Registration of Accredited Exercise Physiologists within the NDIS | External submission

Submission to the Joint Standing Committee

on the National Disability Insurance Scheme

Inquiry into NDIS Planning

September 2019

1.0 About Exercise & Sports Science Australia

Exercise & Sports Science Australia (ESSA) is a peak professional association representing over 8,000 members,

including university qualified and Accredited Exercise Physiologists (AEPs) and Accredited Exercise Scientists

(AESs). AEPs are recognised allied health professionals who provide clinical exercise interventions aimed at

primary and secondary prevention; managing sub-acute and chronic disease or injury; and assist in restoring

optimal physical function, health and wellness.

1.1 AEPs and the National Disability Insurance Scheme

There is compelling evidence that clinical exercise interventions, as delivered by AEPs, provide a range of

physical, mental and psychosocial benefits to people with a disabilityi ii. AEPs develop a range of exercise

based activities that empower National Disability Insurance Scheme (NDIS) participants and support them to

achieve goals in the areas of daily living, social inclusion and functional well-being.

AEPs can currently register under the ‘Exercise Physiology and Personal Well Being Activities’ registration

group. This registration group was recently expanded to include exercise physiology supports in both the

‘Improved Health and Wellbeing’ and ‘Improved Daily Living’ categories of participant plans. The Council of

Australian Governments (COAG) Disability Reform Council’s Quarterly Reportiii revealed that as of June 2019,

2,557 approved providers are registered under the Exercise Physiology and Personal Well Being Activities

registration group.

ESSA has recently received advice that amendments have been made to the NDIS Practice Standards

Verification Module - Required documentationiv to support the registration of AEPs within the Therapeutic

Supports registration group. The NDIS Commission has noted that applications will be accepted pending the

completion of system enhancements for the NDIS Commission and the National Disability Insurance Agency

(NDIA). It is anticipated that the system enhancements will be completed in October 2019.

2.0 ESSA’s Submission to the Inquiry into NDIS Planning

ESSA welcomes the opportunity to provide input into the Joint Standing Committee on the National

Disability Insurance Scheme’s Inquiry into NDIS Planning.

ESSA considers the quality of an NDIS planning experience can be life changing for individuals with a disability

and their family/carers. A positive planning experience has the ability to improve the quality of life of both

participants and their family/carers whilst a negative planning experiences can be distressing for all involved

and lead unessesary to gaps in care.

ESSA’s submission is based on feedback from Accredited Exercise Physiologists delivering services under the

NDIS and provides responses to the following terms of reference:

A. the experience, expertise and qualifications of planners B. the ability of planners to understand and address complex needs C. the ongoing training and professional development of planners G. the reassessment process, including the incidence and impact of funding changes; H. the review process and means to streamline it L. the adequacy of the planning process for rural and regional participants; 3

3.0 Summary of Recommendations

In response Joint Standing Committee on the National Disability Insurance Scheme’s Inquiry into NDIS

Planning, ESSA recommends that:

NDIA Planners, particularly those in leadership positions, be required to have qualifications and/or experience in health, human services or disability.
The NDIA adopt strategies to ensure participants receive a quality planning experience where appropriately skilled and experienced staff are not available to fill NDIA planning positions.
The NDIA adopt strategies previously proposed by the Productivity Commission in relation to improving NDIA planner’s disability knowledge.
NDIA strategies adopted following the Joint Standing Committee on the National Disability Insurance Scheme’s inquiry into the Provision of services under the NDIS for people with psychosocial

disabilities related to a mental health condition be evaluated, with learnings used to inform the

development and delivery of specialist planning approaches for other types disability.

Planners new to the disability sector receive practical training and mentoring support to assist with the development of communication, supported decision making and cultural awareness skills.
Planners receive ongoing education about the role and value of allied health professions, including Accredited Exercise Physiologists.
The NDIA Allied Health Practitioner Engagement Project be adequately resourced to support increased planner knowledge of and engagement with allied health professionals.
NDIS plan reviews are made subject to quality measures and feature meaningful engagement with both participants, carers and relevant providers.
The NDIA’s ‘Rural and Remote Strategy’ and its ‘Aboriginal and Torres Strait Islander Engagement Strategy’ be independently reviewed, with a report against progress achieved made available to the

public.

4.0 ESSA Response to Terms of Reference

A. The experience, expertise and qualifications of planners ESSA considers it essential that planners have qualifications and/or experience in health, human

services or disability. ESSA suggests that a lack of relevant qualifications and experience in these areas

significantly impacts on the ability of planners to understand and address the complex needs of

participants.

ESSA understands that the disability sector generally is facing significant workforce challenges and the

NDIA is not excluded from this. However, ESSA suggests that a range of strategies could be put in place

where appropriately skilled and experienced staff are not available to fill NDIA planning positions.

Strategies could include:

ensuring leadership/supervisor positions within the planning team are filled by qualified and experienced staff.
providing unqualified staff, new graduates and/or people with relevant qualifications but limited disability knowledge with supervision/mentoring.
ensuring plans are reviewed by allied health professionals and/or experts in particular disabilities before being approved. Involvement of an allied health or medical professional at the planning

level will assist in ensuring a thorough assessment of the consumer’s needs, an understanding of

the condition and progression of the disease and the appropriate support required.

encouraging greater use of expert NDIA advisory teams/ consultants in NDIA planning policy and processes.
funding organsiations with specialist knowledge on particular disabilities to support participants with pre-planning support.

Recommendation: That NDIA Planners, particularly those in leadership positions, be required to have

qualifications and/or experience in health, human services or disability.

Recommendation: That the NDIA adopt strategies to ensure participants receive a quality planning

experience where appropriately skilled and experienced staff are not available to fill NDIA planning

positions.

B. The ability of planners to understand and address complex needs The Productivity Commission’s study report on ‘National Disability Insurance Scheme (NDIS) Costs’v

raised concern about the limited disability knowledge of planners. The report noted that planners did

not have sufficient knowledge of:

particular disabilities
the impact that particular conditions have on people’s lives, and
what particular supports are effective for a participant’s disability. Nearly two years on from the release of this report, ESSA members continue to report similar concerns

about the lack of planner knowledge.

ESSA supports strategies previously proposed by the Productivity Commissionv, aimed at improving

planner’s disability knowledge. These strategies included:

specialist planning teams for some types of disability
better use of expertise from within the industry, getting specialist disability organisations involved in the planning process (disability representative organisations).

ESSA understands the Joint Standing Committee on the National Disability Insurance Scheme, following

their Inquiry into the Provision of services under the NDIS for people with psychosocial disabilities

related to a mental health conditionvi recommended that the NDIA, in conjunction with the mental

health sector, create a specialised team of NDIS planners trained and experienced in working with

people who have a mental health condition as their primary disability.

The implementation status reportvii indicated that the following strategies were adopted by the NDIA in

relation to this recommendation:

training of the NDIS workforce to better understand severe and persistent mental health conditions
the progressive implementation of a psychosocial disability stream (in specific locations) featuring the

o the employment of specialised planners and Local Area Coordinators (LACs)

o better linkages between health services and NDIS staff and partners

o a focus on recovery based planning and episodic needs

o the development of a Psychosocial Disability Capability Framework to help inform the

recruitment of staff and requirements to work in specialist roles within the NDIA.

ESSA suggests there may be opportunities to the learn from the success and failures of these strategies

and apply learnings to the development and delivery of specialist planning approaches for other types

of disability.

Recommendation: That the NDIA adopt strategies previously proposed by the Productivity Commission

in relation to improving NDIA planner’s disability knowledge.

Recommendation: That NDIA strategies adopted following the Joint Standing Committee on the

National Disability Insurance Scheme’s inquiry into the Provision of services under the NDIS for people

with psychosocial disabilities related to a mental health condition be evaluated, with learnings used to

inform the development and delivery of specialist planning approaches for other types disability.

C. The ongoing training and professional development of planners ESSA suggests that NDIA planners be supported to develop a strong understanding of the complex

needs associated with particular disabilities (i.e. cerebral palsy). As previously suggested, this may

require training and development of NDIA planners in specialist knowledge areas.

ESSA notes there are advances in disability related research every year and NDIA planners should

undertake ongoing professional development to ensure they stay up to date with best practice and

innovative evidence-based interventions for people with a disability.

ESSA suggest that planners, particularly those new to the disability sector, would benefit from practical

training and mentoring on communication strategies, supported decision making and cultural

awareness.

ESSA strongly recommends that all planners be educated about the role and value of allied health

professions available under the NDIS. ESSA would welcome the opportunity to provide the NDIA with

education and resources on the role and value of exercise physiology.

Exercise physiologists develop interventions for NDIS participants that empower them and improve their

daily living, social inclusion and functional well-being. Despite this, AEPs constantly have to justify to

planners how their services are relevant to NDIS outcomes.

For example, one ESSA member reported that a planner recently denied a participant funding for both

an exercise physiologist and a dietician stating:

“The request for exercise physiology and a dietician will be declined. These supports are more

fittingly provided by Health as they are not disability-related supports. The need for a dietician and

exercise physiology is related to medication-related weight gain, not to her traumatic brain injury nor

her schizophrenia.viii”

In this scenario, the participant’s health and wellbeing related goals were directly attributable to the

primary diagnosis and included strategies to address motivation and the impact of antipsychotic

induced weight gain.

In some circumstances, if a planner perceives interventions or outcomes to be too focused on health and

wellbeing as opposed to function and mobility, they advise particpants to use other rebatable health

services (i.e. Medicare Chronic Disease Management (CDM) Plans [Item code10953] and Private Health

Insurers) before approving exercise physiology services within the NDIS.

ESSA would like to highlight that CDM plans only provide five services in one year and are spread across

multiple allied health providers. Many consumers only receive one-two sessions of this plan which does

not adequately address their multiple chronic diseases and/or co-morbidities and these sessions are

often used within the first few months. If participants were to spread their maximum five CDM services

across the requiredallied health practitioners (e.g. speech therapist, dietician, exercise physiologist), the

ability to make significant changes to the health and wellbeing is limited to potentially only one session

per practitioner per year.

ESSA notes that the NDIA engaged with the Allied Health Professions Australia’s NDIS Working Group

earlier in the year to discuss an Allied Health Practitioner Engagement Project. This project aimed to

improve the interactions between NDIA staff and partners and external allied health practitioners. ESSA

would like to see the Allied Health Practitioner Engagement Project progress in a timely manner with

appropriate resourcing allocated for activities identified as valuable in improving NDIS planner

knowledge of and engagement with allied health professionals.

Recommendation: That planners new to the disability sector receive practical training and mentoring to

assist with the development of communication, supported decision making and cultural awareness

skills.

Recommendation: That planners receive ongoing education about the role and value of allied health

professions, including Accredited Exercise Physiologists.

Recommendation: The NDIA Allied Health Practitioner Engagement Project be adequately resourced to

support increased planner knowledge and engagement with allied health professionals.

G. & H. The reassessment process, including the incidence and impact of funding changes and the review process and means to streamline it

In general, ESSA is supportive of a 12-month review process. Participants’ circumstances can change

significantly over a 12-month period and ESSA considers it important that participants are supported to

reassess their changing needs and goals. As a professional body, committed to supporting the provision

of transparent, accountable and quality exercise physiology services, ESSA also consider it important for

clinicians to held accountable and report on outcomes via the annual review process.

ESSA considers it essential that the review process be a meaningful process for participants. Plan

reviews should not be rushed and should feature meaningful engagement with both participants, their

carers and providers.

ESSA members have reported that some funding review meetings are being requested early and the

review process is rushed. For example, one AEP was asked to prepare a report to help inform a

participant’s plan review.viii The AEP was given two weeks to prepare the report, however, the plan

review process was finalised before the two weeks expired and before the AEP report was submitted.

As a result, the planner did not review the supporting documentation prepared by the AEP and made a

clinical decision that they were not qualified to make. The outcome of this process was reduced funding

for the participant.

ESSA suggests that this practice not only impacts on the quality of the plan provided to the participant,

it also a misuse of valuable NDIS funding (i.e. the NDIS is paying for the preparation of professional

reports that are not taken into considered as part of the plan review process).

Recommendation: That NDIS plan reviews are subject to quality measures and feature meaningful

engagement with both participants, carers and relevant providers.

L. The adequacy of the planning process for rural and regional participants ESSA members report an apparent shortage of local NDIS planners in rural and remote locations. ESSA

considers a local presence to be critical in ensuring planners build the local knowledge and connections

(with participants, families, carers, NDIS providers and mainstream services) required for the provision

of responsive plans.

ESSA has heard from its members that NDIS planning in rural and remote areas is often conducted via

the phone, where a local presence is not available. ESSA has a number of concerns relating to telephone

planning including:

the inability of planners to assess and incorporate environmental factors into a plan
the limited ability of planners to engage with participants with communication disorders in a meaningful and inclusive way
cultural barriers faced, particularly for those who identify as Culturally and Linguistically Diverse and Aboriginal and/or Torres Strait Islander.
a reported lack of clarity amongst participants that a telephone conversation with the NDIA is in fact a planning meeting limiting the ability of participants to pre-plan and engage planning

support from family members, carers, representatives and other supporters.

The absence of a local NDIA presence also sees many NDIS participants/potential participants seeking

face-to-face supports from health professionals and community organisations with offices situated in

the local area. Service providers in these communities often spend a substantial amount of time

answering questions about the NDIS and planning process and are rarely compensated for information

and supports they provide.

ESSA is particularly concerned about the planning experience of Aboriginal and Torres Strait Islander

people living in rural and remote locations. The COAG Disability Reform Council’s Quarterly Report –

June 2019iii indicated that 16,417 people identifying as Aboriginal and Torres Strait Islander had a plan.

This data did not provide statistics on how many Aboriginal and Torres Strait Islander people receiving a

plan lived in rural and remote Australia.

ESSA is concerned about how NDIA figures compare to Australian Bureau of Statisticsix data which

indicates that 34,300 Aboriginal and/or Torres Strait Islander people have a severe/profound disability

(7,333 in remote locations) and 66,900 have a mild/moderate disability (9,900 in remote locations).

ESSA considers the discrepancies between NDIA figures and ABS statistics to be concerning and

suggests that significant barriers continue to exist between Aboriginal and Torres Strait Islander people

with disability engaging with the NDIS to develop plans.

ESSA notes that the NDIA has a ‘Rural and Remote Strategy 2016-19’x and an ‘Aboriginal and Torres

Strait Islander Engagement Strategy’xi. Both strategies are due to expire at the end of 2019. ESSA would

be interested to see an independent and publicly available report on the progress achieved against each

of these strategies.

Recommendation: That the NDIA’s ‘Rural and Remote Strategy’ and an ‘Aboriginal and Torres Strait

Islander Engagement Strategy’ be independently reviewed, with a report against progressed achieved

made available to the public.

5.0 Contact ESSA

Thank you for the opportunity to provide feedback in to Joint Standing Committee on the National

Disability Insurance Scheme’s Inquiry into NDIS Planning.

If you have any further questions regarding the content of this submission, please contact

i Tweedy, S. M., Beckman, E. M., Geraghty, T. J., Theisen, D., Perret, C., Harvey, L. A., & Vanlandewijck, Y. C. (2017). Exercise and sports science Australia (ESSA) position statement on exercise and spinal cord injury. Journal of Science and Medicine in Sport, 20(2), 108-115. ii Willis. C. (2018). Exercise and Paediatric Disability Case Study. Retrieved on 22 May, 2018 from http://activenation.org.au/wp-content/uploads/2018/03/case-study_Exercise-andpaediatric-disability_final.pdf3 iii National Disability Insurance Agency, COAG Disability Reform Council Quarterly Report 30 June 2019 [Internet]. [place unknown]: National Disability Insurance Agency; 2019 [cited 3 Sep 19]. Available from https://www.ndis.gov.au/about-us/publications/quarterly-reports . iv NDIS Quality and Safeguards Commission, NDIS Practice Standards Verification Module - Required documentation [Internet]. {place unknown}: NDIS Quality and Safeguards Commission, 2019 [cite 3 Sep 19]. Available from: https://www.ndiscommission.gov.au/sites/default/files/documents/2019-07/ndis-practice-standards-verification-module-required-documentation_0.pdf v Productivity Commission, National Disability Insurance Scheme (NDIS) Costs, Study Report [Internet]. [Canberra]: Productivity Commission; 2017 [cited 3 Sep 19]. Available from https://www.pc.gov.au/inquiries/completed/ndis-costs/report/ndis-costs.pdf vi Commonwealth of Australia, Joint Standing Committee on the National Disability Insurance Scheme. Provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition. [Internet]. [Canberra]: Commonwealth of Australia; 2017 [cited 03 Sep 19]. Available from https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/National_Disability_Insurance_Scheme/MentalHealth/Report . vii Commonwealth of Australia, Joint Standing Committee on the National Disability Insurance Scheme. Progress Report, March 2019. [Internet]. [Canberra]: Commonwealth of Australia; 2019 [cited 03 Sep 19]. Available from https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/National_Disability_Insurance_Scheme/General_NDIS/Report . viii Personal correspondence [email] from Exercise & Sports Science Australia (ESSA) member to ESSA Policy and Advocacy Officer, Anna Harrington. Dated 30 Aug 2019. ix Australian Bureau of Statistics. Social and economic wellbeing of Aboriginal and Torres Strait Islander people with disability [Internet]. [Canberra]. Australian Bureau of Statistics; 2017 [cited 3 Sep 19]. Available from https://www.abs.gov.au/ausstats/abs@.nsf/Lookup/by%20Subject/4714.0~2014 15~~Feature%20Article~~Social%20and%20economic%20wellbeing%20of%20Aboriginal%20and%20Torres%20Strait%20Islander%20people%20with%2 0disability%20(Feature%20Article)~10001. x National Disability Insurance Agency. NDIA Rural and Remote Strategy 2016-2019. [Internet]. [place unknown]: National Disability Insurance Agency; 2016 [cited 3 Sep 19]. Available from https://www.ndis.gov.au/about-us/strategies/rural-and-remote-strategy . xi National Disability Insurance Agency. NDIA Aboriginal and Torres Strait Islander Engagement Strategy. [Internet]. [place unknown]: National Disability Insurance Agency; 2017 [cited 3 Sep 19]. Available from https://www.ndis.gov.au/about-us/strategies/aboriginal-and-torres-strait-islander-strategy .