SUBMISSION: NDIS Planning
Inquiry by the Joint Standing Committee on the National Disability Insurance Scheme
About Identitywa
Identitywa is one of Western Australia’s leading agencies supporting people with disability and their families. We provide support to children and adults throughout the Perth metropolitan area.
We are an outreach of the Catholic Archdiocese of Perth and while our services are proudly based on Catholic values, our Vision encompasses people of all faiths and backgrounds. Our Vision is to build a community in which “All people live with a sense of purpose, a sense of belonging and a sense of wellbeing”.
Our Mission: Identitywa works in partnership with individuals and families to build a community where people with disability enjoy a fulfilled life. We support individuals to achieve their goals, whatever they may be. We offer families the support they need.
Our Values: Above all else, we make a commitment to act. We look for opportunities rather than seeing the barriers. Our approach is objective, transparent and fair. We’re honest and open, and no matter how challenging, we will see it through to the end.
For each individual and family this means we begin our relationship by asking, ‘What does a good life look like for you?’ We then work together to find the mix of right supports to help make this a reality.
To achieve this, we are continually finding new ways of adapting our support to suit people’s needs, goals and dreams as they change over time.
Response to the Terms of Reference
a. The Experience, Expertise and Qualifications of Planners;
- Variations to plans and funded supports It is our experience that plans vary widely in quality and accuracy depending on the NDIS Planners’ level of experience and knowledge. Our experience is such that our team no longer assume that an NDIS Planner understands the level of support required for any individual, even though it has been fully explained within a SIL Profile for example. In addition, many individuals we support with similar needs, wishes and circumstances will receive vastly different funded supports, even those living together.
Identitywa question the expertise of NDIA Planners. It is our experience that there is no consistency in understanding disability types and or the diagnosis of each participant. Furthermore, how a participant’s disability impacts on their daily life is not consistently
understood, and can quite often be dismissed, especially if the participant presents well at the meeting. Many individuals do present very well and may say that they are able to undertake any variety of tasks. It may be the case that they can, for instance do their own laundry with verbal prompting through every step, some hand over hand support to measure detergent, put their washing on the line and do their ironing with hand over hand support. All of this requires one to one active support to promote independence and yet has been challenged during planning meetings.
It is understandable and appropriate that NDIS Planners have a range of experience and backgrounds. Identitywa have come across some skilled Planners, many of whom have
moved on to other roles and organisations due to the perceived overwhelming
requirements of the planning role. This is disappointing as consistency in assessment is critical for participants.
Additional human resources. Identitywa favor models whereby dedicated teams are allocated to specific geographical areas. This includes experienced teams who have relationships with participants, families and service providers in their area.
b. The Ability of Planners to Understand and Address Complex Needs;
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Face to face planning meetings There is a less than acceptable number of Planners meeting with Participants face to face. Quotas imposed on NDIS Planners and short timeframes for turnaround result in a higher proportion of over the phone reviews, which lack the same level of richness and thoroughness. In Identitywa’s experience, plans undertaken via phone conversations are consistently weaker and hold more flaws and gaps than those where face-to-face meetings have occurred.
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We suggest that the first Planning meeting must be Face to Face and perhaps bi-annual thereafter, where there are no changes in support requirements. It is the Identitywa experience that most documentation information sent through the SIL and WASIL emails are not available for SIL Planner s and general Planners in time or do not appear in their system. This automatically puts them at a disadvantage having not read the rich information entailed in the SIL profiles and attached supporting documentation.
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This lack of access to critical documentation means the meeting is taken up with explaining what a person needs and why, rather than focusing on the goals and outcomes for their next plan.
• Where equipment is required, those Planners with less experience or expertise
sometimes struggle with recommendations from OT and PT reports, questioning the integrity of the information and assessments. Whilst it is important to be objective as a
Planner, it is rare that an independent Allied Health Professional will make an
assessment that is not reflective of the participants needs.
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Similarly, some Planners seem to struggle with understanding complex need and Positive Behavior Support plans. Some Planners have suggested that an individual doesn’t require any further additional funding based on a single meeting during which the person presents well. It has been the case with at least 3 participants supported by Identitywa recently, that continued PBS and support funding has been challenged in subsequent NDIS plans. The proposed reduction in funding for these individuals has contradicted the immense effort that has gone into providing the best support for those individuals to function well. Reduction in support and allied health interventions could have also resulted in reversion to previous heightened behavior or inability to respond effectively to emerging behaviors of concern.
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Some Planners appear to only read certain parts of an individuals Allied Health reports. One example of this in the past few months, was a Planner stated that an individual could ‘cook his own meals’ and was therefore independent in this regard. This was interpreted from a 1 hour OT assessment where the individual was observed (with prompting) to get a frozen meal out of the freezer, prompted to open the packet, assisted to set the time for cooking on the microwave, assisted to check it for heat, assisted to get it out of the microwave with prompting to use oven mits, and assisted to put the food on his plate. What wasn’t overtly stated in the OT report was that, without verbal
prompting and support, this person would not be able to undertake this task
independently. If Identitywa staff had not queried this, the individual would not have the level of support that he requires to live in a SIL supported accommodation.
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Diabetes, breathing apparatus and continence management are also areas that can be difficult for Planners to understand and appreciate within an individual’s plan, especially where the person presents well, but does require significant support. There has also
been an unfortunate amount of confusion with regard to whether the additional
assistance is required due to the person’s disability. It is hoped that this has now been clarified for all.
Recommendations
It is recommended that Planners have adequate time to fully read all documentation relating to individuals that is provided prior to planning meetings. This will assist them to appreciate the level of support required for an individual and to be able to ask probing questions.
c. The ongoing training and professional development of planners; There must be greater co-design principles engaged to ensure that participants, families and service providers can provide essential and valuable information to improve Planners / NDIA staff understanding.
d. the overall number of planners relative to the demand for plans;
- Backlog It is evident due to the slow rate of on time plan reviews and advanced planning meetings scheduled that Planners are under pressure and or unable to attend to the demands required to meet seamless plan reviews.
It has been Identitywa’s recent experience on 3 separate occasions that NDIS planners have contacted with less than a week before expiry of individuals plans to organize meetings with the individual, family and stakeholders (on one occasion it was with less than 15 hours’ notice and could not be attended by any parties. This led to plan extensions for 3 individuals in the house). On each of these occasions it has been impossible to organize suitable times, hence, plans have been extended for 3 months, causing additional administrative burden for both NDIS and organisations and families, through having to create Service Agreement addendums, and new service bookings for short periods of time, knowing that it will occur again in another 3 months.
In addition, the timeline to resolve complaints, light touch reviews or Plan reviews (Section 100) is over six months.
In one case, a high priority Change of Circumstances was submitted to NDIS in January 2019 and was not actioned until the participant ended up in hospital as a result of the change in her support needs.
It would seem that unachievable work load impacts on and results in the higher than anticipated number of plan extensions.
Recommendations
The number of NDIS Planners to be increased relative to the number of plans that are funded.
NDIS Planners to be allocated to plan reviews as soon as practicable and participants and support organisations informed in a timely and respectful manner.
That documentation from Support organisations is better logged and saved within the NDIS document management system. It has been Identitywa’s experience with SIL in
the past 6 months, that NDIS Planners and families have been informed that
documentation has not been sent in a timely manner or is yet to be received at all by NDIS. This is untrue and reflects the poor recording and management of information by NDIS. This has occurred many times and providers unfairly are blamed for the NDIS inadequacies and yet no apology or rectifying error message has ever been forthcoming.
e. participant involvement in planning processes and the efficacy of introducing draft plans;
- There is a lack of face to face meetings or participant involvement can be minimal, particularly given the above experiences of a lack of advance notice and NDIS Planners not appearing to have enough time to even open the documentation that has been provided;
Participants are regularly excluded from a face to face planning review meeting.
- Participant’s right and ability to review a draft plan Participants and their Decision makers and/or service providers should have the opportunity to review and proof read their plan. This would eliminate small, simple mistakes including errors with information, typos and general mistakes. Additionally, if participants were afforded the opportunity to review their draft plan, we would see a reduction in disputes, complaints and request to reconsider.
Examples of this have been where an NDIS Planner has reviewed 5 housemates and:
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Provided continence package for an individual who did not require it;
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Did not provide a continence package for someone who has had continence requirements for many years (and has had this in their NDIS plan);
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Did not include an individual’s specialist nursing support for in-dwelling catheter care.
If there were drafts of these plans, feedback could have been provided immediately to prevent the backlog of waiting time for changes to be made. We are not seeking to influence reasonable and necessary, we are seeking to support a more seamless support system for participants and a fair workload for Identitywa staff.
Another recent example has involved individuals having new plans that have not updated the section about them – Participants Profile. New plans have had information ‘copied and pasted’, we have had one experience where a departed family member of a
participant was included in their new plan. This happened despite updates and
information being shared at the review meeting.
Recommendations
It is suggested that individuals, their decision-makers and support organisations are provided with an opportunity (perhaps 7 working days) to review provide factual feedback on draft plans prior to them being made active. This would reduce additional hold-ups, plan disputes and complaints
f. the incidence, severity and impact of plan gaps; Where plan gaps exist, this represents a direct loss of income to service providers. It is our experience that recovering funding for hours delivered when there is a discrepancy between plan start and end dates is near to impossible.
The amount of additional time to follow up, find out who to speak with and continue to do this across multiple plans and to no avail, is currently burdensome and unacceptable. NDIA say to families that where there are plan gaps, they can still access services from their providers. Families relay this information to providers, who also know this to be the case theoretically. The reality for providers however, is that recouping these funds for services provided between gaps in plans is not easy, highly administratively burdensome and with risk as the payment for hours delivered is significantly delayed or not forthcoming. This is not best practice and directly impact both the participant and the service provider.
Their must be a simple process for recouping funds which is timely, transparent and has a dedicated NDIA staff member.
Identitywa endorse a model whereby a dedicated team of NDIA staff are allocated to geographical areas and service providers.
g. the reassessment process, including the incidence and impact of funding changes;
- Change of Circumstance (CoC) This process is currently lengthy and - in several experiences for Identitywa – costly, as errors made by Planners or inefficiencies within their systems have a direct effect on our organisation and our ability to deliver quality supports and claim for supports.
An example, in January 2019 Identitywa submitted a CoC, it was ‘lost / misplaced’ in the NDIS system and required numerous follow ups by Identitywa. Each time, a different reason was given for the delay. The individual was subsequently admitted to hospital for 5 weeks as Identitywa could no longer provided the extensive amount of support required due to the CoC. Additional funding was eventually approved in July 2019. Unfortunately, due to a gap in plan dates there is now approximately $30,000.00 in SIL funding owing to us. This was identified immediately by the Planner and an email was sent to Provider Payments on 16th July 2019. There has been no further action since then.
An immediate review of the change in circumstance process is required and a time frame allocated for approval.
h. the review process and means to streamline it;
- Plan review dates Where no changes exist, the plan could automatically be extended for a further twelve months. If this was to be implemented, then the process and efficiency of the Change of Circumstance application would benefit.
i. the incidence of appeals to the AAT and possible measures to reduce the number; No comment.
j. the circumstances in which plans could be automatically rolled-over;
- Automatic roll over of funded supports / plan There are a number of items which unless a change of circumstance occurs an automatic roll over should exist. Where participants are attending higher education – e.g. TAFE, SIL – where no changes exist
k. the circumstances in which longer plans could be introduced; Where no changes in circumstance are foreseeable then this would be possible. For participants who have training and or education in their plan e.g. TAFE courses the graduating date is typically greater then 12 months in some instances, then this would lend to a longer plan end date.
l. the adequacy of the planning process for rural and regional participants; and No comment.
m. any other related matters. No comment.
Identitywa’s Contact Details
Phone: (08) 9474 3303 Fax: (08) 9474 3315 Email: admin@identitywa.com.au