New Zealand
College of
Psychiatrists
31 July 2020 •
Committee Secretary
Joint Standing Committee on the National Disability Insurance Scheme
By email to: ndis.sen@aph.gov.au
Dear Committee Secretary
Re: Submission to the inquiry into the NDIS Quality and Safeguards Commission
The Royal Australian and New Zealand College of Psychiatrists (RANZCP) welcomes the opportunity to provide input into the inquiry into the National Disability Insurance Scheme Quality and Safeguards Commission (the NDIS Commission) by the Joint Standing Committee on the National Disability Insurance Scheme.
The RANZCP is the principal organisation representing the medical specialty of psychiatry in Australia and New Zealand and is responsible for training, educating and representing psychiatrists on policy issues. The RANZCP has more than 6900 members and is guided on policy matters by a range of expert committees including the Section of Psychiatry of Intellectual and Developmental Disabilities.
The RANZCP appreciates the important work undertaken by the NDIS Commission in helping to provide protection and safety to NDIS participants against abuse and neglect. However, there remain opportunities for improvement regarding behaviour support processes for people with disability within the National Disability Insurance Scheme (NDIS).
The RANZCP has identified that there are concerns around the operationalisation of behaviour support processes for all NDIS participants but particularly for people with Autism Spectrum Disorder (ASD) and people with intellectual and developmental disability (IDD). This includes the listing of certain medications as ‘restrictive’, within the NDIS for people with ASD.
Psychiatrists play a key role in providing diagnosis and treatment of people with mental health conditions and have been questioned over prescriptions by service providers where participants are assisted to take their medication. Service providers have advised that this is due to National Disability Insurance Agency (NDIA) requirements. They advise that these requirements set out that service providers must seek formal documentation regarding the purpose of a prescription which requires the completion of extensive documents where medications are listed by the NDIA as ‘restrictive’. In some cases, psychiatrists have noted concerns that due to this requirement some NDIS participants may not receive their medication due to issues with NDIS paperwork. This list of ‘restrictive’ medication is not available publicly nor is it clear on what basis and through whose input this list was formed.
The RANZCP would also highlight that the NDIS Commission has stated that ASD has been classified as ‘untreatable’ even though clinicians treat the symptoms and features of ASD as part of their clinical practice. The RANZCP has strong concerns that ASD has been classified
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New Zealand
College of
Psychiatrists
as ‘untreatable’ by the NDIA and believe this is an unacceptable position. The RANZCP •urges that there be dialogue with medical professionals, such as psychiatrists, to ensure decisions are made on current medical practice and research. In addition, as this is a health related issue and not related to an area of NDIA expertise, the RANZCP would appreciate clarification regarding how ‘restrictive’ medication information is utilised by the NDIA. This is particularly relevant as providing the information required by the NDIA, regarding the purpose of the medication, impacts on psychiatrist’s resources with the potential to cause issues for patients in cases where medication is delayed or ceased.
The RANZCP identifies that the disconnect between the health and disability sectors must be urgently addressed in order to provide better support and health outcomes for people with disability. For example, the NDIA and NDIS Commission have been set up as completely separate entities to other organisations and sectors, including the health sector. Optimal health and wellbeing are key components of improving outcomes of NDIS participants. The disability sector is the ‘gatekeeper’ to positive outcomes for people with disability and should not work in isolation to enable people with disability to achieve their goals. As such, the RANZCP would recommend a cross-sectional framework comprising of relevant government bodies and agencies, which would encourage sectors to work together on how they might better support people with disability in the NDIS.
The RANZCP proposes that to better preserve the rights of people with disability, it would more appropriate if behaviour supports were treated and managed in partnership with the mental health system. Currently there is a ‘parallel’ mental health system for people with disability with behaviour supports having different criteria for restrictive practice such as involuntary detention and treatment, different review processes, different staffing profiles and facilities.
The RANZCP fully supports protection of people with disability from adverse treatment and practice. However, we do hold concerns as to the impact this has on people with disability, their families and carers as it affects the ability of people to receive treatment for mental health conditions. Given the importance of this issue, it is important that a range of stakeholders have input into operationalisation of the NDIS to ensure a holistic view is presented. As such, the RANZCP would welcome the opportunity to provide further information on the issues raised in this letter. In addition, we would appreciate the opportunity to engage with the NDIS Commission in relation to improving how the mental health and disability sectors may better support the rights and safety of people with disability.
To discuss any of the issues raised in this letter, please contact Rosie Forster, Executive Manager, Practice, Policy and Partnerships Department via r or by phone on (
Yours sincerely