Additional Australian Psychological Society submission to the Senate Joint Standing Committee on the NDIS regarding the operation of NDIS planners pursuant to its written submission and presentation to the Committee’s Melbourne public hearing.
As stated in its submission to the Senate Joint Standing Committee on the NDIS (the Senate NDIS JSC) and reiterated in its subsequent presentation to the Committee on Thursday November 7th 2019, the APS wishes to place on record with the Senate NDIS JSC, the need for increased oversight of the NDIS planning mechanism to ensure individuals with a disability who need psychological assessment or intervention receive it. It does so on two bases. First, no matter how effective an intervention, if it is left on the shelf through a failure of planners to incorporate it in NDIS Participant plans, it may as well not exist. The failure to include psychological interventions in plans has occurred since the inception of the Scheme and on the basis of recent evidence - see the attached information - it may be becoming becoming increasingly common.
Second, no matter how sound the intentions of a Scheme (and the APS strongly believes in and supports the NDIS), if there is no policing of the performance of that Scheme, then that failure will permit the Scheme to sub-optimally meet or fail to meet its obligations. The APS believes NDIS Participants are currently being let down by the failure of NDIS planners to adequate capture Participants need for the delivery of evidence-based interventions by psychologists. It further believes that planners are actively acting against the choice and control of Participants by denying their legitimate requests for such interventions, downscaling the amount funded under plans for such interventions to the point where such intentions are unlikely to provide the anticipated outcomes and/or removing those interventions from existing plans or making them the subject of others Schemes (e.g., for psycho-social disability under the Medicare Better Access to Mental Health Scheme).
Mechanisms for addressing the NDIS planning problem.
Consequently, it strongly suggests the following practical mechanisms and actions be implemented by the NDIA to increase the oversight of planner (and local area co ordiantor or LAC) activity within the Scheme. Without increased oversight, through these kinds of mechanisms the sub-optimal planning that is occurring is unlikely to meaningfully alter.
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Use of data driven analysis of the NDIS planning function by reference to a league table of performance by (e.g., time from scheme entry to assessment, time from assessment to plan completion, the number of reviews of plans conducted, who participated in them and their outcome) by jurisdiction and region.
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Creation of a transparent, easy-to-use, participant-empathic NDIS internal review/mediation mechanism that reduces the use of external dispute resolution (e.g., as currently occurs through the AAT) around plans and plan reviews. The operation of this mechanism should also be subject to performance-related data
(e.g., by reference to parameters such as number of reviews provided, time to completion of such reviews, the number of AAT reviews conducted of the same period and Participant satisfaction with each).
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Establishment of an NDIS planning oversight entity/mechanism for ensuring that participants in need of psychological assessment or intervention receive such care. The model for this exists in the NDIA Quality & Safeguards Commission (NDIA QSC) and the APS suggests that its mandate be extended to cover planners and LACS. This is justifiable on the basis that the NDIA QSC has carriage of Code(s) of conduct for workers and providers.
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The vesting of authority to oversight the performance of NDIS planners in high level, external-to-Scheme, formal, public oversight mechanisms - for example, as are currently in place for health complaints in any of the Offices of State and Federal, Health Ombudsman and Complaints Commissioners. If not in place, this might include annual parliamentary reporting on planning KPIs as part of a parliamentary report on overall Scheme performance; for example, by the Federal Disability Commissioners.
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The development of a mechanism for making the relevant criteria, definitions, processes and mileposts for the approval of interventions by psychologists better known to known to Participants, their families, carers and guardians and health professionals, so that the creation, approval, review and amendment of Participant plans occurs in a Participant-focused, timely fashion.
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Improved consultative mechanisms are established with the health provider stakeholders like the APS at both peak representative and day-to-day levels of functioning, so that appropriate level, early input and guidance is sought from providers in a collaborative top down and bottom up manner.
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