8 May 2020
Attention: Joint Standing Committee on the NDIS:
Indigenous Allied Health Australia (IAHA) – submissions to the Joint Standing Committee – NDIS – Inquiry into NDIS Workforce
Indigenous Allied Health Australia (IAHA) is a national, member-based Aboriginal and Torres Strait Islander allied health organisation. We play a prominent role in increasing the number of Aboriginal and Torres Strait Islander people who study for, graduate, and succeed in health and related careers. Our work is helping to build the supply of Indigenous health professionals in Australia. Building this workforce is a central strategy to deliver much needed improvements in Aboriginal and Torres Strait Islander peoples’ health and wellbeing. Crucially, an increase in the size and distribution of Aboriginal and Torres Strait Islander allied health workforce is fundamental to ensuring Aboriginal and Torres Strait Islander people (especially), and others who are eligible to receive NDIA related services, are able to access services that meet their immediate and longer-term needs and that these are delivered in a culturally safe and responsive manner.
Aboriginal and Torres Strait Islander people make up around 0.5 per cent of the allied health workforce, while almost 3 per cent of the overall population. While IAHA has contributed to a substantial increase in the growth of this workforce over recent years, the disparity in representation still requires an approximate six-fold increase to reach population parity and considerably more to address the health, disability and related needs of Aboriginal and Torres Strait Islander people. Further, the maldistribution of allied health professionals across Australia overall is profound, resembling the pattern of (non-GP) medical specialists – with acute and chronic shortages outside of the major population centres. While improving access to culturally safe and responsive health care for Aboriginal and Torres Strait Islander people must be a priority across the board, the lack of access to allied health services in many communities, especially rural and remote, is particularly acute. This substantially limits the quality of NDIS assessments, and the availability and efficacy of services delivered to many people; without a multidisciplinary workforce, disability services are inaccessible irrespective of need and eligibility.
IAHAs membership, which is growing on average 25-30 per cent annually, includes representatives from 29 distinct allied health professions. We work across many sectors including disability services, health, aged care, education and more toward a vision where all Aboriginal and Torres Strait Islander people and future generations are; healthy, strong, thriving, and self-determined.
Unfortunately, while the NDIS principles place individual clients at the centre of the Scheme, the development of the NDIS workforce to date has not enabled that to occur. Rather as the NDIS becomes the predominant market for services it has therefore commodified disability services for participants, and disconnected services that would sit alongside other sectors/clientele and support people with a disability to participant economically and socially.
The Terms of Reference for this inquiry focus on employment opportunities which, whilst necessary, does not ask the question of whether the services delivered to people with a disability are meeting their needs; and the follow on question, is the composition of the sector’s workforce skilled enough and accessible enough to meet the choice and control objectives for participants. In many communities in Australia, the circumstances do not exist for these objectives to be balanced; instead, they are in tension and even incompatible. The application of market principles to the disability support system does not necessarily provide the same focus as an underpinning that is person centred would. Part of the resolution of this problem is the development and accessibility of an adequately distributed, cultural capable and professionally skilled allied health workforce.
It is imperative that the Committee consider opportunities to improve the ability of people with a disability to live to their full potential, by providing the services they need through a culturally safe and responsible disability and community services sector workforce.
If you require further information from IAHA please contact Mr Paul Gibson on or via email at
Donna Murray
Chief Executive Officer
Indigenous Allied Health Australia
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Response to the Terms of Reference of the Joint Standing Committee on the
National Disability Insurance Scheme (NDIS) Inquiry into NDIS Workforce
Disability is an umbrella term covering a broad range of physical, mental, sensory, neurological, intellectual, and developmental impairments. People with a disability have an ongoing impairment that impacts on their mobility, daily activities, communication and may hinder their capacity to fully participate in life.1
IAHA, through our work, support efforts to build capacity and improve access to culturally safe and responsive health care and community support services for
Aboriginal and Torres Strait Islander peoples. The Aboriginal and Torres Strait Islander
health workforce plays an essential role in facilitating more equitable access for Aboriginal and Torres Strait Islander people to care and support that meet their needs in urban, regional, rural, and remote areas.
The NDIS represents an enormous opportunity to improve the quality of life and to facilitate the contribution and engagement of people with disability in the social,
cultural, economic and every other aspect of life. It is an investment in our
communities’ and the nation’s capacity. The additional resources allocated to the NDIS nationally represent an enormous, far-sighted investment. The insurance-based nature of the Scheme provides a crucial point of reference for expenditure investment. The onus must be on impact. In that sense quality and availability of the workforce and the services enabled through that workforce are crucial non-negotiables.
NDIS funding is not limitless and the Scheme is predicated on the assumption that (in addition to other improved quality of life impacts for participants) the right interventions will either a) increase the independence and functioning of participants and/or b)
increase independence and autonomy. Therefore, appropriate, and timely
intervention/s would prevent deterioration and may facilitate participants in
employment and thus achieve a return in savings and/or through taxation.
Consequently, it is vital to recognise that an appropriately funded and utilised support system
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facilitates access to the most appropriate services according to participants’ actual, assessed needs and identified priorities.
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supports workforce distribution (including allied health service) presence and sustainability – which is not available in many regions, especially rural and remote areas.
• the presence of this workforce supports the economic and wellbeing of
communities beyond the disability sector.
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1 Allied Health Professions Australia: https://ahpa.com.au/key-areas/disability/
Allied Health Workforce
In addition to access issues, it is disappointing that the current range of funded allied
health services available under the NDIS are limited in scope. For example,
Osteopaths are unable to provide manual treatments. The narrowing of scope of practice under the NDIS illustrates a lack of understanding and recognition of the allied health sector, and its potential to provide a positive impact on the wellbeing of people with a disability.
Allied health professionals (AHPs) provide a wide range of services and supports across the lifecycle and across Australia’s service system – health, disability, aged care, and in schools.
Indeed, recent deliberations from the Aged Care Royal Commission has highlighted some of the detrimental impacts on individuals’ quality of life, self-efficacy and trajectory when too little focus is placed on the strength of retention, rehabilitative and other aspects of care as are often and nearly entirely provided through allied health services.
The NDIS and Aboriginal and Torres Strait Islander peoples with a disability
For Aboriginal and Torres Strait Islander people, access to culturally safe and responsive allied health services can be extremely limited regardless of where they live. This is tied to numerous issues including, for example, the cultural safety of services and affordability more generally. But these are further compounded by an acute shortage of AHPs in rural and remote Australia, where a higher proportion of Aboriginal and Torres Strait Islander people live, compared with non-Indigenous Australians.
Much of Australia’s health and support service system is predicated on models that are designed for high population, metropolitan settings that do not easily translate to rural, remote, and especially Aboriginal and Torres Strait Islander community settings. Often policy and program adjustments designed to translate services to these settings are little more than:
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a scaling down of the service, which in practical terms often means a removal of allied health and other less “general”, but effective care services; and/or
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purportedly delivered through inadequate, infrequent, and ineffective visiting services and/or telehealth-type servicing which are more susceptible to the impacts of poor infrastructure such as digital infrastructure and geographic or seasonal accessibility issues.
There is a growing appreciation that these shortages are due to “failure of the market” in these settings. Too often the service system and funding models reflect urban centre constructs. Generally, “market failure” in these situations may not reflect need 4
or (at least latent) demand for services but may result from program or service inflexibilities that reduce the prospects of serviceable and sustainable local responses. That is to say that a lack of uptake does not necessary reflect need but may be more reflective of the issues mentioned above which can obscure the true demand or ‘market’.
NDIS Marketisation and the Workforce
The NDIS is a legislatively based entitlement for Australians but introduced with the view of using a market mechanism to give people choice and control while providing competitive pressures for quality and cost-containment. The conditions to enable these objectives to co-exist etc are often lacking, therefore it is necessary to develop mechanisms that support access, delivery etc. to a reasonable standard. The side effect of this is that it often results in low workforce development. Reshaping the funding and/or market supports within regions will provide opportunities to increase local and skilled employment.2 Reframing market supports to enable health service delivery to become more client centric in its delivery, would provide opportunities to develop a variety of models of support that would increase local skilled employment prospects and meet local or regional community needs in a more tailored way.
To achieve the goal of the NDIS there is a need for a comprehensive workforce plan which could appropriately examine the issue of the wages and conditions that enable a person to earn a living, and identify training and support needs for the workforce. For example, the NDIS workforce Capability Framework should include, within its core capabilities, a requirement for services to provide culturally safe and responsive care as is now expected (and strengthened in legislation) across health and disability service professionals registered through the Australian Health Practitioner Regulatory
Agency (and increasingly through many of the self-regulated professional
accreditation bodies).
A more comprehensive workforce with the ability to support various employment models in large and small populations and under-serviced areas, not only improves the utilisation of the NDIS it will also improve skilled workforce distribution and service access. The current underspend within the Scheme demonstrates that the program is currently not able to deliver on its legislative intent because of the absence of services. Until this is addressed, the program cannot be successful. IAHA strongly advocates for an increase in the availability of allied health services within the NDIS that will support Aboriginal and Torres Strait Islander people with a disability to live well and to their fullest capacity.
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2 SARRAH, Services for Australian Rural and Remote Allied Health. 2019. Submission to the Senate Selection Committee Inquiry into Jobs for the Future in Regional Areas.
To this end, further development of the NDIS workforce should be informed by and progressed with reference to complementary national agendas, such as the current
work of the National Rural Health Commissioner, who is due to report to
Commonwealth Ministers at the end of June on recommendations to improve access, quality and distribution of allied health services in rural and remote Australia.
The NDIS workforce and Aboriginal and Torres Strait Islander peoples with a disability
As aforementioned, access to health care and community support services for Aboriginal and Torres Strait Islander people is strongly influenced by the level of cultural safety and responsiveness of these systems. For this reason, IAHA calls for the Disability Services system to enhance the cultural safety and responsiveness of the workforce; to support Aboriginal and Torres Strait Islander people to identify (including through appropriate clinical procedures for recording Aboriginal and Torres Strait Islander status) and facilitate access to support and care that they need.
Similarly, with the aged care sector, the disability sector requires a methodology applied to workforce planning that locates the needs of clients as the primary goal. Workforce distribution and creating employment opportunities would follow on from this focus. A marketisation of the disability sector immediately places profit above the client, as we have seen within the aged care system. Profit thus becomes the drive of reducing costs rather than enhancing the workforce’s capability and professional development.
Numerous allied health professions are eligible to register as a provider under the NDIS; however, the Act and its operational guidelines prevent AHPs from providing their full accredited and registered scope of practice (or range of services). This is despite the aim of the Scheme being to provide a range of innovative person-centred services, to enable NDIS participants to choose the best services to meet their individual needs. These seemingly contradictory parameters result from framing of guidelines that aim to direct or restrict what are acceptable treatment, supports and/or
assessments services (regardless of the professional judgement of the health
workforce) while purporting to enable individualised, specific treatment and support.
To meet the needs of Aboriginal and Torres Strait Islander people with a disability and
their families and communities; governments and other stakeholders need to
fundamentally look at actions to develop locally based workforces. This should include the assistant workforce and enable ongoing therapy and assistance, under the direction of professionals who may not be in a specific location and therefore may be available less frequently. This requires supporting education and training models that have been highlighted in various ways by many, within the disability sector and by the Aboriginal community-controlled health sector, who are key service providers within communities providing services beyond health. In many remote areas and regional centres allied health services are rare, inadequate, and sometimes non-existent. 6
There needs to be investment to support training hubs outside of urban centres that provide education and career pathways for local people to work in allied health across the human services system such as disability, and aged care.
IAHA strongly recommends that the Committee support a genuine approach through the Council of Australian Governments for investment:
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in training our sectoral workforces to be safe and respectful with people with a disability and secondly (but no less importantly) to be culturally safe and responsive when working with Aboriginal and Torres Strait Islander people with a disability.
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in growing the Aboriginal and Torres Strait Islander workforces across the social determinants such as health, education, and disability to empower Aboriginal and Torres Strait Islander people with a disability to achieve their goals, good health, and wellbeing.
• in addressing gaps in infrastructure, health care delivery and housing,
otherwise the NDIS scheme cannot deliver on its objectives for Aboriginal and Torres Strait Islander people living in isolated communities.
IAHA also notes the First Peoples Disability Network (FPDN) and their work calling for
whole-of-community approaches that incorporates peer to peer leadership that
implements inclusive education and employment programs. This approach would recognise and value the existing skills, knowledges, and experiences of people with lived experience within the disability sector and enable people with disabilities to be self-determining. Doing so would also inform workforce planning and support the Government’s interest in increasing employment for Aboriginal and Torres Strait Islander peoples and business enterprises.3
Workforce planning requires evidence-based decision making founded on and for Aboriginal and Torres Strait Islander communities. Co-design and shared decision making processes between policy makers and people/ communities within the disability sector should be foundational in workforce planning processes. The FPDN4 has made several calls for action including to:
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Invest to create an Aboriginal Community Controlled Disability Services Sector for the provision of disability supports by Aboriginal and Torres Strait Islander people with a disability for their communities.
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Prioritise timely intervention to ensure supports and services are provided, and available over the long-term, and at the right time in people’s lives. 7
3 FPDN. 2018. Ten Priorities to Address Disability Inequity in Aboriginal and Torres Strait Islander Communities for the NDIS. Retrieved from: https://fpdn.org.au/wp-content/uploads/2018/10/FPDN-ten-priorities-2018.pdf. 4 Ibid
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Develop and implement programs for inclusive education and employment for Aboriginal and Torres Strait Islander people with a disability in line with national strategies for their full social participation.
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Create links between the National Disability Strategy and Closing the Gap Framework for coordinated policy and programs at the Commonwealth, State, and local levels in partnership with Aboriginal and Torres Strait Islander people with a disability and their organisations.
• Develop an Aboriginal and Torres Strait Islander Disability Performance
Framework for the independent monitoring of the social and economic
outcomes of Aboriginal and Torres Strait Islander people with a disability.
FPDNs proposals warrant serious consideration.
Conclusion
The allied health workforce provides care and support for people with all types of disability including physical disabilities, psychosocial disability and developmental or
intellectual disabilities. AHPs provide this support now, although not all the
interventions they are qualified and able to provide legally are facilitated by NDIS funding supports.
AHPs provide services in all settings, from public and private hospitals, to outpatient clinics, community health centres, private practices, in the home, workplace, school, aged care centres, mental health facilities, sport centres and disability facilities. For instance, AHPs routinely provide support and assessment around issues such as
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functional tasks and activities of daily living, including personal care and eating
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home and environmental aspects and assistance to identify equipment and sensory needs
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therapeutic care related to the physical requirements of the disability and
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mental health support. Workforce planning for the NDIS warrants engagement with other policy design processes from other sectors such as health, aged care, and community services more broadly. There is much learning that can be gained from other programmatic approaches especially the lesson that program objectives cannot be achieved without a workforce. Health professionals’ cut across sectoral needs and therefore the workforce must not be viewed within program silos. The need for integration of services, particularly health and disability has been highlighted during the Disability Royal Commission as being critical to reducing and overcoming barriers, and that disability supports should not stop at the door of a hospital.
Unfortunately, where systems are not developed to support the viable distribution of the AHP workforce and/or support sustainable service provision, these services may not be available to NDIS participants, regardless of their own preferences or the 8clinical need and/or other benefits of them.