Submission 22 — Alliance20 — NDIS Planning | External submission

Submission to Joint Standing Committee on the

National Disability Insurance Scheme

NDIS Planning Inquiry

ABOUT ALLIANCE20 Alliance20 brings together 21 of Australia’s largest and most influential disability service providers to work with Governments, the National Disability Insurance Agency (NDIA) and others to shape the National Disability Insurance Scheme (NDIS) for a future that enables choice, ensures value, minimises complexity and delivers better outcomes.

Collectively Alliance20 supports around 75,000 people with disability in every state and territory, has over 30,000 staff working directly in disability services and represents around $2 billion in funding for disability services. Drawing on the unparalleled collective experience of members, Alliance20 is focused on shaping and influencing the development of NDIS policy and processes to support the long term objectives of the scheme for the benefit of people with disability in Australia.

BACKGROUND Effective planning is essential as the gateway to the NDIS. It is important that participants are directed to supports that focus on their best life outcomes. It is also important to ensure that those who do not need NDIS supports are directed to arrangements (informal and/or other government services) that enable them to achieve their best life outcomes without NDIS supports.

Planners and Local Area Coordinators (LAC) are fundamental to assisting people with disability and families as they engage with and access the NDIS. LACs/Planners aim to empower people with disability and their families and carers by providing information, planning services, support with pathways and promoting choice and control over key life decisions. Key planning responsibilities include:

meeting with participants and assisting them with their ‘First Plan’ which guides transition into the scheme
assisting participants to implement their plans, including community inclusion and building capacity
undertaking plan reviews with participants. Additionally, LACs are also required to provide a range of other functions around community development and engagement, supports for people ineligible for the NDIS and referrals to other services and pathways.

CURRENT ISSUES Strong sector feedback indicates that LACs currently spend most of their time with individuals and families on planning and services for people eligible for the NDIS and time allocated to people not eligible is greatly reduced and puts pressure on these people to

access alternative supports. Concerns also exist over the different skill sets required for planning and for community development and whether individuals can possess both skills or can effectively undertake both roles.

The inconsistency of approaches by LACs and Planners is also an issue with families reporting different processes, outputs and outcomes from different services which highlights issues with the training, support and experience of LACs and Planners.

Service providers are largely excluded from assisting with LAC and Planner functions, despite many having long term and close associations with participants and significant input that may assist. Families can be told that service providers are not able to assist even if they request this input.

The need to transition many people into the scheme has stretched the resources of LACs and Planners and means that many families do not see a LAC prior to the NDIS assessment. High ‘throughput’ targets also compromise services and limit the time spent with people with high needs and/or with families from vulnerable and marginalised groups. The substantially different needs of mental health participants again stretch the resources of LACs/Planners and greatly increases the knowledge required. These issues are exacerbated in rural and remote communities and Aboriginal and Torres Strait Islander communities.

For many people with disability, considerations about life outcomes extend well beyond an annualised planning cycle. Planning will be ineffective without that capability.

The lack of resources for community development and the need for better links with Information, Linkages and Capacity (ILC) programs reduces opportunity for people with disability who are ineligible for the NDIS to receive information on supports available placing greater pressure on families.

The lack of existing service provider input to planning and service allocation, is disadvantaging participants who have no other representation and do not receive family support. For people with severe disability, this issue often limits the information provided to the NDIS for assessment.

As a result, some people may be ‘over-funded’ and others are grossly ‘under-funded’. The need to understand mental health needs as well as the specific needs of people from Aboriginal and Torres Strait Islanders or CALD backgrounds may compromise assessments and result in poor allocation of services as individuals and families have difficulty in conveying need and in detailing the help that they believe will be useful.

Annualised planning makes it difficult for providers to commit to the service offerings that people with disability are seeking. Annualised planning removes certainty and risk mitigation from the market which needs to make multi-year investments/commitments to supply the services that people with disability would choose.

The history of disability funding shows that other health and human services withdraw where disability funding is a possibility, even if that has long term adverse consequences.

There are also workforce shortage issues resulting in large numbers of new staff being employed in a short space of time and limited experience, resulting in:

Worsening skills shortages for disability services
Limited overall disability knowledge by LACs/Planners
An increased reliance on training and supervision of LACs/Planners to ensure consistency and appropriateness of approach
Short-term contracts for some staff may contribute to the lack of skill and disability knowledge as well as to high turnover

Families and service providers report different approaches to planning and markedly different levels of understanding about disability by LACs/Planners, particularly where the disability has co-morbidities or is relatively rare. This includes:

Inconsistency as to communication issues, whether face to face or phone
The level of support from pre-planning to service allocation
The level of knowledge about different types of disability
Families have also reported a lack of understanding about the nature of disability when it is complex or episodic.

PROPOSED SOLUTIONS Consideration should be given to:

A commissioning approach could be used for future LAC/Planner functions.
Enhanced training, including but not limited to: o knowledge of disability including relatively rare conditions and mental health o knowledge of cultural factors in disability and the need to assist people from Aboriginal and Torres Strait Islander and CALD backgrounds. o administration of consistent process and planning tools to ensure that the experience of one participant/family is similar to another o knowledge and skills in community development to fulfil this part of the role or split the role o knowledge of local service providers and programs
Aligning those most knowledgeable and experienced with the most complex cases.
Employing staff with specific community and/or cultural knowledge and provide an ongoing reference point for that community
Consider splitting the LAC role into planning and community development functions and employ people with these skills in the distinct roles. This will also better serve those ineligible for NDIS.
Include service provider input in planning, particularly in high needs cases and/or where family support is absent or when requested by participants or families. This inclusion could extend to funding needs across the whole of the health and human services sector and to better integrating funding arrangements for providers across this sector

Need for Longer Plans 3

Alliance20 supports the option for NDIS participants to have three years support plans and consideration should also be given for up to five year plans, with a phased implementation between these time frames. The implementation of longer plans should be developed in partnership with participants, providers and the NDIA.

Effective planning brings together the supports, goals and aspirations a participant wants. Central to longer plans is a planning process that strengthens, enables and supports participants to exercise optimum choice and control.

The NDIS plan review and implementation process, can be complicated for both participants and providers:

Participants need to collate a vast array of documentation to support the reasonable and necessary supports they seek, even if they do not need to change those supports.
Providers need to provide data and information to participants, while also managing the alignment of service bookings with expiring/new plans.

The Benefit of Longer Plans The COAG Disability Reform Council Quarterly Report (June 2019) states that for the June 2019 quarter a total of 63,924 plans were reviewed. As the NDIS nears full scheme and volume of plan reviews increases, there will be a substantial risk that the review process will be under more pressure, further compromising participants’ capacity to exercise optimum choice and control.

Longer plans provide the opportunity to further streamline the planning process and reduce the administrative burden for everyone involved. For participants, in particular, this will provide a greater emphasis on goal achievements shifting focus on living their lives, rather than the level of funding.

Three year (or longer) plans provide the opportunity to lay the framework for a more dynamic planning process which can be more flexible, greater recognition of individual difference (both in life choices and life stage of the participant) and responsive to change.

Proposal for Implementation of Three Year Plans With any changes to the NDIS planning process, risks will need to be managed in order to safeguard NDIS participants’ choice and control. Alliance20 proposes the development of guiding principles to assist the implementation such as:

To be eligible for a three year plan, a participant’s NDIS funding should only have varied by (say) 10% (excluding price increases) in each of the previous two years
If a participant’s reasonable and necessary supports change within the three years, a plan can be reviewed
Participants could elect to review only some components of their plan
Annual goals for a participant should be included in a three year plan
Participants should achieve 80% of their annual goals to maintain three year plans 4

Key Elements / Considerations

Different services could have different planning cycle e.g. Supported Independent

Living (SIL)/Community Access

A baseline for measurement of change should to be established
Providers should be required to commit to having a quantitative process in place to measure progress towards participant goal achievement
Providers should be required to commit to participate in a data collection processes to ensure a quantification of the cost reduction due to the change to three year plans
Participants with SIL funding are the most appropriate target for the initial introduction of three year plans.
Participants who are 30 years of age or older tend to be in a fairly stable employment / community access / living situations, and therefore could a secondary initial target for three year plans.
An annual goal achievement/funding suitability review could be completed
If overall plan value has varied less than 10% per annum (excluding price increases) for the previous two years, participants should be considered for three year plans
A checklist template could be completed annually to track goal achievement

Measurement of change Benefits of three year plans will not be felt by participants in the short term. To secure participant benefits providers will need to assess that participants’ goals and achievements align with the plan funding in place. Other benefits, such as for the NDIA and providers from reducing the administrative burden of the NDIS, will become clear over time.

Members Overview

$2 Billion             75,000+             30,000+

in disability funding               clients supported               employees

1,800 service             All members         All support clients

locations             are leading disability not-for-       with complex needs

in all states/territories profits or mutual organisations around Australia providing a range of services

Short Term           Lifestyle Supports       Supported

Accommodation          and skills building   Independent Living

services provided             (Respite)                   services provided

services provided

Employment            Allied Health            Therapy

services provided                services provided                services provided

Member organisations

We operate in all states and territories in Australia