NDIA Accountability Project

Submission 36 — Kin Disability Advocacy Inc — NDIS participant experience in rural, regional and remote Australia

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Kin Disability Advocacy Policy and Procedure Manual

INQUIRY INTO THE NDIS PARTICIPANT EXPERIENCE IN RURAL,

REGIONAL AND REMOTE AUSTRALIA

Submission to the Joint Standing Committee on the NDIS

132 Main Street

Osborne Park, 6008

Phone: (08) 9388 7455

Email: admin@edac.org.au

Website: www.edac.org.au

February 2024

President: Angelo Cianciosi

Chief Executive Officer: Wendy Rose

Author: Siyat Abdi PhD

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Contents

INQUIRY INTO THE NDIS PARTICIPANT EXPERIENCE IN RURAL, REGIONAL AND REMOTE

AUSTRALIA ………………………………………………………………………………………………………………………… 1

Submission to the Joint Standing Committee on the NDIS……………………………………………………….. 1

About Kin Disability Advocacy (formerly EDAC): ……………………………………………………….. 3

  1. Application process –Access to NDIS. ………………………………………………………………………………… 5 Issues – ……………………………………………………………………………………………………………………………… 5

The consequences to the issues …………………………………………………………………………………………… 7

  1. Service Access ………………………………………………………………………………………………………………… 8 The Issues ………………………………………………………………………………………………………………………….. 8

The consequences to the issues …………………………………………………………………………………………. 10

  1. Access and Awareness …………………………………………………………………………………………………… 11 The issues – ………………………………………………………………………………………………………………….. 11

The consequences to the issues …………………………………………………………………………………………. 12

  1. Socioeconomic Factors and Disability ………………………………………………………………………………. 12 The Issue – …………………………………………………………………………………………………………………… 12

  2. Recommendations ………………………………………………………………………………………………………… 12 References: …………………………………………………………………………………………………………………………. 14

Appendix A Education Case Study. …………………………………………………………………………………………. 19

Appendix B – Modified Monash Method (MMM) …………………………………………………………………….. 21

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About Kin Disability Advocacy (formerly EDAC):

Kin  Disability Advocacy formerly (EDAC)  is Western  Australia's peak  not-for-profit

organisation advocating for the rights of people with a disability, from a Culturally and Linguistically Diverse (CALD) background and their family and carers.

Kin Disability Advocacy is a member of the National Ethnic Disability Alliance (NEDA).

Kin  Disability Advocacy  currently  receives  recurrent  funding from  the  Australian

Department of Social Services (DSS) and the WA Department of Communities Disability Services (DS).

Kin Disability Advocacy delivers individual and systemic advocacy services in WA’s metropolitan, regional, and remote areas. This includes state-wide CALD advocacy services and individual generalist advocacy to WA’s North-West region (Kimberley and Pilbara).

Additional project funding is used to deliver human rights-based self-advocacy training for people with disability and their families/carers.

Kin Disability Advocacy operates a Digital Communication Project funded by the DSS, which addresses the intersection of disability and ethnicity in relation to various aspects such as services, policies, legislation, and more.

Kin Disability Advocacy generates additional income by providing cultural competency training to the disability services sector. The delivery of this training adheres to the National Disability Services Standards.

Kin Disability Advocacy expresses its gratitude for the opportunity to offer comments in response to the Senate inquiry concerning the NDIS participants’ experience in rural, regional, and remote areas of Australia.

We express our appreciation to the Senate Joint Standing Committee on the National Disability Insurance Scheme for undertaking this inquiry and allowing us to address the terms of reference for the inquiry into the NDIS participants’ experience in rural, regional, and remote areas of Australia.

Our objective is to advocate for adjustments in the operational procedures of the NDIS across several vital aspects, such as application, plan design, implementation, and participant support. We aim to enhance the efficacy of the National Disability Insurance Agency in effectively serving the rural, regional, and remote areas of Australia.

Within this submission, we aim to outline and address the valuable insights shared by NDIS Participants in their experiences with the NDIS process, covering key areas including initial contacts/registrations, eligibility assessment, planning, implementation plans, and the servicing of their plans.

The submission results have been informed by the concerns voiced by Kin’s Individual Advocates and the clients we represent and an extensive literature review on rural and remote Australia.

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The author also acknowledges valuable contribution to this discourse by Dr Qian Fang, Lecturer in Social Work and Human

Services, University of South Australia Justice & Society for

sharing the comparative experiences of participants living in rural and remote South Australia.

The information discussed originates from the advocacy we offer to clients and our contact experience with NDIA operations in rural and remote Australia.

Our submission will emphasise investigating the choice and control NDIS participants possess concerning their services and supports. This submission will focus on the

experiences  of  Aboriginal and  Torres  Strait  Islander  participants,  culturally and

linguistically diverse participants, and participants from low socioeconomic backgrounds.

The impact of remoteness on National Disability Insurance Scheme (NDIS) participation is multifaceted, reflecting challenges related to accessibility, service delivery, and support networks.

Obtaining direct access to local NDIS services can pose a challenge for individuals living in rural or remote areas.

Those residing in regional and remote areas who choose to schedule appointments with specialists experience prolonged travel times and must arrange accommodation in Perth city to attend the appointment, leading to significant financial challenges for these individuals.

Accessing internet services can eliminate the need to travel long distances, saving money and time and potentially increasing the choice of NDIS service providers.

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  1. Application process –Access to NDIS. Issues –

  • If an applicant cannot provide birth certificates, passports, or other identification documents, their application will be held until they can obtain these required forms of identification. This delay subsequently substantially strains community support to obtain clients’ personal information for application processing.

  • A significant number of Aboriginal parents harbour a fear of government services, primarily because of the immense possibility of child protection agencies intervening and separating their families. Many parents within this cohort strongly dislike engaging with the NDIS, as they cannot discern the distinctions between state-based and commonwealth services because of their shared nature as government services.

  • Deficiencies, lack of cohesion, and considerable challenges for our diverse clientele mark the NDIS Access framework in rural and remote Australia. This clientele includes newly arrived refugees and migrants who have established themselves in remote areas, Aboriginal clients living in isolated regions, and individuals with psychosocial disability who frequently encounter challenges in providing evidence of their disability during the NDIS application process. As a result, they frequently endure protracted periods without assistance as they await appointments with specialists to obtain the supporting evidence. The lack of disability assistance leaves individuals without the means to effectively advocate for themselves, which is especially problematic for our clients due to the additional challenges they face regarding language, culture, and accessing information.

Within Australia’s rural and remote areas, there is a considerable prevalence of individuals who lack proficiency in the English language and therefore require assistance. This highlights the additional complexities associated with accessing the NDIS and identifying barriers and enablers for individuals seeking to apply to the NDIS in rural and remote areas of Australia. A good example is having only 1 Auslan interpreter for entire Kimberley region. It is anticipated that individuals who are not fluent in English or require substantial support will encounter further difficulties, especially in socioeconomically deprived areas. This underscores the importance of targeted outreach and support services to ensure equitable and inclusive access to the NDIS.

The support provided by Local Area Coordinators is lacking because of their limited presence in rural and remote areas of Australia. However, data is not being captured to show gaps in service.

  • Applicants face difficulties in accessing the NDIS due to the lack of a knowledgeable guide who can provide a step-by-step access process that caters

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to the requirements of applicants/participants residing in rural and remote regions of Australia.

  • NDIS applicants may receive limited information support from local agencies, teachers, therapists, and other professionals, but it is not within their purview to provide specialised navigation. These individuals may lack expertise in specific disability areas.

  • The expertise of the general allied health practitioners may not extend to pediatrics or a specific diagnosis, thus making it difficult to provide the required evidence for access.

    • The process of accessing diagnoses for autism, intellectual disability, or

psychosocial disability is arduous, and there is a notable absence of systematic distribution of professionals across regions, including rural and remote areas of Australia.

  • Accessing specific diagnoses poses significant challenges, including the financial burden of travel, extended waiting periods (as exemplified by pediatricians), and a scarcity of qualified assessment staff in rural and remote areas of Australia.

  • Difficulties are associated with performing capacity assessments for assistive technology and occupational therapists.

  • The barriers to accessing information include limited Internet access, insufficient digital literacy, unreliable communication infrastructure where one

telecommunication services carrying a monopoly in the regions and the need to consider underserved socioeconomic populations.

  • Individuals with prior involvement in the justice system are not promptly assisted or considered for NDIS access upon release. Face-to-face communication is the preferred approach for building trust among many First Nations individuals. Nevertheless, the vast majority of WA remains non partnered, and access is further limited by inadequate internet and phone service. A case example is reported that a client who was waiting for NDIS appeal case for many months had the possibility of creating a reschedule of the appeal hearing case due to Power outage.

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The consequences to the issues

  • The number of individuals with disabilities residing in remote and very remote locations who receive NDIS support is significantly low.

  • The access and coverage provided by NDIA is limited, and there is a lack of diverse inclusion of participants and support for rural and remote residents with NDIA services.

  • The reduction in the number of NDIS participants who meet the eligibility criteria has resulted in extensive waiting times for individuals with disabilities who are seeking to become part of the NDIS, require evidence for planning purposes, or require funding for allied health services.

  • A significant disparity exists between the NDIS approach and traditional social work values regarding choice, self-determination, and participation.

  • Identifying appropriate assessments about the support needs, daily living activities, and personal goals of individuals with disabilities residing in rural and remote areas of Australia poses a challenge, as it fails to align with the objectives and mission outlined in the NDIS Act of 2013.

  • The availability of information regarding choice and control in relation to the NDIS is inadequate and unsatisfactory.

  • Individuals with potential to participate are succumbing before they can even avail themselves of the scheme, primarily due to the absence of early intervention and mounting frustration with the system.

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  1. Service Access

The Issues

  • Rural regions face the challenge of having a limited number of specialised services available, especially in the domains of healthcare and aged care. Due to the expansive nature of these regions, service providers are scarce. In remote and very remote areas, providers often face a shortage of healthcare and disability service options. The scarcity of resources may constrain NDIS participants’ options to access the assessments and support required to apply and manage their NDIS plans. A few individuals who become NDIS participants face challenges with accessing services, and even if they are able to access services, they encounter substantial restrictions in terms of their plans and objectives.

  • In some regions, service providers are completely absent or nearly absent, leaving participants without local access to the services they require. In addition, the service is commonly available in extremely remote or isolated areas.

  • Travel requirements: Based on the observations of our advocates, some note that individuals living in remote areas may be required to undertake extensive travel to access services, attend assessments, or take part in planning meetings. This can augment the duration, expenses, and intricacy of interacting with the NDIS.

    • Assistive technologists (ATs), occupational therapists, and Orientation

Mobility Instructors (OTs) necessitate dedicated support hours, tasks, and responsibilities. Such services are not readily accessible in remote and rural areas of Australia. As a result, essential support is limited by the number of hours available. The time frame for these sessions can span from one to four hours, excluding travel in remote and rural areas. These professionals must negotiate with the participants regarding the cost of their services.

  • The staff at NDIA lack a comprehensive understanding of the local context with delivering services to individuals with disabilities from culturally and linguistically diverse backgrounds, as well as Aboriginal and Torres Strait Islander people with disabilities.

  • Clients in remote regional areas may encounter cultural safety issues when accessing services from certain providers. The traditional service delivery model may not always suit our clients and can lead to family confusion and conflicts.

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  • In rural and remote areas, there are obstacles to accessing therapy services and implementing individual funding models for children with disabilities. This is a matter of great concern, especially considering the difficulties faced by children with disabilities and their caregivers in navigating the disability service landscape provided by the NDIS in these regions.

  • The presence of disability service deserts and thin markets in rural and remote areas of Australia has a substantial influence on the self-determination and opportunities accessible to individuals with disabilities, underscoring the imperative for targeted interventions to enhance disability service provision and support under the NDIS in these areas. The term “disability service desert” in Australia pertains to regions that lack sufficient disability services that are accessible and culturally responsive to individuals from ethnically diverse communities. The importance of this issue is heightened by the substantial number of culturally and linguistically diverse (CALD) individuals in Australia, as evidenced by recent census data showing that 21% of the population speaks a language other than English at home (Lewis, 2020). In general, as well as in rural and remote areas, diverse communities in Australia encounter obstacles that are logistical, linguistic, and communicative in nature.

  • Individuals with disabilities encounter difficulties when accessing a range of services, including speech therapy, physiotherapy, and occupational therapy (Dew et al., 2012). The shortage of services is compounded by the unequal distribution and overwhelming workload of healthcare workers in rural and remote regions (Dew et al., 2013).

    • The NDIS is currently understaffed to offer necessary services, and

participants encounter challenges in visiting the office to seek clarification. Acquiring clarification can be a lengthy process.

  • Failing to consider the distances between towns when accessing services in terms of budget and service accessibility imposes limitations on participants’ ability to make choices and control their plans.

  • Planners, whether from different regions or within urban centers, frequently lack familiarity with the distances between towns and the difficulties in obtaining the required evidence for access.

    • There is insufficient information regarding access to doctors, and on

occasions, doctors face difficulties accessing medical billing agencies to generate prescription reports.

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•     The  lack  of  trained  staff competence exposes  participants  to  vulnerability,

compelling them  to  engage  private  support  workers  instead  of  qualified

professionals who have undergone proper documentation checks.

  • In remote areas, there is a lack of awareness and access to information about the NDIS and its benefits. The primary factor behind this is the inadequate provision of local services and community outreach networks. This can lead to a lack of programs utilisation by eligible individuals. Obtaining comprehensive guidance on navigating the NDIS process is more arduous in remote regions, characterised by unreliable internet connectivity and a scarcity of community centres or support networks.

Remote communities commonly cultivate strong social connections, yet they may face limited access to professional support networks in the realm of disability services. The ability of individuals and families to receive the assistance required for optimal involvement in the NDIS may be compromised. As an illustration, the government’s remote community connectors program facilitates the dissemination of information and the education of the local population. Nevertheless, the remote community connectors face resource limitations and encounter particular difficulties in serving the aboriginal communities, primarily because of inadequate support from NDIS. Consequently, the connectors face limitations in effectively informing and educating local individuals about NDIS services. Therefore, there is a necessity for education and increased funding to deploy additional personnel, as the connectors must travel significant distances to deliver education to the community.

•     The NDIS training program  is deficient in meeting the needs of local

communities and fails to effectively engage them.

  • The funding’s sustainability and long-term viability are compromised by the possibility of not renewing block funding, thus leading to interruptions in NDIS staff’s ability to provide continuous support and services. Furthermore, the process of accessing funding is time-consuming.

The consequences to the issues o Prolonged waiting times and extensive lists.

o Participants are facing a decrease in their ability to make choices and have control over their services.

o   Insufficient   service   availability  could   result   in  the   potential

underutilisation of NDIS plans.

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o If the current funds are not fully utilised, there is a possibility of reduced funding in future plans.

o Growing dependence on informal care or the necessity of traveling considerable distances for services.

o Participants experience a substantial decline in both their quality of life and independence.

o The presentation only scratches the surface regarding service availability and delivery, failing to adequately meet the participants’ demands.

  1. Access and Awareness The issues –

  • The impact of socioeconomic status on access to information and services, including healthcare and support systems like the NDIS, is substantial.

  • A higher socioeconomic status is frequently associated with improved education, stronger social networks, and increased access to information. These factors can enhance involvement with and utilisation of the NDIS.

    • Individuals living in regions with the lowest socioeconomic disadvantage may

encounter obstacles, such as limited awareness concerning the NDIS, challenges in comprehending the enrolment procedure, or inadequate assistance navigating the system.

  • There is a significant prevalence of individuals lacking proficiency in English and requiring assistance in rural and remote areas of Australia. This brings attention to the added complexities in accessing the NDIS and identifying the obstacles and facilitators for those applying to the NDIS in rural and remote Australia.

  • Non-English speakers and individuals in need of substantial support are likely to face extra challenges, especially in areas with lower socioeconomic status. This highlights the significance of implementing focused outreach and support programs to guarantee fair and equal access to the NDIS.

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The consequences to the issues

  • The current system is in disarray, resulting in ineffective service for participants and hindering the achievement of the NDIA’s strategic objectives.

  • Inequity is evident in the access and distribution of services provided by the NDIS.

  • The prevailing discontent surrounding the operation and management of the NDIS scheme in rural and remote Australia stems from the belief that the agency’s

    operations are restricted to metropolitan areas with the infrastructure and

workforce resources.

  1. Socioeconomic Factors and Disability

The Issue –

  • There is ample evidence to suggest a correlation between lower socioeconomic status and elevated rates of disability. Adverse health outcomes, increased accident risk, and limited availability of early intervention services influence this correlation.

    • Based on the data, it can be inferred that enrollment in the NDIS is

disproportionately higher in areas with greater advantages, highlighting potential disparities in NDIS accessibility and usage (reference: appendix…).

  1. Recommendations o Providing incentives for service providers to operate in these areas.

o Deploy versatile service models, such as telehealth or the augmentation of mobile services.

o Support the development of service solutions that prioritise community involvement and mobility.

o Introduce focused and effective policy changes to address the specific difficulties faced in these particular areas.

o Methodically establish practical frameworks to provide and uphold the need for culturally proficient and inclusive services while mitigating concerns surrounding the NDIS’ efficacy in addressing the specific challenges encountered by Indigenous people with disabilities and individuals from diverse ethnic backgrounds. This assertion is backed by implementing culturally sensitive and inclusive service delivery models, which address the specific needs of ethnically diverse communities (Unwin et al., 2016).

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o The involvement of socioeconomic status (SES) in NDIS engagement implies the necessity of focused policy interventions to guarantee fair and equal entry into the program. This could encompass outreach initiatives in socioeconomically disadvantaged regions, assistance programs for

individuals with  limited  English  proficiency, and  streamlining the

enrollment procedure. Comprehending the challenges those in lower quintiles confront can help adapt services to cater to their particular needs, ensuring that the NDIS effectively assists all eligible individuals, regardless of their socioeconomic status.

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Young, L., Sigafoos, J., Suttie, J., Ashman, A., & Grevell, P. (1998). Deinstitutionalisation of persons with intellectual disabilities: a review of australian studies. Journal of Intellectual & Developmental Disability, 23(2), 155-170. https://doi.org/10.1080/13668259800033661

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Appendix A Education Case Study. Client A reached out to us seeking support for her daughter, Client B, who has been diagnosed with ASD, ADHD (possibly ID), and is experiencing difficulties at a nearby rural high school. Despite being informed about Client B’s diagnosis, the school has opted to remove her from class for stimming, which is a cause for concern.

Client A is experiencing frustration because of the school’s denial to furnish details concerning the allocation of funding (schools plus) and the precise implementation of support strategies for Client B within the classroom. Despite the submission of reports from various therapy teams (OT, Speech, Psych, etc.), the school has resisted adopting any of the recommended strategies.

Regrettably, Client B has been a victim of bullying, including the alarming occurrence of death threats through social media. Surprisingly, the school has failed to respond, asserting their inability to intervene or even denying the occurrence of the incidents. Unfortunately, Client B has also been a victim of physical assault, and despite their previous attempts to seek help from the police and District Education office, they were unsuccessful and were referred to the school.

The Support Coordinator, Person C, has attended a meeting at the school and personally observed the problematic behaviour. Their intervention did not yield a satisfactory resolution with the school.

In addition, other members of the school faculty have observed the disrespectful conduct of the senior school team towards the parent, yet they are reluctant to intervene.

The school has recommended alternative options such as home schooling or the SIDE program; however, Client A deems these alternatives unsuitable. Despite ongoing endeavours to uncover more suitable rentals in various areas, no appropriate lodging has been found.

Adding to the complexity, Client B’s sibling, Client D, who also has Level 3 ASD, is a student at the same school and receives support through a NDIS plan.

Understandably, Client A is experiencing emotional exhaustion and distress due to the treatment her children have received at the school. They are seeking advocacy support to achieve a satisfactory resolution, which would enable Client B to attend school without worrying about bullying and guarantee that she receives the support she needs.

Subsequently, the advocate contacted the Regional Education office to explore viable solutions and assist in the resolution. The response proved unexpectedly surprising, as it suggested that the family explore alternative educational possibilities. The family placed their trust in the advocate to handle the submission of a formal complaint to the Standards and Integrity Department. The regional office contacted the family to resolve

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the complaint. This course of action was believed to have been initiated because of the complaint.

Since then, the school has informed the family that they are forming a new team to address their concerns. However, this response does not adequately address the family’s previous experiences and ill-treatment from certain individuals within the school community. This mistreatment has spilled over into the local rural community, resulting in incidents of public harassment directed at the family.

The family has expressed that some community members have also raised concerns and sought solutions from the school with no positive outcomes. Client A was subsequently advised on where these families can seek help. It is particularly disconcerting to note that the key individuals responsible for these issues have been allowed to either stay in their positions and one has been transferred to another position out of area and been promoted.

The family seeks accountability for the treatment they have endured and the distress their daughter has faced because of her disability. They view this mistreatment as discriminatory. They have taken the step of lodging a complaint with the Human Rights Department.

As a result of the ongoing difficulties, the family has opted for external online education for Client B to ensure her safety. However, this decision has the unintended consequence of isolating her from vital social connections. Regrettably, the family feels that Client B cannot safely return to the local High School, as the individuals responsible for her victimisation have not been held accountable.

The situation has caused immense stress for the family, and they are even considering relocating outside of Australia to safeguard their children they have been unsuccessful to find accommodation in another area and close to Client A’s husband’s place of employment. They are seeking a comprehensive investigation into the events that transpired and identification of those accountable. Additionally, they request a sincere explanation and apology from the involved parties and a clear plan for supporting children with disabilities in rural communities moving forward.

The advocate then drafted a letter to the minister of education and sent it to the family for approval.

The most recent development concerning this family is that they have requested Kin Advocacy to suspend this matter temporarily, complaining about potential complications in their ongoing citizenship application. Although the advocate has assured them, it should not pose any risks, they understand the parents’ perspective and will await further instructions later.

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Appendix B – Modified Monash Method (MMM)

Meshblocks Monash Modified Method

Remoteness            1         2         3        4        5         6        7        Grand

ABS Total

111                                                                          111     0.03%

Major Cities

216,204                                                                 216,204    60.37%

of Australia

Inner

Regional                             31,886    20,351    10,129     13,759      174               76,299    21.31%

Australia

Outer

Regional                              5,213      6,036      4,512     31,695      162               47,618    13.30%

Australia

Remote

9,768      220      9,988     2.79%

Australia

Very

Remote                                                                                    7,900      7,900     2.21%

Australia

Grand Total       111    216,204     37,099    26,387    14,641     45,454    10,104     8,120    358,120   100.00%

0.03%    60.37%    10.36%    7.37%    4.09%   12.69%    2.82%    2.27%   100.00%

The table highlights the complexity and nuances involved in using geographic classifications like the Monash Modified Method (MMM) and the ABS Remoteness Areas for planning and analysis in Australia. These systems categorise areas based on accessibility and proximity to services, which are crucial for resource allocation and service delivery. However, applying these methods, especially the MMM, can affect how we understand and address the needs of specific populations, such as those with disabilities.

Key Points on MMM and ABS Remoteness Areas

  • MMM for Health Workforce Planning: The MMM is tailored for health workforce planning, focusing on the accessibility of health services. It categorises individual Statistical Areas Level 1 (SA1s), allowing for detailed micro-level planning. This specificity is crucial for health service delivery but may not capture the broader needs of communities, especially in terms of human services beyond healthcare.

  • ABS Remoteness for Broader Planning: The ABS Remoteness Areas provide a more general classification, useful for a wide range of planning purposes, including education, infrastructure, and broader human services. This classification considers the physical distance from services and amenities, offering a contiguous geographic perspective that can guide comprehensive policy and program development.

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Implications for Disability Services and Population Distribution

  • Disguising Population Distributions: When the MMM is applied to disability information, there’s a risk that the specific distribution and concentration of populations, particularly those with disabilities, might be obscured. This is because the MMM focuses on health service accessibility rather than the broader spectrum of services and supports that individuals with disabilities might require. For example, areas with significant concentrations of people with disabilities may require targeted services beyond healthcare, such as specialised education, employment support, and accessible infrastructure.

  • Need for Integrated Approaches: To effectively address the needs of populations with disabilities, it is essential to integrate data from both the MMM and ABS Remoteness Areas with disability-specific information. This integrated approach can help identify the healthcare needs and broader social and infrastructure requirements of these populations.

  • Tailoring Services to Community Needs: Understanding the geographic distribution of populations with disabilities requires a nuanced approach that considers both the accessibility of health services (as highlighted by the MMM) and the overall remoteness (as defined by the ABS). This dual perspective can guide the development of tailored services that address the comprehensive needs of individuals with disabilities, ensuring equitable access to all necessary supports.

The application of geographic classification systems like the MMM and ABS Remoteness Areas has significant implications for planning and service delivery across Australia. While these systems provide valuable frameworks for understanding accessibility and remoteness, their application to specific populations, such as those with disabilities, requires careful consideration. By integrating these classifications with detailed population data, policymakers and service providers can develop more effective strategies to meet the diverse needs of all Australians, ensuring that no group is disadvantaged by geographic location.

The use of the Monash Modified Method (MMM) by the National Disability Insurance Agency (NDIA) to report on Culturally and Linguistically Diverse (CaLD) and First Nations participants without providing additional context presents several issues, which can be understood through a broader examination of the implications of context in research and reporting methodologies. While the specific studies on the MMM’s application in this context are not directly available, insights can be drawn from related research on the importance of context in meta-learning, ethical considerations in research involving diverse groups, and the generalizability of findings from controlled experiments.

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Issues Associated with the NDIA’s Approach

  1. Context-Agnostic Reporting: The NDIA’s approach, by focusing solely on geographical remoteness without additional context, overlooks the complex interplay of cultural, social, and economic factors that influence the experiences and needs of CaLD and First Nations participants. Perrett et al. (2020) emphasise the importance of considering context in meta-learning to avoid the distraction of irrelevant data. This analogy highlights how ignoring the context in reporting can lead to misinterpretations and oversights in understanding the needs of diverse groups.

  2. Ethical Considerations: Reporting on sensitive demographic data requires careful ethical consideration, particularly regarding voluntariness, informed consent, and the potential for coercion. Liebel and Chakraborty (2021) discuss the ethical issues in empirical studies involving student subjects, underscoring the need for transparency and ethical rigour. Similarly, the NDIA’s reporting practices must ensure ethical data handling, especially given some participants’ vulnerable status.

  3. Generalisability and Validity Concerns: The NDIA’s use of the MMM without context may raise questions about the generalizability and validity of its findings. Research by Dahabreh et al. (2018) on extending inferences from randomised trials to new populations illustrates the challenges in applying findings across different contexts. This suggests that the NDIA’s reports do not fully capture the diverse realities of CaLD and First Nations participants, leading to policies and services that do not adequately meet their needs.

  4. Lack of Detailed Reporting: The absence of detailed reporting on the recruitment and characteristics of participants can undermine the credibility and usefulness of the NDIA’s findings. Schaer et al. (2012) and Daun et al. (2017) highlight the importance of detailed reporting in research to enhance understanding and applicability. The NDIA’s approach, by not providing comprehensive context, may limit the ability of policymakers and service providers to develop targeted and effective interventions.

Conclusion

The NDIA’s reporting approach, characterised by a lack of contextual detail, presents several challenges, including the risk of oversimplification, ethical concerns, and questions about the generalizability of its findings. To address these issues, it is crucial to incorporate a more nuanced understanding of the diverse experiences and needs of CaLD and First Nations participants, ensuring that policies and services are informed by a comprehensive and ethically sound evidence base.

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References

  • Perrett, T., Masullo, A., Burghardt, T., Mirmehdi, M., & Damen, D. (2020). Meta-

Learning with Context-Agnostic Initialisations. Retrieved from

http://arxiv.org/abs/2007.14658v2

  • Liebel, G., & Chakraborty, S. (2021). Ethical Issues in Empirical Studies using

Student Subjects: Re-visiting Practices and Perceptions. Retrieved from

http://arxiv.org/abs/2102.13387v2

  • Dahabreh, I. J., Robertson, S. E., Steingrimsson, J. A., Stuart, E. A., & Hernan, M. A. (2018). Extending inferences from a randomised trial to a new target population. Retrieved from http://arxiv.org/abs/1805.00550v3

  • Schaer, P., Hienert, D., Sawitzki, F., Wira-Alam, A., & Lüke, T. (2012). Dealing with Sparse Document and Topic Representations: Lab Report for CHiC 2012. Retrieved from http://arxiv.org/abs/1208.3952v1

  • Daun, M., Hübscher, C., & Weyer, T. (2017). Controlled Experiments with Student

Participants in Software Engineering: Preliminary Results from a Systematic

Mapping Study. Retrieved from http://arxiv.org/abs/1708.04662v1

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