Australian Parliament
Joint Standing Committee on the National
Disability Insurance Scheme (NDIS)
Inquiry into the NDIS Workforce
Occupational Therapy Australia
supplementary submission
August 2021
Occupational Therapy Australia Limited ABN 27 025 075 008 | ACN 127 396 945
5 / 340 Gore St. Fitzroy VIC 3065
Ph 1300 682 878 | Email policy@otaus.com.au | Website www.otaus.com.au
Introduction
Occupational Therapy Australia (OTA) welcomes the opportunity to provide the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) with a supplementary submission commenting on the NDIS National Workforce Plan.
OTA is the professional association and peak representative body for occupational therapists in Australia. As of June 2021, there were more than 24,800 registered occupational therapists working across the government, non-government, private and community sectors in Australia. Occupational therapists are allied health professionals whose role is to enable their clients to engage in meaningful and productive activities.
Occupational therapists provide physical and mental health therapy, vocational rehabilitation, chronic disease management, assistive technology prescription, home modifications and key disability supports and services. As such, many occupational therapists provide services to NDIS participants.
The following submission contextualises the current demands on the occupational therapy workforce, including the immediate needs of those working within the NDIS. It then comments on the priority actions set out in the NDIS National Workforce Plan.
Occupational Therapy Workforce
Workforce profile The Department of Health (2021) has identified occupational therapy as the fastest growing registered health profession in Australia. Between 2015 and 2019, the occupational therapy workforce experienced an annual growth rate of 7.0 per cent, followed closely by osteopathy at 6.9 per cent (Department of Health, 2021).
During this time, there has been an increase in both the number of undergraduate and postgraduate occupational therapy courses available, as well as the number of students enrolled in these programs. This has placed increasing pressure on the workforce in terms of the number of student placements and fieldwork opportunities it can support – particularly in the context of an increasingly privatised workforce.
Over 90 per cent of the occupational therapy workforce in Australia is female and they are predominantly young professionals, with 48.8 per cent of the workforce under the age of 35 (AHPRA, 2020; AHPRA, 2021). Over 40 per cent are aged between 25 and 34, compared to just 26.9 per cent aged 35 to 44 and 15.1 per cent aged 45 to 54 (AHPRA, 2020).
Demand for occupational therapists Despite the establishment of many new occupational therapy courses, those graduating from such programs often do so with multiple job offers awaiting them. OTA members across most states and territories routinely report that they struggle to fill job vacancies.
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OTA anticipates that this workforce shortage will become more pronounced as the NDIS continues its rollout and more Australians with disability are deemed eligible to join it. The NDIS has already drawn significant numbers of allied health professionals from other areas of practice.
Demand for occupational therapists will also boom as our population ages. Whether opting to age in place or move into residential care, Australia’s rapidly growing number of older people will likely require the expertise of an occupational therapist to ensure not just their physical safety, but also their health, mental wellbeing and quality of life.
In this context, Australian governments must explore ways to fast-track the registration of more occupational therapists, without compromising the quality of occupational therapy services in Australia. They must also consider how to attract and retain occupational therapists in the profession for longer, at a time when multiple careers are considered the norm in a person’s working life.
Workforce attraction and retention OTA members advise that a number of complex factors impact on attraction and retention of occupational therapists in the workforce. In general, these include, but are not limited to:
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Lack of financial incentive to gain new skills or qualifications due to few positions for senior occupational therapy roles;
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Limited potential for income growth;
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Lack of opportunities for career progression, with few clinically-oriented senior positions (the major pathway for promotion is via management);
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Limited academic career pathways, which are needed to translate evidence to practice and develop innovative interventions and service delivery models; and
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High levels of emotional load and workplace stress – compounded upon by limited opportunities for mentoring, supervision and support – which can result in burnout.
OTA members have also identified a number of barriers to retention which are specific to the NDIS. In particular, OTA often fields enquiries from members reporting burnout due to the bureaucratic nature of the NDIS, as well as a lack of understanding of the occupational therapy role by NDIS Planners, Local Area Coordinators and Support Coordinators.
Occupational therapists working in the NDIS may also have less access to peer supervision compared to those working in a more traditional setting such as a hospital. OTA understands that the shift towards a billable hours funding model does not support paid supervision.
OTA believes that a number of these factors could be addressed in the NDIS National Workforce Plan. In particular, OTA suggests that the NDIA consider:
- Offering supervision and other clinical supports for allied health practitioners;
- Supporting allied health professionals to host more student placements; and
- Reducing bureaucratic and administrative burden. 3
NDIS National Workforce Plan
Priority 1: Improve community understanding of benefits of working in the care and support sector and strengthen entry pathways for suitable workers to enter the sector
Whilst OTA welcomes this as a priority, it is unclear how the associated actions will attract more occupational therapists to the NDIS.
Of the five initiatives listed under this priority, only one appears to target allied health students, that is, initiative 5: “better connect NDIS and care and support providers to employment and training providers and workers” (page 25).
According to the NDIS National Workforce Plan: “Job seekers (school leavers, VET students, unemployed people, allied health students) are not always aware of NDIS or broader care and support sector opportunities…NDIS providers report great difficulty in attracting allied health professionals from university, with reports that universities do not recognise the growth potential in the NDIS” (page 25).
OTA members routinely report that they cannot fill job vacancies, despite the very generous packages they offer. However, OTA understands that this is more often due to the overall shortage of occupational therapists, rather than a lack of awareness by universities of the job opportunities available to occupational therapists in the NDIS.
In a competitive job market, OTA also notes that graduates may preference a structured graduate program with strong supports, as opposed to less structured and supported roles which are sometimes available within the NDIS. Similarly, universities are more likely to encourage graduates to enter structured roles with strong clinical supports and supervisory arrangements in place.
Exposure to the NDIS through placements undertaken at university may also assist in attracting allied health professionals to the NDIS workforce upon graduation. Student placements in the NDIS are explored in greater detail under Priority 2.
Priority 2: Train and support the NDIS workforce
Whilst OTA supports this priority in principle, the actions underpinning it do not fully address the current support needs of the occupational therapy workforce in the NDIS.
According to the plan, micro-credentials (initiative 6) are intended to provide “a viable initial learning pathway, which can later lead to formal qualifications” (page 27). Clearly, this is not relevant to registered occupational therapists who have completed a minimum of four years study to obtain their qualification. Similarly, the proposed skills passport (initiative 8) appears to be targeted towards disability support workers.
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OTA has no objection to a Care and Support Worker Professional Network (initiative 7); however, we do not believe this would fully address the needs of occupational therapists currently working in the scheme.
As noted previously, occupational therapists working in the NDIS do not always have access to the discipline-specific supervision and peer support which play a valuable role in the development of professional expertise and self-confidence, as well as the retention of occupational therapists in the workforce.
Whilst this is particularly important for new graduates, occupational therapists of all career stages benefit from professional mentoring, networking and supervision. OTA would therefore welcome the addition of an initiative to increase access to supervision and other clinical supports for allied health practitioners working in the NDIS.
Initiative 9 – Support the sector to grow the number of traineeships and student placements OTA welcomes this initiative and agrees with the Department’s assertion that the current supply is low because, among other reasons, providers “lack resources to provide supervision, cover costs of administration relating to placements and guarantee work hours” (page 28).
OTA would add that these difficulties are compounded by the fact that many occupational therapists operate small private practices or as sole traders and do not have the frameworks in place for hosting students.
OTA fields a variety of related enquiries from members, including whether clinicians may bill for time spent supervising students, as well as practical considerations, such as office space and insurance requirements. Clarification of these and similar questions may also encourage more clinicians to host students.
OTA looks forward to opportunities to work with the NDIA to “explore how student placements can be delivered efficiently in a disaggregated market” (page 28), noting that this is a growing challenge across all sectors, not only disability or the NDIS.
Priority 3: Reduce red tape, facilitate new service models and innovation and provide more market information about business opportunities in the care and support sector
OTA welcomes this as a priority and acknowledges that the actions underpinning it are more closely aligned to the current needs of the allied health workforce.
Regarding red tape, however, OTA is deeply concerned that the Department has overlooked a valuable opportunity to genuinely improve the experience of allied health professionals working under the NDIS.
According to the National Workforce Plan, 58 per cent of providers believe that there are too many unnecessary rules and regulations in the NDIS (page 28). Providers also report that the costs of processes like audits – which can be upwards of $15,000 – impact viability in the NDIS, particularly for small providers (page 18).
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Of further significance, 72 per cent of allied health professionals ranked “excessive administrative burden” as one of the top three challenges impacting the productivity of the NDIS workforce (page 19).
These findings are entirely consistent with the feedback which OTA routinely receives from its members. In response to these findings, the Department proposes the following:
“A review will explore options to achieve greater regulatory alignment across the care sector, including for disability, aged care and veterans’ affairs. The review will explore the merits of streamlining provider audits and worker screening checks, while still maintaining quality.”
Efforts should certainly be made to streamline audits and checks to enable the flow of workers across sectors. However, it is essential that such a review also consider whether registered health practitioners should be subject to further NDIS certification and registration requirements at all.
In February 2019, OTA drew this Committee’s attention to the substantial and growing bureaucratic burden placed on Australian health professionals:
Certification by the NDIS Quality and Safeguards Commission is a disincentive to continued registration with the NDIS, in particular the prohibitive cost of the required audit. OTA asks again why one arm of government, the Australian Health Practitioner Regulation Agency (AHPRA), deems our members fit to practice while another, the Commission, questions that fitness.
This question has never been satisfactorily addressed by the NDIS Quality and Safeguards Commission.
To become a registered occupational therapist, an individual must complete an accredited undergraduate degree and meet all registration requirements set by AHPRA. These requirements cover criminal history, English language skills, professional indemnity and insurance arrangements, continuing professional development and recency of practice.
Occupational therapists must also renew their registration annually and demonstrate that they continue to meet AHPRA’s registration standards.
Imposing any additional screening or registration requirements on occupational therapists simply duplicates regulatory functions. Such duplication is not only unnecessary; it has the demonstrated effect of disrupting workforce attraction and retention.
Certification and verification of AHPRA registered service providers by the Commission is unnecessary. It is onerous. It is expensive. Worse, it drives talented clinicians from NDIS work, depriving NDIS participants of enhanced choice of service providers – supposedly a tenet of the Scheme.
At a time of historic health and budgetary challenges, OTA calls on this Committee to lead a charge against the onerous, expensive and time consuming bureaucracy that besets
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Australia’s health professionals. Either the Australian Government trusts the rigour of AHPRA’s registration processes, or it does not. If it does, AHPRA registration should suffice.
Regarding the remaining initiatives identified under this priority, OTA provides the following feedback:
Initiative 11 – Continue to improve NDIS pricing approaches to ensure effective operation of the market, including in thin markets OTA supports this initiative in principle, provided that all stakeholders – including allied health peak bodies – are adequately consulted and engaged, and that the initiative is not used to progress cost cutting measures which reduce consumer choice and control.
Initiative 12 – Provide market demand information across the care and support sector to help identify new business opportunities OTA does not oppose this initiative but notes that occupational therapy providers’ capacity to expand is generally limited by supply rather than demand issues. This is particularly true of regional and remote areas where recruitment challenges are generally most severe.
Initiative 14 – Explore options to support allied health professionals to work alongside allied health assistants and support workers to increase capacity to respond to participants needs OTA supports Allied Health Assistants (AHAs) when properly qualified, appropriately deployed and responsibly supervised. Indeed, they are crucial to ensuring that fully qualified allied health professionals have capacity to work to top of scope.
Under no circumstances, however, and regardless of workforce shortages, should AHAs be undertaking occupational therapy-related tasks for which they are not properly trained or without the supervision of a registered occupational therapist. OTA is advised that this is currently occurring within the NDIS with increasing frequency.
For more information, the Committee is invited to review our position paper, The role of allied health assistants in supporting occupational therapy practice (OTA, 2015).
Conclusion
OTA thanks the Joint Standing Committee for the opportunity to inform its inquiry into the NDIS workforce. OTA is committed to future proofing the occupational therapy workforce and ensuring all NDIS Participants have access to high quality occupational therapy services when and where they need them.
Please note that representatives of OTA would be pleased to appear before the committee to expand on any of the matters raised in this submission.
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References
Australian Health Practitioner Regulation Authority. (2020). ‘Occupational therapy in 2019/2020’. Retrieved from https://www.occupationaltherapyboard.gov.au/News/Annual-report.aspx.
Australian Health Practitioner Regulation Authority. (2021). ‘Occupational Therapy Board of
Australia – Registrant Data’. Retrieved from
https://www.occupationaltherapyboard.gov.au/About/Statistics.aspx.
Department of Health. (2021). ‘Allied Health in Australia’. Australian Government. Retrieved from https://www.health.gov.au/health-topics/allied-health/in-australia
Occupational Therapy Australia. (2015). ‘Position Paper: The role of allied health assistants in supporting occupational therapy practice.’ Retrieved from https://otaus.com.au/practice-support/position-statements.
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