non-compliance and take prompt action? How do we ensure people are well-aware of their personal obligations? Can we provide real evidence of compliance? Is it possible to accurately synchronise information between regulators, auditors, providers and participants? What is required to reduce bureaucracy to a minimum?
The following scenarios describe the current analogue world and the potential of the digital world for auditing.
The Analogue World
The regulator determines a scheme to meet the expectations and protect the interests of those involved. Performed by people who have a strong belief in the regulations and a commitment to quality, safety, environment, etc. They do not necessarily understand the viability of business and the imposition of regulations, the fear and uncertainty this creates. While these are well-intentioned, they may well threaten the viability of many organisations and test the capabilities of people to understand the obligations and ensure that they comply.
Regulations are produced in documents. They may commence from a framework that is well-understood within the regulator with the multiple dimensions of the framework. They need to be able to communicate this to the various organisations that must comply with standards. The most common, although not the most effective means of communication is through documents. These tend to be one-dimensional documents that are written for a single purpose. The dissemination of information through documents simplifies the message of each individual document but does not create a picture that is understandable.
Organisations are confused by myriad documents that seem to be conflicting and they need to try and put the whole picture together. Eg. NDIA pricing documents. This consumes a great deal of time. Documents are the most-accepted and popular means of capturing, formatting and presenting information that is related to a single purpose. While documents are considered to be a convenient means to present information, they have severe limitations. They typically need to be related to information contained in other documents and require a great deal of cross-referencing of information.
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The complexity of a set of documents results in interpretations of information that leads to inconsistencies, inefficiencies and misunderstandings. While the authors of documents may find these intuitive and a single source of truth, this is often not the case. Multiple authors may be required to ensure the set of documents is provided in an acceptable timeframe. There may already be errors and inconsistencies in these documents. It is not humanly possible to have a perfect set of documents that are consistent and reliable, nor interpreted reliably.
The Future in the Digital World
Standards are set and communicated between the NDIA and NDIS Commission These are captured in a digital form, broken into their component parts and shared with all involved parties. Different views of the standards can be created for the various stakeholders so that can easily understand how they apply to their situation. Each of these views is based on the one source, contained in a digital form to remove redundant information.
The policy documents can still be printed equivalent to the original form. The big difference is that these are generated from one information source. As the source changes, documents are automatically updated and only need to be re-printed (of course, any printed document cannot be guaranteed to be current).
The digitisation of the standards:
Guarantees consistency between documents Allows the format of documents to be changed to suit individual needs May limit the documents to only contain information necessary for the recipient Allows the incorporation of controls in processes to ensure compliance.
How does this digitisation of standards affect auditing?
Standards can be provided digitally from the Commission to auditors, ensuring an accurate transfer of one knowledgebase rather than a complex set of documents that is subject to interpretation.
Step 1 – Providers have a clear definition of standards and obtain the appropriate policies and processes that are applicable to their business. These do not all need to be custom-written although they may require some alignment to internal operations. As these are all digital, auditors can very these policies and processes remotely, utilising different views to investigate and potentially compare to acceptable standards. This is a simple exercise are far more cost-effective than site visits.
Step 2 – Are all people within service providers aware of the policies and processes? Have they consumed them and kept themselves informed of changes?
Digital systems can be monitored. Rather than relying on someone simply signing a form to certify that they have read all the documentation, digital systems can track the actions of people and verify that the information has at least been accessed, even if it cannot be proved that it has been read and understood. This helps organisations onboard staff more effectively and take appropriate action if staff have not kept up-to date. Alerts can be established if people have not accessed the necessary policies and processes, particularly after changes have been made.
Step 3 - The ultimate test is whether people are following processes, acting in a compliant fashion and recording results in the correct manner. A digital analysis of the systems can provide such evidence through digital mining techniques. By logging actions in systems, alerts can be created when processes are not followed correctly. Auditors can examine the reports produced by digital analysis, reducing the time and effort required to complete audits. With digital technology, such activities could be undertaken remotely at a vastly reduced cost to themselves and service providers. This technology can also allow service providers to be continually monitor their own staff performance against the standards, reducing the likelihood of any non-conformance, rather than waiting months or years after any issues.
Step 4 – It may still be necessary to conduct some interviews but only after the majority of the work has been undertaken. This should be less disruptive, less expensive and have far more reliable results.
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