© Assistive Technology Suppliers Australia Pty Ltd 2019 www.atsa.org.au
Submission in response to:
Joint Standing Committee on the National
Disability Insurance Scheme
NDIS Planning Inquiry
6th September 2019
CONTACT
David Sinclair, Executive Officer
ATSA
PO Box 7245, TATHRA NSW 2550
(02) 8006-7357 info@atsa.org.au
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© Assistive Technology Suppliers Australia Pty Ltd 2019 www.atsa.org.au
Introduction
Assistive Technology Suppliers Australia (ATSA) welcomes the opportunity to respond to this Inquiry by the Joint Standing Committee on the National Disability Insurance Scheme: NDIS Planning.
ATSA is a national organisation representing assistive technology and home modification (ATHM) suppliers, including manufacturers, importers, distributors, retailers, tradespeople and technicians. Our 140 members comprise businesses and not-for-profit organisations and range from small family owned concerns to multinational organisations throughout Australia. It is estimated that, excluding ATHM for communication and sensory disabilities, approximately 80% of the ATHM in Australia passes through the hands of ATSA members.
The Australian Assistive Technology and Home Modifications (ATHM) Industry
A viable and competitive ATHM provider sector is pivotal to ensuring choice and flexibility for people with disability in Australia, and to meeting their needs at the lowest possible cost.
Australians with disability have access to most of the world’s leading ATHM products through a network of 350-400 specialist ATHM retailers. The extensive diversity of products and services is remarkable in a market of just 22 million people.
The ATHM industry is as much a services industry, as it is a goods-based industry. In Australia, the cost of most of these services are factored into the retail price of ATHM rather than being charged separately, except for some post-sales activities such as maintenance and repairs. Services to the sector by ATHM suppliers include: research and development, innovation, sourcing new products, training allied health practitioners, standards testing and compliance, regulatory compliance with the Therapeutics Goods Administration, and providing free ATHM demonstration products to Independent Living Centres and other key facilities such as brain injury, spinal cord injury and rehabilitation units.
Services to individual ATHM users include pre-sales activities such as provision of information, advice, detailed assessment and development of specifications for an ATHM solution, quotes, holding extensive stock of a wide range of ATHM for display and trials, configuring and adjusting the device and in-home trialling. Post-sales services include delivery, set-up, adjustment, training, and ongoing support/advice, maintenance, repairs and spares. All of these services are undertaken to ensure a good fit between the person with disability and their ATHM, and often require considerable specialised expertise and experience.
According to the Queensland Competition Authority’s 2014 report into AT pricing, the Australian AT market is highly evolved and very competitive with prices on average 24% lower than those in other countries when delivery to Australia is taken into account (QCA 2014, pg. 48, see Final-Report-Medical-and-Disability Aids-and-Equipment). For more details on AT pricing issues see the ATSA Briefing Paper: Assistive Technology Pricing: Is it fair and reasonable?
An active partnership between the person with disability, their allied health practitioner(s) and their ATHM supplier(s) is essential to ensuring an optimal outcome for the individual.
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© Assistive Technology Suppliers Australia Pty Ltd 2019 www.atsa.org.au
The NDIA’s Assistive Technology and Home Modifications team have been steadily implementing a range of positive reforms to the provision of ATHM supports funded through the NDIS. ATHM providers are therefore going through a period of change, as new processes are defined, trialled and gradually rolled out nation-wide. Hence some of the planning issues raised with ATSA by ATHM providers are gradually being addressed.
ATSA members broadly endorse key reforms to the ATHM quoting processes and the implementation of a simplified low cost ATHM pathway.
However, a significant change to ATHM planning will depend upon the findings of the NDIA’s Specialised Assistive Technology and Home Modifications Assessment Pilot and the subsequent changes to planning processes that are likely to occur. The Pilot was scheduled to conclude in August 2019 and to date, ATSA has not viewed the findings and recommendations. This is likely to have a significant impact on planning for ATHM supports in Participants’ plans, hopefully for the better. ATSA members have expressed concern that the Specialised ATHM Panel, if implemented, may be restricted to larger, national organisations as a great deal of specialist expertise resides with individual allied health practitioners.
In response to the Committee’s specific points of reference, ATSA provides the following
a. the experience, expertise and qualifications of planners; Appropriate ATHM supports vary widely depending upon Participants’ disability, the type of ATHM required (cognitive, mobility, vision, communications, hearing, driving, recreation etc) and the level of complexity. It is not possible for NDIS planners to have the knowledge and experience necessary to effectively plan for ATHM supports and maintenance without engaging specialist AT experts. The is why the outcomes of the recent pilot will be critical to the future of ATHM planning within the NDIS.
In the past, ATHM providers have experienced frequent issues with Participants’ plans, highlighting a lack of understanding of what is ‘reasonable and necessary’. Common failures have included not allowing for adequate ATHM maintenance funding and a fundamental lack of appreciation of the critical role that ATHM plays in the everyday life of those who need it.
Increasingly, ATHM providers are playing an informal role assisting Participants with NDIS planning which is rarely recognised or monetised. Clearly there is a need for more specialist ATHM skills throughout the planning process and ATSA hopes that this will be achieved once changes are implemented as a result of the Pilot.
b. the ability of planners to understand and address complex needs; This varies widely depending upon the experience of an individual planner and disability of the Participant. As explained above, it is impossible for planners to have an in-depth understanding of the application of the myriad of possible ATHM solutions appropriate for the widely varied landscape of disability.
c. the ongoing training and professional development of planners; ATSA is unable to comment extensively on the training and professional development of NDIS planners.
However in relation to ATHM, the annual ATSA Independent Living Expos provide an ideal opportunity for planners to gain a broad appreciation of the range and complexity of ATHM available. These Expos are now run in Brisbane, Sydney, Melbourne, Perth and Canberra and are the largest annual showcase of ATHM in Australia.
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ATSA would welcome the opportunity to include specific sessions for NDIS planners as part of the highly regarded Expo Conference Program. Specialist ATHM providers are also able to offer tailored mentoring for planners if deemed appropriate.
d. the overall number of planners relative to the demand for plans; Given the rapid evolution of the NDIS, it is difficult for ATSA to comment on the adequacy of planner numbers.
Nevertheless, an issue reported by ATHM providers stems from a lack of timeliness when plan reviews are sought. One recent example was of a Participant who lodged a complaint due to his request for an important AT device being ignored by the planner. The plan was only reviewed some 11 months later following an appeal to the Federal Minister for the NDIS. This suggests a lack of available resources to properly deal with planning reviews when required.
e. participant involvement in planning processes and the efficacy of introducing draft plans; ATSA members report continued frustration from Participants due to the failure to provide a draft NDIS plan prior to plan finalisation.
f. the incidence, severity and impact of plan gaps; It is commonly reported that NDIS plans do not include adequate funding for both preventative and emergency maintenance of ATHM. This can result in a Participant having to use alternate NDIS funds leaving them short for other supports or rely on their own private money. ATSA has also heard of ATHM providers being left out of pocket after performing an urgent repair for a Participant in need.
NDIS plans should include a comprehensive list of ATHM that the Participant uses, along with the age of the ATHM. An allocation of funds must then be made for maintenance of each device when deemed necessary.
g. the reassessment process, including the incidence and impact of funding changes; Costly ATHM reassessments can occur over an extended period of time due to the need to trial potential solutions, obtain allied health practitioner evidence, engage with planners and wait to receive the finalised plan. This often results in lengthy delays from when the ATHM provider first supplies a quotation to finally receiving an order/confirmation to supply.
ATHM pricing can vary due to changes in manufacturers’ costs and foreign currency exchange rates, given that more than 90% of most ATHM solutions are imported. A reasonable allowance for changes to ATHM pricing should be considered as a means to streamline supply and avoid the need to requote and undertake a further approval process.
There is also a perception amongst ATHM providers of a lack of informed staff at the NDIA to readily assist with resolving issues.
h. the review process and means to streamline it; Resources need to be made available to respond in a timely manner when Participants request a plan review. Delaying the provision of appropriate ATHM can have a profound impact on Participants’ health and wellbeing, worsen social isolation and increase the workload of caregivers and others providing informal support.
The example provided in point d above had the possible impact of worsening a paraplegic’s shoulder integrity, while increasing the burden on his wife and making it harder to access his local community.
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i. the incidence of appeals to the AAT and possible measures to reduce the number; ATSA has no feedback on NDIS appeals to the AAT.
j. the circumstances in which plans could be automatically rolled-over; Care needs to be exercised in rolling over plans for Participants who rely on ATHM solutions. Ageing devices inevitably require more maintenance and new ATHM solutions regularly emerge that could have a positive impact on Participants’ ability to achieve their goals and potentially reduce the cost of other supports as well as the workload of those providing informal supports.
Timely and responsive processes need to be established for Participants whose plans are rolled over to ensure they are not denied adequate funding for ATHM maintenance and access to emerging technology and solutions.
k. the circumstances in which longer plans could be introduced; Some Participants’ report that they find the NDIS planning process arduous and overwhelming, and implementing longer NDIS plans would help alleviate this. The challenge is how to make the NDIS more spontaneous and lifelike so that Participants are able to pursue opportunities as they arise, to live a fulfilling and inclusive life?
Resourcing the types of timely and responsive processes highlighted in point j above could enable Participants to utilise longer plans, confident in their ability to make changes when required. This is particularly relevant in relation to ATHM.
l. the adequacy of the planning process for rural and regional participants; and Coordinating ATHM trials for rural regional and regional Participants can be costly and challenging, involving long distance travel, the need to transport a wide of possible ATHM solutions (sometimes from multiple providers) and engaging with experienced allied health practitioners. It is hoped the ATHM Pilot will reduce the impact of some of these issues. These difficulties are obviously compounded in remote locations.
m. any other related matters. Developing a successful NDIS plan should then seamlessly progress to prompt plan implementation. ATHM supports included in a plan are generally able to commence immediately, dependent on the lead times for devices and the availability of ATHM technical resources.
ATHM providers continue to encounter costly inefficiencies the NDIS Provider Portal when it comes to NDIS plan implementation.
- The Daily Service Booking report from the portal does not easily: a. Identify an ATHM provider’s quote reference, requiring them to manually match this based on a name or NDIS Participant number and search back through their ERP system.
b. Identify which product/service codes have been included in a plan (ie where the funds have been placed in the Participant’s plan).
c. Identify the state/suburb of the Participant (larger ATHM providers cannot match to local branches for workflow purposes).
- When raising a service booking, ATHM Providers cannot search a Participant’s plan to find where relevant funds are allocated.
ATSA and our members are keen to work with the NDIA to resolve these portal related inefficiencies as soon as possible.
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