Joint Standing Committee on NDIS – NDIS Planning
6/9/2019 Submission – Kyabra Community Association Inc.
a. the experience, expertise and qualifications of planners; Lack of understanding about disability, for example participants with multiple diagnoses and how this can impact on their support needs. Poor communication with Participants about how they can use their funding. For example, a participant stated they were told they could no longer receive Speech Therapy. When the planner was asked by the Support Coordinator about this, they stated that they told the participant if they didn’t find the therapy helpful, they should stop it. The participant did find the therapy helpful so was able to continue but without the clarification provided by the Support Coordinator, this therapy likely would have stopped. This same participant was directed by the planner to receive assistance from support coordinator to implement the plan, however this funding was not allocated in the new plan. Request for Service referencing another participant’s situation or support needs.
b. the ability of planners to understand and address complex needs; Reference to primary diagnosis and age of the participant as a guiding tool in what level of funding they will be allocated or style of support they should receive. For example, a participant was told that due to his age and primary diagnosis, he should be engaged in 1:3 ratio group support rather than the 1:1 support that was being requested. This did not take into consideration the additional diagnoses the participant was living with (anxiety) and the plan of a slow transition from 1:1 support to a 1:3 group ratio.
c. the ongoing training and professional development of planners; Plans received with multiple errors, including participant request for a specific style of plan management not being included or needed items missing from Capital Supports – Assistive Technology section.
d. the overall number of planners relative to the demand for plans; Considerable delays when trying to organise a scheduled plan review Lack of planner preparation prior to the scheduled plan review meeting. For example, planners often appear to have not read the submitter reports prior to the meeting and do not have a basic understanding of the participant’s situation. Difficulty contacting planners following plan review meeting or following activation of plan to discuss any concerns. The phones at some of local offices in our area are not answered and there is a recorded message to email the office but the emails are also unanswered.
e. participant involvement in planning processes and the efficacy of introducing draft plans; In situations where a participant requires a plan nominee to assist in decision making due to lack of capacity, this nominee is often not informed of a plan review meeting date. The participant’s support coordinator is also not often
informed. For example, in one case, the participant was under the Office of the Public Guardian and their Guardian was not informed of a review meeting date. The planner presented at the home of the participant (SIL Arrangement) but without the OPG involved or Support Coordinator present to inform on the implementation of the last plan, the meeting could not go ahead. This meant that the review meeting had to be rescheduled, causing unnecessary delays in the planning process as well as a waste of the planner’s time. Draft plans would greatly increase the efficacy of the planning process as it would give the participant, their informal supports and the support coordinator the opportunity to provide feedback on any errors. This will reduce the need for a review of the plan and new plans being produced. For example, a participant supported by Kyabra required a new plan a week after a plan had been activated due to several items being missed. This could have been avoided if a draft plan format had been used in the first instance. Inadequate notification being provided of new plan activation. Participants are not called when a new plan is activated and where there is no portal access, they do not have access to their full plan until it is posted to their address which can take weeks
f. the incidence, severity and impact of plan gaps; Plan gaps cause significant issues for service providers due to periods being not covered by a current service agreement and booking, and the associated billing issues. The Gap in Plans process has helped to an extent, however this is only possible if the participant has funding remaining from their previous plan. Even if the participant does have funds, the plan has an uncertain end date which means a new plan may be activated before services have recouped payment for the previous period and the previous period is consequently pro-rated leaving insufficient funds for the provided services. Interim plans being allocated contain inadequate funding for reasonable and necessary supports and pose the same issues stated in the first point regarding billing issues and pro-rated funding once the new plan is activated. The system of pro-rating funding following the end of plans, is in conflict with the understanding that support coordination is not provided on a “per month” or “per week” consistent basis but tends to be used more in the early stages of a plan during implementation.
g. the reassessment process, including the incidence and impact of funding changes; Lack of reasonable notice given to participants, nominees and support coordinators regarding additional evidence that may be needed to ensure ongoing level of funding. For example, a participant was asked in a planning meeting to provide proof of diagnosis as he had entered the scheme as a defined participant but there wasn’t sufficient evidence. Assisting the participant to get an appointment with their GP to receive this documentation and then share it with the NDIA was a time consuming process which could’ve been streamlined had the participant been informed earlier of the need for additional documentation in this area Planners have been unwilling to discuss reductions in funding directly with the participant and their nominee/s. For example, we have had 2 occasions where the planner shared the new plan and discussed funding reductions with the support coordinator and requested they pass this information on to the participant
and their nominee/s. The participant and their supports have then been unable to contact the planner for clarification regarding these changes.
h. the review process and means to streamline it; Requests for unscheduled plan reviews due to Change in Circumstances or a Review of a Reviewable Decision are frequently not responded to, and require ongoing follow up often via the National NDIS phone line to escalate the request, due to lack of response at local office level. We have had many participants wait months for a response to their requests, with some still waiting. This has left many participants with insufficient funding available in their current plans for their reasonable and necessary supports
i. the incidence of appeals to the AAT and possible measures to reduce the number;
j. the circumstances in which plans could be automatically rolled-over; Strong communication with the participant, nominees and support coordinator could identify situations where the plan could be automatically rolled-over.
k. the circumstances in which longer plans could be introduced; A draft plan procedure would increase the likelihood of participants being comfortable with a longer plan. Tighter timeframes around the review process would also assist with this.
l. the adequacy of the planning process for rural and regional participants; and
m. any other related matters. It would be helpful to include a discussion of whether a plan nominee will be appointed in the initial planning meeting and ensure that this is assessed at each subsequent planning meeting and re-appointed as needed. There are participants who require this assistance and have informal supports able to help them. However, if they are not formal nominees, they cannot speak to the NDIA about the plan or sign service agreements. Many informal supports believe they are nominees as the process has not been clearly explained to them. The process of becoming a nominee outside of the planning meeting, involves another visit to their local NDIA or LAC office, where parking is often an issue. For some informal supports, this is a very challenging process. Delays may mean that the Participant misses out on reasonable and necessary supports as a result.