PHYSIOTHERAPY
ASSOCIATION
Response to the Joint Standing Committee on the NDIS Inquiry into the NDIS Quality and Safeguards
Commission
Response by the
Australian Physiotherapy Association
August 2020
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PHYSIOTHERAPY
ASSOCIATION
Table of Contents
Introduction ……………………………………………………………………………………….. 3
Summary of Recommendations ……………………………………………………………… 4
NDIS administrative requirements and processes …………………………………………………….. 5
Excessive administrative burden and lack of guidance ………………………………………………. 5
Lack of support for smaller providers and providers in thin markets ………………………….. 5
Communication and responsiveness to NDIS providers ……………………………………………… 6
Lack of accessible and timely information………………………………………………………………… 6
Lack of responsiveness, guidance and transparency around decision making …………….. 7
Conclusion ………………………………………………………………………………………….. 8
Australian Physiotherapy Association ………………………………………………………. 8
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Introduction
The Australian Physiotherapy Association (APA) welcomes this opportunity to make a submission to the Joint Standing Committee on the National Disability Insurance Scheme (NDIS), as part of the inquiry into the NDIS Quality and Safeguards Commission (the Commission), on behalf of the physiotherapy profession.
Our profession, at both the level of individual physiotherapists, and collectively, is focused on maximising value in disability – on achieving the best health and related outcomes at the lowest cost whilst maintaining quality of care. Physiotherapy can bring value to the lives of people with disability, however some of the processes and structures of the current system make that difficult to achieve.
The APA are concerned about the administrative burden associated with the provider registration and ongoing auditing processes. This creates significant fiscal and opportunity costs, in particular for smaller providers, and providers in geographically regional, rural and remote locations. This results in some physiotherapy providers choosing not to register with the NDIS, which has considerable impact on the availability and variety of physiotherapists to NDIS participants in their local communities. The APA recommends the Commission set pricing standards for auditors based on a tiered NDIS provider sizing model, and supplement some of the auditor costs incurred by smaller providers.
The APA are committed to improving the quality of care provided to people living with disability in Australia. We support the intent and focus of the Commissions’ role to ensure provider quality and safety for NDIS participants. We believe disability workers need to be adequately regulated. We want to see increased resourcing to the Commission to extend its capacity to undertake its originally intended function as a quality and safeguarding authority.
The APA also recommends enhanced information sharing by the Commission, as well as increased responsive and timely communication by the Commission regarding information requests, advice and regulatory processes involving NDIS providers. We also want to see the establishment of regional or local provider engagement and liaison representatives, to improve information sharing, responsiveness and provide clarity to NDIS providers.
We would be happy to meet with the Standing Committee on the NDIS on behalf of the physiotherapy profession and have provided a summary of our recommendations in our submission.
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Summary of Recommendations
Recommendation 1 That the Commission develop resources and templates to support smaller providers with the registration and auditing process, including specific resources and education for allied health professionals outlining key processes, best practices examples and detailed guidance to meet the auditing standards.
Recommendation 2 The Commission set pricing standards for auditors based on a tiered NDIS provider sizing model, and supplement some of the auditor costs incurred by smaller providers to ensure they are able to provide a service.
Recommendation 3 Increase resourcing to the Commission to extend their capacity to undertake their intended function as a quality and safeguarding authority, including their original functions relating to assessment and approval of quality auditors and the assessments they conduct.
Recommendation 4 The Commission collate and streamline their communication materials and use simple and sequential messaging to alert providers of changes to standards and regulatory requirements.
Recommendation 5 Establish regional or local provider engagement and liaison representatives, similar to the Provider Relations roles within the NDIA, to improve information sharing and provide clarity and advice, including on roles and responsibilities to NDIS providers.
Recommendation 6 The Commission should regularly meet and consult with the allied health sector and key allied health bodies.
Recommendation 7 The Commission establish and publish specific KPI’s related to NDIS provider responsiveness, including the length of time taken to: acknowledge a received request acknowledge a received provider registration application process a registration application respond to a reported incident respond to general enquiries or requests for information
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PHYSIOTHERAPY
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NDIS administrative requirements and processes
Excessive administrative burden and lack of guidance
The APA supports the need for regulation and registration of disability workers to ensure that safe physiotherapy is delivered to participants, in particular for those who are currently not regulated
through AHPRA or their own professional association or standards. AHPRA registered
physiotherapists working within the NDIS funding scheme already undergo significant additional provider registration requirements and ongoing regulatory requirements. AHPRA professions also have well established frameworks for both practice and ethical decision making in a wide range of situations.
Providing physiotherapy to people with disabilities can be challenging and time consuming. Given the complexities and variability of the caseload, the nature of providing work in the disability sector involves a consistently high caseload with significant work between allocated sessions. There is also often administrative work required outside of designated appointment times.
Our members have raised both the costly and time intensive registration and auditing requirements that create significant fiscal and opportunity costs. They have consistently told us that the current provider registration process, and ongoing multi-stage auditing processes are also overly complex and lengthy. This includes the extensive provider certification process, which creates multiple barriers for providers wanting to register, in particular smaller providers that have less resources and fewer administrative mechanisms and established policies and procedures.
Many of our members who are current NDIS providers have reported that the current auditing process is extremely time intensive. This is further increased by the additional State and Territory, and other National requirements that providers need undertake and or maintain:
“[There] seems to be too many layers of overlap between State and Federal including [regulatory requirements regarding] Working with Children Checks, [requirements for providers under the] Disability Worker Exclusion Scheme, national AHPRA registration, national police checks, National Quality and Safeguard Commission.” - APA member.
The Commission is also disproportionately focused on the registration aspects of its role and is not adequately focused on its broader, and originally intended function as a quality and safeguarding authority. This results in a lack of adequate resourcing, and capacity for the Commission to focus on, and offer appropriate and relevant information to providers on a range of regulatory aspects as needed. Our members have described a general lack of clear and accessible guidance and resources, with existing policies and operational requirements often being unclear and difficult to understand. This is further complicated by the continued and ongoing changes to policies and requirements which are difficult to keep track of, understand and adhere to.
Lack of support for smaller providers and providers in thin markets
APA members have raised the costly and time intensive registration and auditing requirements that create significant fiscal and opportunity costs, including the excessive costs and charges by auditors.
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The cost and resourcing burden is further emphasised for both smaller providers, and providers in
geographically regional, rural or remote locations. This often results in smaller providers
being unable to compete with larger providers and cost effectively register and offer services through the NDIS. In addition there are minimal supports and guidance for smaller providers to navigate and complete the provider registration process:
“The [NDIS audit] process for a small organisation is arduous and exceptionally expensive.” - APA member.
The overall increased costs to a practitioner working in the disability sector, coupled with a lack of guidance and responsiveness by the Commission to providers, creates uncertainly and unease amongst providers. This leads to some opting to not provide services under the NDIS, and results in a lack of diversity and availability of service providers. This also effectively reduces choice and control for NDIS participants, a key principle that underpins the purpose and intent of the NDIS.
Recommendation 1 That the Commission develop resources and templates to support smaller providers with the registration and auditing process, including specific resources and education for allied health professionals outlining key processes, best practices examples and detailed guidance to meet the auditing standards.
Recommendation 2 The Commission set pricing standards for auditors based on a tiered NDIS provider sizing model, and supplement some of the auditor costs incurred by smaller providers to ensure they are able to provide a service.
Recommendation 3 Increase resourcing to the Commission to extend their capacity to undertake their intended function as a quality and safeguarding authority, including their original functions relating to assessment and approval of quality auditors and the assessments they conduct.
Communication and responsiveness to NDIS providers
Lack of accessible and timely information
APA members have noted information is difficult and time consuming to obtain or locate, and risks important information being missed. In addition, ongoing changes and updates to the website and
information mean it is very difficult to keep track of new information and reforms.
The APA encourages enhanced consultation and engagement with the allied health sector, in particular with peak bodies, to ensure improved information sharing between the Commission,
allied health peak bodies and other regulatory bodies. In addition, greater localised
information sharing at State and Territory and regional levels is required. This should be done using a direct contact point for providers to support more responsive information sharing, including to clarify and contextualise information relevant to them.
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Lack of responsiveness, guidance and transparency around decision making
At present there is no mechanism or capacity to ensure timeliness from the Commission on behalf of providers. This is a particular problem when providers require a timely response to requests, as well as more generally, to ensure providers are appropriately updated and informed when they submit information or engage with the Commission. Currently, when an APA provider submits information to the Commission as part of the auditing process, or requests guidance or advice from the Commission, this is addressed in an ad hoc manner with no guarantee of a timely response. The APA recommends a formal approach to the response and decision-making processes by the Commission, including urgent requests for guidance or information by providers.
Recommendation 4 The Commission collate and streamline their communication materials and use simple and sequential messaging to alert providers of changes to standards and regulatory requirements.
Recommendation 5 Establish regional or local provider engagement and liaison representatives, similar to the Provider Relations roles within the NDIA, to improve information sharing and provide clarity and advice, including on roles and responsibilities to NDIS providers.
Recommendation 6 The Commission regularly meet and consult with the allied health sector and key allied health bodies.
Recommendation 7 The Commission establish and publish specific KPI’s related to NDIS provider responsiveness, including the length of time taken to: acknowledge a received request acknowledge a received provider registration application process a registration application respond to a reported incident respond to general enquiries or requests for information
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PHYSIOTHERAPY
ASSOCIATION
Conclusion
The APA is committed to improving the quality of care provided to people living with disability in Australia. Physiotherapists are vital to enhance the quality of life of NDIS participants and to empower them with the skills and tools to continue to raise their participation and function.
We believe that the NDIS Quality and Safeguards Commission is essential to ensuring high quality
care is provided to the disability sector and offer our recommendations as improvement
opportunities to strengthen the impact of the Commission.
We would welcome the opportunity to further contribute to any reforms that emerge.
Australian Physiotherapy Association
The APA vision is that all Australians will have access to quality physiotherapy, when and where required, to optimise health and wellbeing.
The APA is the peak body representing the interests of Australian physiotherapists and their patients. It is a national organisation with state and territory branches and specialty subgroups. The APA represents more than 28,000 members who conduct more than 23 million consultations each year.
The APA corporate structure is one of a company limited by guarantee. The APA is governed by a Board of Directors elected by representatives of all stakeholder groups within the Association.
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