Joint Standing Committee on the National Disability Insurance Scheme
Senate Inquiry: Planning
Date: 6 September, 2019
Sent by email to: ndis.sen@aph.gov.au seniorclerk.committees.sen@aph.gov.au
Submitted by: Brightwater Care Group
Level 3, 355 Scarborough Beach Road
Osborne Park 6017 Western Australia
Introduction
Brightwater Care Group is a non-profit organisation that supports people to live a better quality of life, with the mission of ‘pursuing the dignity of independence’. Our services are extensive, from short and long-term residential accommodation and rehabilitation services to capacity building and assistance in the home, and include specialist skills in supporting people living with Dementia, Acquired Brain Injury and Huntington’s Disease. Our expertise is providing high quality care in a strong and flexible framework that embraces changes in funding models and paradigm shifts in consumer-directed care, and values investment in dynamic relationships across multiple care sectors including health, primary care, mental health, and disability. The Supported Independent Living (SIL) service maintains a focus on helping people to remain active and engaged within their home and community. Navigating transition to the NDIS has presented this cohort with opportunities to broaden perspectives on service delivery models and integration with providers including health, mental health, housing, and community services.
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In regard to the committee’s inquiry into the implementation, performance and governance of the National Disability Insurance Scheme (NDIS) in regard to Planning, we submit to you our experience and recommendations as a large Capacity Building and SIL provider in Western Australia.
a) the experience, expertise and qualifications of planners Challenge: The experience, expertise and qualifications of planners vary significantly, which impacts the quality of the NDIS plan and supports provided. There is a great reliance on participants and their family to navigate the NDIS and advocate their needs. This is all very well for people with independent decision making capacity and support but it is not a very functional environment for clients without capacity and/or support.
Example: Participants are not informed about key supports that can assist with using the plan and navigating services i.e. Support Coordination. This results in participants not being able to functionally use plans, as they are not clear on how to navigate and utilise services.
b) the ability of planners to understand and address complex needs Challenge: There appears to be a limited number of NDIS planners who have the ability to understand and address complex needs. Our interactions with planners reveal that most have limited understanding of how service systems interface and can work with each other to support the needs of the participant. It is not clear what training and professional development is provided to planners.
Anecdotally, one client who has complex support needs was told by an NDIA planner that they were ‘too complex’ for the NDIS. This is very distressing for all concerned.
Opportunity: Ongoing training and retention of planners is crucial. Retention of corporate knowledge and experience, translated into mentorship and succession planning, will yield opportunities for better service delivery.
Challenge: The NDIS escalation pathway for people with complex and/or critical needs is not defined and this lack of clarity causes delays to achieving meaningful plans and supports.
Opportunity: Development of a clear escalation pathway, and upskilling of planners to
understand the logistics of the pathway, will provide clarity and facilitate better planning for participants with complex needs.
Challenge: We experience inconsistency of knowledge and understanding from planners in regard to consent and authority to discuss plan information on behalf of the client.
Example: There is a heavy reliance on Service Providers to facilitate the NDIS process, especially for people who do not have independent decision making capacity and/or family support. NDIA repeatedly requests, but does not appear to maintain, records of a participant/decision maker’s consent for the service provider or family members to communicate on their behalf. The process of having to repeatedly affirm consent is very frustrating for all involved, particularly for clients with significant expressive communication difficulties. This is an unnecessary burden leading to further delays and negative perception of the NDIA system functionality.
Opportunity: NDIA records of consent, decision making, and authority to discuss plan
information should be maintained and readily available at all times within a participant’s account
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details. Planners should be knowledgeable about this process, work collaboratively with
participant representatives in a progress oriented manner, and act to minimize duplication of form requests.
c) the ongoing training and professional development of planners As discussed in item b).
d) the overall number of planners relative to the demand for plans Challenge: In Western Australia, the low number of NDIA planners has significantly delayed the roll out of the scheme, the development of plans, and plan reviews. It would seem there are inadequate numbers of planners and they are ill equipped (trained, systems, etc.) to develop the volume of plans that are required to support individuals waiting to transition to the NDIS. Consequently, participants experience significant delays to access needed services.
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Planning meetings are often held 6 months or more after an Access Request is granted. After the planning meeting, the process to get the final plan approved also can take several months.
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Defined clients (those who are known to have an eligible disability) who are receiving state funded services from an NDIS registered provider are waiting more than 14 months to start the plan development process, and communication with NDIA planners is intermittent at best.
Examples:
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One participant in our care became eligible by roll out date in April 2018. No planning meeting was scheduled despite numerous phones call to NDIA to raise the issue. The participant was contacted by an NDIS Partner in the Community (LAC) in July 2019. The LAC did not review the participant information carefully prior to calling. The LAC realised that the person needed complex supports and withdrew assistance and sent the participant file back to NDIA. On behalf of the participant, the service provider contacted an NDIA booking officer who responded by email. When they responded, the participant was in hospital so they wanted to wait until he came out of hospital. The last email from the NDIA said emails will be forwarded to the executive director; however, as at 6 September 2019 the participant has received no further contact from NDIA.
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Another participant in our care completed an Access Request in November 2018 to which there was no decision. Our service followed up on behalf of the participant and was informed that the NDIA lost their forms. In January 2019 the NDIA asked for the forms to be re-submitted. The documents were re-sent, and one of the attachments was reportedly interpreted as a ‘virus’, and so the message was rejected by the NDIA firewall. The participant’s access was finally approved in February 2019. As at 6 September, 2019, no planner has contacted the participant for a planning meeting despite significant advocacy by the SIL provider on behalf of the participant.
Opportunity:
- Western Australia requires a significant increase in the number of knowledgeable, skilled planners. All planners require ongoing training and development, with particular
attention to complex care pathways and support.
• The cohort of defined individuals living in supported accommodation in Western
Australia is distinct and known to NDIA. These individuals have confirmed eligibility and are supported by service providers who can contribute to the planning process in a way that meets the individualised needs of the participant and his/her decision makers. It is
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essential that the NDIA addresses, as a top priority, the backlog of participants waiting for initial NDIS plans.
e) participant involvement in planning processes and the efficacy of introducing draft plans Challenge: Draft plans are very useful to ensure that the participant needs will be met by the plan, and given that the plan is intended to be by and for the participant, they have a right to see the plan before it is finalized. The process of adding another step in the plan development process creates further delays to achieve approval and implementation.
Example: A participant’s needs were not captured accurately by the NDIA planner, resulting in a plan that did not include all relevant supports. The participant/representative queried the omission with the NDIA planner. The planner refused to update the plan, citing the change as a changed need, not an administration error. The participant must then choose whether to proceed with a changed needs request that involves more meetings, documentation, time and uncertainty, or proceeding with utilizing a plan that does not include all of their necessary supports.
Opportunity: The introduction of a draft plan for each participant will provide an opportunity to check information prior to planning approval, and optimize the opportunity for improved outcomes for the participant. This will need to be supported by clear guidelines for NDIA planners, as current practice is to view any change as a plan review. This must also have clear timeframes for communication and data management strategies in place to minimize delays associated with correspondence and loss of documents in the NDIA database.
f) the incidence, severity and impact of plan gaps Challenge: Plan gaps can emerge as a result of the person/agency responsible for managing the plan and communication between the relevant parties.
• Many participants with complex care needs have appointed decision makers for
different aspects of daily living, with widely variable levels of engagement with the client, family and service providers. There is heavy reliance on current service providers to intensively support preparation for the planning process including engagement and upskilling of the participant, family, and other decision makers in the participant’s life.
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Even for clients who are their own decision makers and/or who have highly engaged family or guardians, coordination of communication between service providers and the NDIA can be a very challenging, and highly dependent on the skill and knowledge of the planner.
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Plan gaps may be created by the by the protracted process for participants to access specialized equipment of a newly acquired disability.
Example: NDIA planners may initiate contact with a participant over the phone. On initial contact they do not have a developed understanding of the individual’s capacity to provide informed consent. One participant was contacted by an NDIA planner and asked if she would like to self-manage her plan. This participant is able to hold conversations, but does not have the capacity to manage her own finances. Because the consent was obtained, the plan was then created on the premise that she could fulfil the requirements of self-managing a plan. The service provider, from whom she had been receiving state funded services, found themselves in the dilemma of whether to continue delivering services for an NDIS eligible client who cannot manage her funds. There is currently no escalation process for the service provider to advocate for payment. Proceeding with communication through NDIA Provider Payments is associated
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with response times of many months. If the provider ceases services, then the participant is without necessary supports.
Opportunity:
• It should be a fundamental expectation that representatives of the NDIA are
knowledgeable, communicate effectively, and consistently act in the primary interest of participant goals and outcomes.
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We recommend that plans for complex clients include funding for interagency multi- disciplinary time to work jointly on goals and empower more collaborative interactions.
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Support Coordination and access to resources such as NDIS Partners in the Community should be included in all plans for SIL participants, and recognized as a continuous requirement for dynamic management of complex support.
g) the reassessment process, including the incidence and impact of funding changes No comment
h) the review process and means to streamline it Challenge: The review process is long and delayed, which has resulted in some participants not receiving support. It is not uncommon for a scheduled plan review to occur prior to a ‘change need’ review. Further clarity is required to develop the review process to meet participants’ changes in need, including greater clarity around the process.
Opportunity:
- Participants should be notified of the predicted timeframe for processing applications.
- Increase planner numbers or introduce a plan review role. This could be a specialist position which may require a different qualification due to the nature of a review. It would need to be supported by specialist planners to some other escalation process if at review there is significance difference.
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 For people with stable impairment and relatively less complex support needs, two or three year plans would make good sense. This is probably best to apply after their initial NDIS plan to ensure that the range of supports has been tested for relevance and suitability.
k) the circumstances in which longer plans could be introduced For people with stable impairment and relatively less complex support needs, two or three year plans would make good sense. This is probably best to apply after their initial NDIS plan to ensure that the range of supports has been tested for relevance and suitability.
l) the adequacy of the planning process for rural and regional participants No comment
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