Neurodevelopmental and Behavioural
Paediatric Society of Australasia
18 November 2020
Committee Secretary
Joint Standing Committee on the National Disability Insurance Scheme
By email: ndis.sen@aph.gov.au
Dear Committee Secretary
Re: Submission to the Inquiry into the NDIS Quality and Safeguards Commission
Thank you for the opportunity to provide a submission to the Inquiry into the NDIS Quality and Safeguards Commission (NDIS QSC), in particular on Term of Reference (a) relating to the role of the Commission in monitoring and reporting on restrictive practices. We support the Convention on the Rights of Persons with Disabilities, which recognises the potential for inappropriate prescribing of medications for the purpose of chemical restraint. In our support for the role of the NDIS QSC in this area, we wish to bring to your attention a number of considerations applying to the care of neurodiverse children. The Neurodevelopmental and Behavioural Paediatric Society of Australasia (NBPSA) is a membership organisation for doctors, including paediatricians, general practitioners and child psychiatrists, who have a specialist interest in working with neurodiverse children, their families and carers. The majority of Society members are paediatricians who care for children and adolescents, including those with intellectual disability and Autism Spectrum Disorder, as well as those with other developmental conditions. Paediatricians are responsible for the diagnosis and management of the majority of neurodiverse children in Australia. The current approach to the regulation of restrictive practices in the disability sector captures a wide range of psychotropic medications within the concept of chemical restraint. For example, any child on this type of medication without a formal mental health diagnosis triggers a review by NDIS providers. This then requires a behaviour support plan or a report of an adverse incident to the Commission. However, for many children with neurodevelopmental concerns accurate diagnosis may not be possible or appropriate early in their life course, yet medication may be indicated for clear clinical reasons.
The risk of the current approach is that these monitoring and reporting requirements may capture therapeutic clinical prescribing in child development. This potentially has an unintended negative impact on these children’s care and developmental success.
A recent NBPSA document on behaviour support and psychotropic prescribing in paediatric practice is attached for your information [Tab One]. Also attached is the NBPSA submission to the Tune Review which contains a number of recommendations including greater consultation between the health and disability sectors [Tab 2]. The NBPSA is also acting to improve the quality and consistency of prescribing psychotropics for children who are neurodiverse and is currently developing relevant guidance in this regard.
While we recognise the need to balance the right to access medical care w ith the regulation of quality and safety, particularly for children in care, this is a complex area for disability and health providers alike. Closer collaboration between agencies, regulators and clinicians with sharing of expertise would inform and enhance the rights of children w ith neurodevelopmental and behavioural disabilities.
The current national focus on review of implementation of the National Disability Insurance Scheme and associated organisational responses reflects a need for change in this area. The NBPSA respectfully suggests that greater consultation and engagement is needed between the NOIA and Health to help inform approaches to care for children with neurodevelopmental and behavioural concerns. Effective collaboration in development of policies and procedures that impact on children w ith disability is needed, to ensure the rights of these children to quality medical care are protected while detecting and responding to inapprapropriate or restrictive practices.
Thank you again for the opportunity to share these thoughts. The Committee’s consideration of our submission is greatly appreciated. The Society would be pleased to contribute to any collaborate process that may assist in resolving the issues raised, including consideration of the potential for legislative change.
Should you require any further information, please contact Greg Rochford, Chief Executive Officer, NBPSA at
Yours sincerely
Dr Jane Lesslie Dr Samantha Kaiser
President Chair Advocacy Committee
(encl)