APS Response to
Joint Standing Committee on the National Disability Insurance Scheme:
Australian Psychological Society | Submission, May 2020
psychology.org.au
Contact
Dr Tony McHugh MAPS
Senior Policy Advisor
The Australian Psychological Society Ltd
Level 13, 257 Collins Street
Melbourne, VIC 3000
Phone: 03 8662 3300 Email: contactus@psychology.org.au Web: psychology.org.au
ABN 23 000 543 788
This resource is provided under licence by the Australian Psychological Society. Full terms are available at psychology.org.au/Special-pages/Terms-and-Conditions. In summary, you must not edit or adapt it or use it for any commercial purposes. You must acknowledge the Australian Psychological Society as the owner.
We acknowledge the Traditional Custodians of the lands and seas on which we work and live, and pay our respects to Elders, past, present and future, for they hold the dreams of Indigenous Australia.
© 2020 The Australian Psychological Society
Contents
The Australian Psychological Society . . . . . . . . . . . . . . . . . . . . . . . . . . 4
Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
APS Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
The APS Response to the Inquiry’s Terms of Reference . . . . . . . . . . . . . . . . . . 8
Term of Reference (a): The current and future size and composition of the NDIS workforce 10
Term of Reference (b): Workforce attraction and retention challenges . . . . . . . . . . . 11
Term of Reference (c): The impact of Commonwealth Government policy on the
NDIS working environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Term of Reference (d): Government’s role in NDIS workforce development planning . . . . .15
Term of Reference (e): The interaction of NDIS workforce needs with employment in adjacent
sectors including health . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
Term of Reference (g): Other matters . . . . . . . . . . . . . . . . . . . . . . . . . .19
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Appendix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
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The Australian Psychological Society
The Australian Psychological Society (APS) is the largest national professional organisation for psychologists, with over 24,000 members across Australia. It seeks to help people achieve positive change, so they can confidently contribute to the community.
Psychologists are experts in human behaviour and The APS has a long history of working collaboratively use evidence-based psychological interventions with the Australian Government, State and Territory to enhance human performance and functioning, governments and other agencies to help address prevent people from becoming unwell, and assist major social, emotional, and health issues for local them to overcome mental and physical illness. communities and ensure healthcare is equitable Economic evaluations highlight the cost-effectiveness and accessible to all members of the Australian of psychological interventions to support functioning, community. prevent people from becoming mentally unwell, and to treat a range of mental health symptoms and disorders when they do occur.
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Executive summary
The APS welcomes the opportunity provided by the Joint Standing Committee on the National Disability Insurance Scheme (NDIS/the Scheme) to provide feedback on the Scheme’s workforce and guide improvements that will support the lives of many Australians living with disability and the communities in which they reside.
The APS offers the following recommendations in relation to the Terms of Reference set out by the Joint Standing Committee.
APS Recommendations needs analysis and conducted with input from key stakeholders (including the peak professional bodies) across the disability sector. The current and future size and composition Workforce attraction and retention challenges of the NDIS workforce The APS recommends that the Australian The APS recommends that the Australian Government takes the necessary steps through Government takes the necessary steps through the the NDIA to address the workforce attraction and National Disability Insurance Agency (NDIA) and retention challenges facing the Scheme. In particular, NDIS to ensure that a viable and sustainable NDIS it recommends that the NDIA: workforce of the requisite quality is established as a matter of priority. This will be enabled by: 4. Ensure NDIS planners, Local Area Co-ordinators (LACs) and support co-ordinators recommend the 1. A thorough participant-care needs analysis, use of psychologists as the preferred providers of conducted with input from key stakeholders psychology interventions for NDIS participants for (including peak professional associations) across neurocognitive, behavioural and mental health and the disability and other relevant (e.g., health and psychosocial disabilities. mental health) sectors.
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Address the cost of Third-Party Verification (TPV), 2. An analysis of the workforce supply and demand. especially for small practices with small customer This analysis should specifically seek to establish bases. (a) the number of NDIS participants with a mental illness and/or a psychosocial disability, (b) what 6. Reduce unnecessary “red tape” and the burden of proportion of those participants with such needs administration in service delivery. have current plans that include psychological Impact of Commonwealth Government policy goals and (c) which professionals are providing on the NDIS working environment the required services, and (d) the impact of recent changes to auditing/registration requirements on The APS recommends that the Australian provider workforce numbers, and impact on eligible Government develops comprehensive policies in participant access to psychologist providers. relation to the NDIS working environment regarding
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Development of workforce benchmarks for education and training of NDIS staff, fee setting and successful service delivery predicated on the regulation of providers, and that, via such policies, NDIA and NDIS take the necessary steps to:
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- Fully assist the NDIS workforce to develop to Other matters its optimal potential. This includes developing The APS recommends that the Australian Government operational policies that are supportive of the takes the necessary steps to ensure that the NDIA and needs of staff and providing training targeted to NDIS act to: workers and NDIS staff (including planners and LACs) and 11. Improve the quality of communications with practitioners, industry representatives and peak 8. Appropriately engage with professional professional bodies. organisations in the development and implementation of NDIS targeted programs of 12. Review the role of NDIS planners for their impact education and training. on the NDIS workforce and the availability and quality of service delivery through the NDIS Government’s role in NDIS workforce Quality and Safety Commission. development planning
The APS recommends that the Australian Government takes the necessary steps through the NDIA and NDIS to develop a comprehensive strategic workforce development plan. To facilitate this, the APS recommends the:
- Development of workforce benchmarks for successful service delivery predicated upon a needs analysis and conducted with input from key stakeholders (including the peak professional bodies) across the disability sector and the close involvement of the Quality and Safeguards Commission.
The interaction of NDIS workforce needs with employment in adjacent sectors including health
The APS recommends that the Australian Government takes the necessary steps through the NDIA and NDIS to better design the arrangements that apply to interaction of NDIS workforce needs with employment in adjacent sectors. To facilitate this, the APS recommends that:
- The NDIS/NDIA commence high level government, industry and peak association consultations aimed at clarifying the best set of working relationships of the Scheme to all adjacent sectors for their workforce and service delivery implications and impacts.
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Introduction
The APS welcomes the opportunity to provide a The market-place environment in which the NDIS submission to the Joint Standing Committee (JSC) operates has potentially profound consequences inquiry into the Workforce of the National Disability for participants and practitioners through the NDIS Insurance Scheme (NDIS). workforce. Ongoing scrutiny of the NDIS workforce is essential in ensuring that the best possible outcomes Psychologists are an important part of the workforce for participants are being targeted and delivered. involved in providing support to people with Based on APS member comment, this submission disability in Australia. In making this submission, focuses on the Terms of Reference set out by the JSC the APS liaised with members who are working Inquiry into the: or have worked in the NDIS environment as sole practitioners, staff members of service provider a. the current size and composition of the NDIS organisations or members of other entities. The workforce and projections at full scheme; APS believes it is critical that the workforce issues b. challenges in attracting and retaining the NDIS it identifies in this submission are addressed if workforce, particularly in regional and remote the NDIS is to operate as the originally envisaged communities; landscape-altering scheme for the provision of care to Australians with a physical, intellectual, sensory c. the role of Commonwealth Government policy in and/or psychosocial disability. influencing the remuneration, conditions, working environment (including Workplace Health and The operation of the NDIS is underpinned by a Safety), career mobility and training needs of the philosophy that places autonomy (though choice NDIS workforce; and control in decision making about services). It decentralises service delivery from state government d. the role of State, Territory, Commonwealth providers to the non-government and private sectors Governments in providing and implementing a via various funding mechanisms that aim to improve coordinated strategic workforce development plan the quality of life of Australians living with disability. for the NDIS workforce;
e. the interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care;
f. the opportunities available to, and challenges experienced by, people with disability currently employed, or wanting to be employed, within the NDIS workforce; and
g. any other matters.
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The APS Response to the Inquiry’s
Terms of Reference
Term of Reference (a): The current provide a variety of supports and interventions and future size and composition of to participants. This includes services related to
assessment (e.g., of neuro-cognitive disorders), early the NDIS workforce childhood disabilities (e.g., in intellectual function and
learning disorders), complex behavioural deficiencies, Individuals who require care and support under developmental issues (e.g., sexual maturation), the the NDIS can be affected by a range of sensory, co-ordination of life stage transitions (e.g. from special intellectual, developmental and/or behavioural to mainstream schools and vice versa and from school impairments and disabilities. Importantly, research to adult day care programs) and capacity building (e.g., demonstrates that people with a disability have for community participation). a higher prevalence of mental health disorders compared to those without a disability. In mid-2018, the NDIS predicted that 64,000 Australians with severe and persistent mental illness The impairments and disabilities experienced by will be eligible to access the Scheme by the time it is NDIS participants and the psycho-social disability in full operation (NDIS, 2018). Around a year later, it associated with them impact significantly on was identified that the Scheme is likely to fund plans their capacity to function within the community. for over 500,000 Australians over the next five years Scheme participants are, therefore, among the (NDIS Ministerial statement; August 2019), many of most disadvantaged Australians and the challenges whom will also experience psychosocial disability. involved in working with them are considerable. In the face of this demand, the NDIS in August 2019 Scheme participants are entitled to best-practice projected that up to 90,000 FTE equivalent NDIS care and interventions for their disabilities. For this to workers will be employed in the field in Australia occur efficiently and effectively, however, two things by 2023. As the APS understands it, this is twice the are required: current disability workforce. Given the projected 1. Clarity of scope: There must be clarity about what number of NDIS participants with mental illness disabilities are within the scope of the Scheme. (13% of the total NDIS population) and that those APS member feedback indicates a serious lack with psychosocial disability arising from or associated of clarity among planners about the mental with disability are not included in this, the demand health conditions accepted under the NDIS and for psychology interventions that is facing the NDIS whether psychosocial disabilities will be funded is, and will continue to be, significant. for intervention. The APS stresses the critical importance of addressing this issue as it creates As at 31 January 2020, there were approximately significant uncertainty for participants and 1000 psychology practices (most of which likely providers. employ more than one psychologist) registered to
- Fit for purpose: The NDIS workforce must be fit provide services under the Scheme across Australia for purpose if it is to deliver best-practice care (NDIS, 2020). Based on this data, there is uncertainty and interventions. To ensure this, the NDIS regarding the capacity of the current psychology workforce must not only be of appropriate size workforce to meet current demand, and even more and availability, but appropriately qualified, uncertainty regarding its capacity to meet expected with the requisite capacities and skills for future demand. The psychology workforce must delivering best practice care and interventions to increase if the supply and availability of psychology NDIS participants. services is to cope into the future. The work required to address participants’ There are demonstrable service gaps in regional, rural psychological needs under the NDIS is specialised and and remote Australia and in relation to those with often complex in nature. The role of psychologists neurocognitive disorders, early childhood disability in providing assessment, care and interventions and behaviour support. APS member feedback, to participants is vital to assisting them and their from surveys in 2018 and 2020 and contacts to the families, guardians and carers, to cope with their APS’s Professional Advisory Service, identifies an disability. Psychologists working under the Scheme inability of the current workforce to address these
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gaps. In the absence of any hard data provided by the scope (eg. to provide psychological services without NDIS – for example, that which compares psychology the requisite training) or encourages growth in registrations for the Scheme against the numbers unregistered providers at the expense of registered judged by the NDIA as necessary for the successful providers via unregulated price incentives is a risk operation of the Scheme – the indications are that the to the appropriateness and quality of services. Scheme is failing to keep pace with the needs of many The composition of the workforce and the balance participants with mental ill health and/or psychosocial between registered and unregistered providers is social issues associated with their disabilities. incredibly important and as the APS has previously observed there is a paramount need to APS member feedback also highlights that the engage the right person with the right knowledge current supply and demand ratio may be worsening and skills for the job. There will be considerable and that, contrary to any idea that the psychology pressure on agencies to recruit a cheaper workforce workforce will increase, practitioners are reluctantly with inadequate knowledge, skills and experience to deciding to leave the Scheme and, in some cases, the undertake the more high-level services that might field. Illustrative of this, a March 2020 APS member be required by a person with a disability (APS, 2018). survey about the NDIS, to which there were 963 respondents who indicated they intended, were As the APS argues in relation to Term of Reference (b), currently or had recently worked under the NDIS, 10 there is a need to remove workforce barriers per cent of those surveyed indicated their intention and undertake a campaign to attract and retain to discontinue providing services under the Scheme. psychologists within the NDIS. As the APS argues in These practitioners were very experienced, with 29 relation to Term of Reference (d) this can only be done and 26 per cent of them having respectively worked on the back of a comprehensive workforce plan that for more than 10 or 20 years in the disability field. gives due prominence to psychology. If the current supply of psychologists as a proportion of the NDIS workforce was maintained, this Recommendations would provide for a doubling of the number of The APS recommends that the Australian psychologists under the Scheme over the next three Government takes the necessary steps through years. However, such an increase in the psychology the NDIA and NDIS to ensure that a viable and workforce would simply maintain parity with the sustainable NDIS workforce of the requisite current supply and demand ratio which, as noted quality is established as a matter of priority. above, appears insufficient to meet the current This will be enabled by: needs of many participants in the Scheme and would 1. A thorough participant-care needs analysis, certainly be insufficient to address the likely increase conducted with input from key stakeholders in demand for psychology interventions in the future. (including peak professional associations) There is a significant likelihood that an increase in across the disability and other relevant (e.g., the psychology workforce will not occur without health and mental health) sectors. NDIS intervention to sharpen the demand-supply 2. An analysis of the workforce supply and curve. The APS is not aware of any plan by the demand. This analysis should specifically NDIA to address this and meaningfully grow the seek to establish (a) the number of NDIS psychology workforce and accelerate the supply of participants with a mental illness and/or a psychology services. psychosocial disability, (b) what proportion The development of an NDIS disability workforce of those participants with such needs have plan (see Term of Reference (d)) which provides current plans that include psychological goals for a proper matching of the supply of psychology and (c) which professionals are providing providers against demand for psychology services the required services which professionals has been a glaring omission in the operation of the are providing the required services and (d) Scheme to the present time. the impact of recent changes to auditing/ registration requirements on provider The APS has expressed its concerns to a range of workforce numbers, and impact on eligible inquiries (e.g., those conducted by JSC and Australian participant access to psychologist providers. Productivity Commission (APC)) about the impact
- Development of workforce benchmarks for of market forces on the capacity to ensure quality successful service delivery predicated on the services. The importance of developing the correct needs analysis and conducted with input workforce trajectory for the NDIS cannot be from key stakeholders (including the peak overstated. Any strategy that deskills the workforce, professional bodies) across the disability sector. encourages practitioners to work outside their
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Term of Reference (b): Workforce High need participant groups attraction and retention challenges No less important, but often less visible, is the problem of inadequate workforce supply for, and The APS has repeatedly identified areas of particular service delivery to, specific high need participant workforce challenge and the issues that mediate sub-populations. Members of the APS have identified the attraction and retention of the NDIS workforce1. several areas where workforce deficiencies are acute: These issues and influences are described below. (i) in the treatment of Autism and other
i. Areas of particular workforce challenge Neurodevelopmental disorders (like Intellectual
Developmental Disorder, Global Developmental Regional maldistribution
Delay, Learning Disorders, Attention Deficit/ The most obvious challenge to making the Scheme Hyperactivity Disorder, Other Specified operate to full capacity relates to attracting suitably Attention-Deficit/Hyperactivity Disorder, qualified practitioners to work in rural, regional Unspecified Attention-Deficit /Hyperactivity and remote Australia. The APS has in its previous Disorder, Specific Learning Disorder and submissions cited examples of serious delays in the Stereotypic Movement Disorder). provision of interventions to participants outside of metropolitan Australia2. (ii) in the provision of Early Childhood Support (ECS) and Behaviour Support Service, where there The APS considers it imperative that the existing are indications that providers – who often have workforce in rural, remote and regional Australia is provided a highly-dedicated and expert service activated and supported to develop capacity services – are choosing to not do this work because under services under the NDIS. The APS is strongly Scheme-driven difficulties of the view that the problem will not be solved by markets and timely, creative solutions are required (iii) in services to participants with mental health if workforce-related service shortfalls are to be issues and/or psychosocial disability, where successfully addressed. they, their families, carers and practitioners are continually referred to the MBS for assistance. The NDIA is urged to consider mechanisms to expand Although the APS has repeatedly raised this as a capacity rather than leave it to market forces (with all problem with the NDIS and government, there of the implications that this would create for rising has been little improvement in this area. prices and unit costs). Intrinsic to these problems is the failure of the Possible capacity-building mechanisms include funding:
Scheme to effectively and unambiguously define • indentured trainee placements and registrars in
and/or appropriately translate which conditions are practices and provider organisations
within the Scheme’s scope and which conditions are • practitioners to travel to regional, rural and
not, and for planners, LACs and support co-ordinators remote locations to provide concentrated to be obligated to act in accordance with that “sessions” of appointments
definition. Autism is a key example of where there • fly-in clinic-type services and
is frequent failure to accept participants into the • the use of tele-health or video conferencing
Scheme or approve sufficient interventions within (including for individual and multidisciplinary participant plans and where there is an attempt to teamwork) that is offered in a manner that it inappropriately cost shift the needs of participants to consistent with best practice guides. The APS has the health system under the MBS. developed a range of resources for psychologists related to telehealth, such as using telehealth This leads to significant problems for those with children and young people which could easily attempting to provide care. The following example be adapted to the NDIS environment. provided by a member illustrates the dilemma that
1 Roufeil, L. (2017). APS Response: Joint Standing Committee on the National Disability Insurance Scheme (NDIS) inquiry into transitional arrangements for the NDIS. APS: Melbourne. DOI 08/2017. 1 Roufeil, L. & McHugh, T. (2018). APS Response: Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Inquiry into Market Readiness for the NDIS. APS: Melbourne. DOI 02/2018. 2 Roufeil, L. & McHugh, T. (2018). APS Response: Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Inquiry into Market Readiness for the NDIS. APS: Melbourne. DOI 02/2018. 2 Roufeil, L. & McHugh, T. (2018). APS Response to the New South Wales Parliament Legislative Council Portfolio Committee No. 2 – Health and Community Services – Inquiry into the Implementation of the National Disability Insurance Scheme and the Provision of Disability Service. APS: Melbourne.
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faces participants, their families and carers and feedback strongly suggests that planners in some practitioners in the psychology space. It involves: locations are much more likely to send a participant a 36 yo male client who lives in supported who mentions they have anxiety, behavioural or accommodation. He has a moderate intellectual mood issues to the health system without even disability and ASD and has a substantial NDIS exploring the genesis of the issue. package. He was displaying increasingly erratic The most recent 2020 APS survey of members behaviours leading to four admissions to a mental confirms that the issues encapsulated within this health facility over a short period of time. The example remain significant problems. mental health facility eventually deemed him to be “unsuitable” for their care due to his intellectual Inadequate support disability. The NDIS planner was contacted to Second, members report that what is approved by obtain emergency respite but because there was no planners in participant plans (where psychology is funding specifically allocated to emergency respite, warranted) is inadequate. The most frequently cited the request was rejected by the planner. Thus, the concern is that NDIS approved interventions for mainstream mental health service rejected the complex problems are not of sufficient frequency and client due to his intellectual disability but the NDIS duration to address the impairment or disability of planner was also unable to provide suitable care for focus. An important example for this relates to the the client development of evidence-based behaviour support plans (BSPs) for individuals with complex behaviour As this example demonstrates, the absence of a clear issues. Members have informed the APS that plans do definition of scope results in decisions that directly not include functional behaviour assessment or time affect the care provided to participants. to devise, implement and monitor a BSP. (ii) Issues in the planning process The Institute for Applied Behaviour Analysis – There are several patterns of planner decision- internationally acclaimed service providers for making behaviour that result from the lack of clarity children and adults with disability – estimates around scope, which affect service delivery and as a that it can take over 80 hours to adequately consequence affect the experience of psychologists complete a behavioural analysis3. This contrasts working in the Scheme. These issues have been with the experience of an APS member providing identified by members as contributing factors to their psychological care to a 58 yo male participant decisions to review – and in some cases discontinue – who is an amputee with an acquired brain injury, their involvement in the Scheme. high medical support needs, high-need support for all activities of daily living and who exhibits Inconsistent decisions high levels of physical and verbal aggression, has First, there is demonstrable variability in the decisions inappropriate sexualised behaviour towards other made by planners for participants with similar care residents and staff in community-located supported and support needs. APS members report on the accommodation who frequently returns to the facility considerable variation between NDIS plans in terms in an intoxicated state. She reported that despite the of what services, skills and degree of intervention is enormity of his needs, required, particularly when a participant presents his NDIS plan included only 6 hours of behaviour with psychosocial disability. support, when [in line with best-practice] he needed In its 2017 submission to the APC, the APS observed that a … functional behaviour analysis, baseline cognitive If an individual has significant anxiety and/or assessment and (associated) adaptive measures … mood and/or behavioural issues as a result of their BSP and an (implementation) instruction for the disability and this is contributing to their inability to staff of the residential facility. The psychologist also function within the community, should services be needed to be available for monitoring and review of provided under the NDIS or via the health system? the BSP over 12 months. The experience of members is that this depends on Cost-shifting to Medicare what planner is working with the participant, or the The APS is particularly concerned by the consistent location of the participant. Some participants are feedback from members that planners are provided psychological services via the NDIS, yet for inappropriately and incorrectly instructing the same issue or circumstances, other participants participants and their carers that the NDIS does not are told to obtain a GP Mental Health Plan and permit psychological interventions and they are to see a psychologist under Medicare. This anomaly receive treatment under the Medicare Better Access cannot be explained by participant choice. Member to Mental Health Scheme (Better Access).
3 see www.iaba.com
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This attempt to push participants to Medicare has This is because the NDIS inadequately distinguishes been particularly common in relation to Autism, between the high-level knowledge, skills which is not approved for treatment under Better and experience of psychologists in behaviour Access and interventions are not funded. It also management (especially complex behaviour applies to ECS as indicated by the following member management) and those of the less qualified comments: workforce who are currently delivering behaviour
• I have seen the introduction of NDIS result in support under the NDIS. (such as OT assistants).
children with brain injuries receiving less services or The APS has been advised by members over some recognition of their disability. time that there is evidence of active advocating
• There has been a lack of knowledge by NDIS staff in by planners against the inclusion of psychology
relation to ASD [autism spectrum disorder], stating interventions in plans and/or in favour of the it was required (not recommended) that children provision of interventions by other providers, who with ASD be reviewed because it was mandatory lack the expert skills for the delivery of specialist that they were provided with an ASD level. This psychology interventions for the conditions and was not the case, after I spoke to NDIS but still behaviours involved on the basis of cost. occasionally a planner or LAC will tell the family The overall result of such planner decision-making this and there have been many upset parents in my in developing plans for participants is that it directly practice who are very confused. Even in the early influences the care, services and interventions that intervention arm of the stream I have had children are made available to participants. This inappropriate denied access until they have an assessment. restriction on the provision of psychology
• One of the key concerns I have had in early interventions in relation to neuro-cognitive disorders,
childhood is NDIS planners giving families ECS needs, mental health problems and psychosocial inappropriate information about the role of psych disability has unequivocal consequences for and or recommending to families that even though workforce retention and attraction. they have NDIS funding that they should save this for OT/Speech Pathology etc. and use Better Access There is also evidence that participants with funding for psych sessions. behaviour support needs (especially those with complex needs) are being denied to the opportunity Despite the APS having consistently raised these to make choices and exercise control over the concerns in submissions and in direct communication services they need. Member feedback suggests that with the NDIA, there appears to have been little this is primarily due to the development of plans change for the better and the feedback is that, to the by planners that do not reflect what is needed contrary, the incidence of such advice is increasing. for behaviour management plans for clients with Several members have suggested that planners are complex needs (in terms of both cost and time). The following an NDIS operating protocol or directive APS is aware that highly credentialed psychologists to direct psychology services to Medicare. The APS with long histories of delivering best practice has not been able to establish the accuracy of this interventions to the disability sector have left or are assertion but would be very concerned if it were the intending to leave the NDIS because of the inability case. Further detailed comments from members are to deliver best practice interventions to clients. appended to this submission. These planning deficiencies are common and are Non-psychologists delivering psychology particularly problematic for participants with interventions multiple or complex needs, who are among the most A further concern of the APS relates to the preference disadvantaged members of our community. Such of planners to advocate for non-psychologists deficiencies have the potential to place the safety of to deliver mental health interventions where participants, and their families, guardians and carers psychosocial disability is accepted as a target for at risk through the provision of sub-optimal care. interventions. Ultimately, such planner decision-making has the The APS is firmly of the view that decisions about potential for very significant impacts on participants. who is best to deliver interventions cannot be left to If psychologists de-register their services, depriving the marketplace, as there is significant potential for vulnerable NDIS participants of true choice, then the market to operate to meet service demand via default services are likely to be less appropriate for for-profit organisations and large Non-Government their condition(s) and needs. Organisations (NGOs) using a low cost and low capacity workforce.
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To summarise, the APS’s view is that there are serious Currently, only NDIA registered providers who structural and behavioural deficiencies in the NDIS have satisfied audit requirements are able to planning process as it has operated in relation provide services to participants with Agency to the approval of psychology interventions in managed plans. This is inherently problematic, participant plans. Given it is acting as a deterrent to given evidence recently made available to the APS’s the continued involvement of some practitioners in survey of members about the NDIS. The number the Scheme, the APS believes is critical that planner of psychologists choosing to work as registered decision-making behaviour be addressed for their providers is decreasing due to of their experience of impact on workforce availability development. the registration and auditing process as cumbersome and excessively expensive. (iii) Barriers and costs Also affecting the attraction to and retention of Psychologists are remunerated for their work across psychological practitioners in the NDIS are the a range of third-party payment systems (e.g., in barriers and costs involved in being a registered workers compensation, traffic accident and victims of provider for psychologists under the Scheme. crime and services systems related to current and ex serving military personnel) and primary health care Remuneration systems. None of those systems has a comparable With respect to the framework for pricing, the level of administrative burden and cost although APS has long argued that the NDIS inadequately some (e.g., Comcare) provide for similar rates of distinguishes differential credentials within the remuneration. Psychology workforce. The APS acknowledges the need for only suitably Psychologists with advanced training and competency credentialed and experienced practitioners to (as recognised within the psychology profession by deliver services. It believes, however, that the cost of the Psychology Board of Australia through Areas of registration and the necessity of re-registration needs Practice Endorsement) bring a level of additional to be addressed to reduce its deterrent value. The APS expertise, which is not adequately recognised in the is of the view that it is not enough to assume that current NDIS pricing regime. The APS has laid out its the business model of large provider entities can be view on this issue in previous papers4. applied to the whole workforce without deleterious Another area of concern relates to the cost of travel. impacts on engagement. The attached appendix of It is often not only highly desirable, but clinically sample comments about the impact of TPV from the necessary for psychologist practitioners to travel recent APS survey of practitioners in the disability to deliver interventions to NDIS participants. field is illustrative of this. Remuneration for travel has long been considered
insufficient by practitioners who operate to deliver Recommendations services in a client-located manner. This is a
The APS recommends that the Australian particularly acute problem in the dormitory suburbs Government takes the necessary steps through the of Australia, where practitioners can travel long NDIA and NDIS to address the workforce attraction distances to provide participants with services. and retention challenges facing the Scheme. In Third party verification (TPV) particular, it recommends that the NDIA: Of particular concern to members is the introduction
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Ensure NDIS planners, Local Area Co- of costly Third-Party Verification (TPV) and ordinators (LACs) and support co-ordinators particularly certification (as applies in relation to recommend the use of psychologists as work with children or participants with challenging the preferred providers of psychology behaviours). They have indicated that it has either interventions for NDIS participants for made it unaffordable or cost ineffective for smaller neurocognitive, behavioural and mental (including sole practitioner) practices to take health and psychosocial disabilities. on children under the age of seven years. This is particularly concerning, given evidence that smaller, 5. Address the cost of TPV, especially for small quieter and less sensorially stimulating environments practices with small customer bases. are what is required for these participants groups.
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Reduce unnecessary “red tape” and the burden of administration in service delivery.
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Australian Psychological Society. (2019). The Future of Psychology in Australia: A blueprint for better mental health outcomes for all Australians through Medicare – White Paper. Melbourne, Vic: Author.
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Term of Reference (c): The impact of
Commonwealth Government policy Recommendations
on the NDIS working environment The APS recommends that the Australian Government develops comprehensive policies The importance of the Commonwealth Government in relation to the NDIS working environment in influencing the remuneration, conditions, and regarding education and training of NDIS staff, working environment of the NDIS workforce through fee setting and regulation of providers, and policy cannot be over-stated: government policy is that via such policies the NDIA and NDIS take critical to the ongoing viability of the NDIS workforce. the necessary steps to: There is an obvious and significant role for
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Fully assist the NDIS workforce to develop government policy in price setting, defining what to its optimal potential. This includes conditions and impairments are within Scheme, and developing operational policies that safeguarding quality and safety by regulating the are supportive of the needs of staff and behaviour of providers and workers and NDIS staff. providing training targeted to workers and However, the environment in which the NDIS NDIS staff (including planners and LACs) and workforce operates extends beyond government
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Appropriately engage with professional policy settings. It is also necessary that the NDIS/ organisations in the development and NDIA sets supportive operational policies and implementation of NDIS targeted programs develops competency-based education, training and of education and training. supervision to build workforce expertise across the sector that supports the Scheme’s vision. A factor that should not be overlooked in the NDIS working environment is the potential for caring professionals and workers in disability and mental health field to “suffer because they care”. This is not uncommon in such workforces and carries a significant personal cost (Sabin-Farrell & Turpin, 2003). The NDIS requires a workforce with good mental health literacy and that is supported by management and peers who are aware of the principles of trauma informed care. It also requires access to Psychological First Aid (PFA) which permits safety, calm, connectedness, self-efficacy and group efficacy, and hope. To this end, it is important that the NDIS partners with professional organisations to help drive change in the planning process via targeted programs of education and training for provider organisations, workers and NDIS (especially planners and LACs).
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Term of Reference (d): Government’s The APS acknowledges that the NDIS has role in NDIS workforce development commissioned considerable work around the role
of allied health assistants in the NDIS. The APS planning has contributed to this work and looks forward to
The APS believes that it is critical that a working with the NDIS and governments across comprehensive strategic workforce development Australia to ensure that best practice arrangements plan (Plan) be developed as a matter of the priority are identified and implemented. to enable the delivery of best-practice care and The APS is also aware that it has been decided that interventions to NDIS participants. Such a Plan is as of 1 July 2020, on the basis of October 2018 fundamental to defining the appropriate workforce recommendations from the Disability Reform to deliver the services required under the NDIS. It Council, a new tole of Recovery Coach will be is critically important that it clarifies who is best introduced into the NDIS. qualified and safest to deliver the services required The APS was not involved in consultation on the for participants. introduction of this new role and is not aware of To accommodate situations where it is not clear what evidence was used to inform that decision. It which health professionals are best placed to deliver is notable that a recent study into recovery-oriented certain types of services, or where less complex practice and the impact on clients (see Meadows et services may be delivered by a non- or lesser-qualified al., 2019) reports a small but significant intervention worker, the Plan must articulate closely managed effect. Importantly that article, which represents one delegations with appropriate protocols and provide of the few reviews of recovery coaches, acknowledges for easily auditable paper trails. the paucity of evidence to support such roles and Benchmarks that assure the quality of interventions that they make little if any difference to most mental are central to proper workforce planning. The health clients. APS suggests that the establishment of effective The APS acknowledges the view in the disability field benchmarks be facilitated by a range of actions; that “recovery coaches” are required to assist NDIS for example, participants with complex needs. It understands
• the development of prototypical industry position that a typical target group of recovery coaches would
descriptions for workers that articulate Key be those with complex behaviours, such as those Selection Criteria and required and desirable requiring a BSP. experience
As the APS has previously observed in its submission • the identification of a preferred supervision
to the JSC and again reiterates in this submission, the arrangements and encouragement of supervision NDIS is complex in its operation. Often it is difficult networks
for participants, their families and carers to navigate • ongoing targeted and supported professional
the system with its diverse workforce of NGO development activities that relate directly to the providers, workers and health professionals, each disability field
with different enterprise agreements/fee schedules, • the implementation of training so that the
skill levels and professional roles and capacities. workforce has the disability relevant skills and mental health literacy required for successful role Recovery coaches may be able to assist participants accomplishment (see Term of Reference (c), page with that navigation. They may also play an
- and important role in the implementation of plans and • benchmarks for intervention activity that guide co-ordination of the care provided by the variety of
the content and intensity of intervention required practitioners, workers and organisation who may for psychology work approved in plans. be involved in the delivery of care. They could also fruitfully be involved in the linking and coordination The benchmarks should reflect appropriate of that care and the “Team” that sits around implementation guidelines and frameworks such as participants. the Victorian Government’s Allied health capability framework (Department of health and Human The APS is strongly of the view, however, that Services; DHHS, 2020). recovery coaches must not operate to deliver interventions under the NDIS. This is because they do The Plan must carefully anticipate where there is not possess the required qualifications, experiences likely market failure (see Term of Reference (b)) such or capacities. as for regional, rural and remote NDIS participants and those with neurocognitive, ECS, mental health Rather, they must act under the direction of LACs and and psychosocial disability service needs. support co-ordinators to assist Participants to access
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best-practice care and interventions. Given the role In this context, this workforce plan must be subject difference and capabilities involved, allied health to monitoring by an independent agency. That fits assistants, LACs, support coordinators and recovery well with the mandate of the NDIS Quality and coaches, must each have clear job descriptions and Safeguards Commission and it appears well placed to will need to worker under clear delegations and oversee the ongoing operation and maintenance of a supervision with clear audit trails. viable NDIS workforce. The APS recognises the need for workforce
development at the low intensity end of the support Recommendations spectrum and acknowledges the potential for allied
health assistants and recovery coaches to play a The APS recommends that the Australian valuable role. However, the APS is concerned that Government takes the necessary steps through both will be seen inappropriately as solutions to the NDIA and NDIS to develop a comprehensive psychology workforce issues in the NDIS and may strategic workforce development plan. To introduce new complexities. Issues of accountability, facilitate this, the APS recommends the: supervision, delegation and potentially loss of service 9. Development of workforce benchmarks for quality will need to be addressed. The introduction successful service delivery predicated upon of recovery coaches has the potential for adding a needs analysis and conducted with input further complexity and confusion into the system; from key stakeholders (including the peak unless practice in all parts of the system shifts professional bodies) across the disability to assume a recovery focus, there is potential for sector and the close involvement of the inconsistent messaging, confusion and ultimately Quality and Safeguards Commission. harm to NDIS participants. Issues such as what team care arrangements will be in place to support this (this cannot be undertaken via the MBS) will need to be addressed. How these issues will be mitigated appears not to have been considered by the NDIS. The insights of the 2019 Victorian Royal Commission into mental health and the APS submission support this view and should be considered. The APS submission strongly emphasised the need for skilled clinicians providing evidence-based care to be an integral focus within that system. For case coordination and supporting roles (such as recovery coaches), provisional psychologists (who work under supervision) could be considered. The NDIS has developed a range of critical guidance documents including practice standards, business rules, codes of conduct for providers and workers and NDIS Codes of Conduct for Service Providers and Workers and the Guidelines associated with each. Such documentation is well supported by
Federal and State Government Disability Plans and
state government practice frameworks and advisory statements (such as the Victorian Government’s allied health capability framework) and by professional association Codes of Ethics (such as the APS Code of Ethics, which has been adopted as a matter of National law, and its associated Ethical Guidelines). The development of a comprehensive workforce development plan represents a missing link in the documentation required to fully support the Scheme.
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Term of Reference (e):The interaction through the mainstream and community sectors of NDIS workforce needs with (e.g., referral to the public mental health system and
private mental health service providers including employment in adjacent sectors psychiatrists and psychologists).
including health Although this is a process identified as necessary by The NDIS makes it clear that it is not a surrogate the NDIS, there has been no reporting (e.g., by the for all systems that fund the provision of care and public release of data) to date of its success. While health services to all Australians. Such systems it is the responsibility of support co-ordinators and include federal and state workers compensation, LACs to assist participants/families in the planning Road Traffic Accident, Victims of Crime, Aged Care and process, and to identify suitable service providers, the Department of Veterans Affairs systems and public effectiveness of this is open to dispute. Additionally, health systems and programs directly funded by where they coordinate with non-plan related services government and public health activity funded by the is unclear. MBS. Those systems employ significant workforces. The APS is strongly of the view that the current The point of separation between these systems arrangements at the interface of systems are not and the NDIS is the individual’s permanency of working. The archetypal example of this relates to impairment or disability. That separation requires psychosocial disability. careful judgment based on what individuals are Given its nature, psychosocial disability requires reasonably entitled to receive in those systems and a mixture of evidence-based psychological when those systems have objectively discharged their interventions and broader social supports to enable responsibilities toward those individuals. This will functioning. Some individuals with psychosocial often hinge on whether evidence-based treatments disability will also require psychiatric interventions. have been applied with effect and whether the individual’s condition has become stable (i.e., no Psychosocial disability, however, can have its roots more improvement can reasonably be expected). in intellectual, sensory or physical disabilities; for example, an individual with permanent severe physical An example of this relates to chronic pain and the disability derived from stroke is likely to experience intersection of impairment and disability related psychosocial disability (e.g., depression, anxiety and to it in accident and compensation schemes and irritability) directly related to their disability. the NDIS. To the APS’s knowledge there are, as yet, very few cases of participants with chronic pain Additionally, many NDIS participants with mental receiving NDIS funded interventions. The best way to health conditions or psychosocial disability may not meet the needs of the individuals must be carefully have been formally psychiatrically diagnosed. This considered and the correct course of action planned does not mean, nevertheless, that their psychological within context of the NDIS’s responsibility and other state does not affect their wellbeing and functionality schemes within the wider funding environment. The and – based on the intention of the Scheme – they are achievement of that could provide a useful point of legitimately entitled to mental health and capacity comparison for defining what is outside the Scheme building interventions under the NDIS. for a range of other conditions. The APS continues to have significant concerns about Up until the age of 65 (when the aged care system the intersection of the health and disability sectors assumes responsibility for the (non-health-related) around psychosocial disability. Evidence provided by care of people with disability) or where individuals members suggests that gaps in services for Scheme are no longer eligible for care and interventions under participants with psychosocial disabilities are not other Schemes and their impairment and disability is narrowing and may be widening. judged to permanent, the NDIS is responsible for the It can be challenging (and in many cases impossible), care of those individuals. to identify the components of disability that However, there is a grey area where judgments are warrant a mental health as opposed to an NDIS made regarding whether support needs are or are response. Consequently, planners, LACs and support not a function of disability. Where the NDIS deems co-ordinators operate in a grey area that too often an individual is not eligible for funding in relation leads them to – contrary to the control and choices of to some aspect of their care – for example, because participants – refer (or “opt out”) participants to the they have mental health issues that are neither mental health sector. permanent nor related to their disability – there Given this, the APS draws the JSC’s attention to the is a need to assist those persons to find support need for the Government to definitively reinforce
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to the NDIA and the NDIS that for participants with either mental health conditions and/or psychosocial Recommendations disabilities requiring inventions, that they be ruled as fitting within the Scheme’s scope in the absence of The APS recommends that the Australian evidence that their conditions and difficulties are in Government takes the necessary steps through no way connected with either a physical and sensory the NDIA and NDIS to better design the or psychosocial disability. This will effectively redirect arrangements that apply to interaction of NDIS the Scheme from the “opt out” decision-making that workforce needs with employment in adjacent has become the defacto norm under the Scheme in sectors. To facilitate this, the APS recommends relation to mental health and psycho-social disability. that: A well-functioning process would see fewer 10. The NDIS/NDIA commence high level complaints of people ineligible for NDIS funding government, industry and peak association struggling to source alternative options. This is not consultations aimed at clarifying the best the case and there is an urgent need to resolve the set of working relationships of the Scheme current lack of clarity regarding where to distinguish to all adjacent sectors for their workforce a person who should be treated under the NDIS and service delivery implications and from those whose care should be funded by another impacts. system. This is best to occur at peak government level, involving agencies, councils (especially the
Disability Reform Council and the National Mental
Health Commission), industry representatives, associations (including the APS) and “think tanks” (such as Safe Work Australia) and state and federal government departments. The insights of the 2019 Victorian Royal Commission into mental health and the APS submission to it are noteworthy.
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Term of Reference (g): Other matters The APS has consistently expressed concern about the impact of planners on the delivery of Communication with stakeholders services to participants with mental health and/or psychosocial disability. Further, the APS is strongly of The stated intention of the NDIS and NDIA is to the view (based on interactions with its members) act in a timely and consultative fashion with key that the role of planners has a deterrent effect on stakeholders to address existing and emerging psychologists entering or remaining within the concerns so that the Scheme’s goals can be Scheme as registered providers. effectively realised. It is the experience of the APS and its members that the NDIS does not provide There are significant potential benefits in having timely responses to practitioner enquiries about or the NDIS Quality and Safeguards Commission clarifications of decisions about psychology care, accept responsibility for addressing this by support and interventions. creating mechanisms for planning oversight. Such mechanisms will ensure that plans developed for Many APS members have provided feedback about the individuals with a disability in need of psychological psychology ‘unfriendliness’ of the NDIS, reporting that:
assessment or intervention are appropriate and • getting clear answers from the NDIS about
enable them to receive such care. what is needed to have psychology approved in participant plans is very difficult The APS emphasises the need for urgent reform of
• there is difficulty obtaining clarification about the NDIS planning function so that:
anything! • there are minimum industry qualification
- when matters are formally raised with the NDIS requirements for planners – for example, by posting an entry on the NDIS • there are planning guidelines urgently
Providers page on the NDIS portal – these entries developed for the inclusion of psychology in plan have been removed by NDIS staff without the development, especially for complex cases
permission of the author of that post • the bases on which planners can reject participant
• NDIS staff have a poor grasp of the challenges requests and provider recommendations for
that face practitioners outside of provider psychology interventions are open to scrutiny and organisations and the pressures upon individual reviews are conducted efficiently
practitioners. • the planning review process is streamlined, so
that participants are provided with timely and It is important that the NDIS establishes appropriate responsive plans and plans reviews and
consultation mechanisms not only with participants • professional organisations are partnered with
(which the APS recognises as fundamental to by the NDIS to help drive change in the planning the proper operation of the Scheme) and health process via targeted programs of education and providers, but also other stakeholders, such as the training for planners. APS, at both peak representative and day-to-day levels of communication, so that early advice is sought from providers in a collaborative top-down Recommendations and bottom-up manner. The development of the Workforce Plan discussed in Term of Reference (d) The APS recommends that the Australian provides an excellent opportunity for demonstrating Government takes the necessary steps to a change of approach. ensure that the NDIA and NDIS act to: The role of Planners 11. Improve the quality of communications with practitioners, industry representatives The successful operation of the NDIS depends on and peak professional bodies. central planning that attends to the functioning and wellbeing of participants and their choice and control 12. Review the role of NDIS planners for in decision-making about what will be included in their impact on the NDIS workforce and their NDIS plan(s). However, the need for central the availability and quality of service planning can result in a variety of issues for the delivery through the NDIS Quality and participant and practitioner as it impedes progress Safeguards Commission. and creates roadblocks in the delivery of care. When this occurs, practitioners lose trust and can become disillusioned and participants’ aspirations are thwarted.
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Summary
The APS again thanks the Joint Standing Committee for the opportunity to submit to this Inquiry. This submission raises various important areas of consideration for the Committee’s review. The APS seeks to convey to the Committee that several of the observations made and the associated recommendations relate to issues that have been brought to the attention of the NDIA and NDIS before via a range of channels. The APS calls for government action on each issue identified and the propositions made. It does so on the basis that now is the time for action.
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References
DHHS (2020) Allied health capability framework: Victorian Government https://providers.dhhs.vic.gov.au/workforce-capability-framework-implementation
Littlefield, L. & Roufeil, L. (2015). APS Response: Proposal for a National Disability Insurance Scheme Quality & Safeguarding Framework. APS: Melbourne. DOI 30/04/2015.
McHugh, T (2019). APS Submission to the Royal Commission into Victoria’s Mental Health System APA: Melbourne. https://www.psychology.org.au/getmedia/d809397b-fa55-4e2d-9801-c72be582aaa0/19APS-Victorian-Royal-Commision.pdf
McHugh, T., Clarke, J. & Mundy, G. (2019). APS Response: Joint Standing Committee on the National Disability Insurance Scheme: NDIS Planning. APS: Melbourne. DOI 09/2019.
Meadows, G., Brophy, L., Shawyer, F., Enticott, J. C., Fossey, E., Thornton, C. D., … & Slade, M. (2019). REFOCUS-PULSAR recovery oriented practice training in specialist mental health care: a stepped-wedge cluster randomised controlled trial. The Lancet Psychiatry, 6(2), 103-114.
NDIS (2020). Growing the NDIS Market and Workforce: Based on Commonwealth of Australia (Department of Social Services) data. https://www.dss.gov.au/sites/default/files/documents/03_2019/220319-ndis-market-and-workforce-strategyacc-ij5665.pdf
Media Release. NDIS Workforce Funding. The Hon Stuart Robert MP. https://ministers.dss.gov.au/media-releases/5036
Roufeil, L. (2017). APS Response: National Disability Insurance Scheme (NDIS) Costs: Productivity Commission Issues Paper, February
- APS: Melbourne. DOI 23/03/2017. Roufeil, L. & Li, B. (2017). APS Response: Provision of services for people with psychosocial disabilities related to mental health conditions under the National Disability Insurance Scheme. APS: Melbourne. DOI 02/2017.
Roufeil, L. & McHugh, T. (2018). APS Response: Inquiry into the Implementation of the National Disability Insurance Scheme and the Provision of Disability Service. APS: Melbourne. DOI 26/09/2018.
Sabin-Farrell, R., & Turpin, G. (2003). Vicarious traumatization: implications for the mental health of health workers?. Clinical psychology review, 23(3), 449-480.
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APSAPSResponseResponsetotoJointJointStandingStandingCommitteeCommitteeononthetheNationalNationalDisabilityDisabilityInsuranceInsuranceScheme:Scheme:NDISNDISWorkforceWorkforce
Appendix
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Appendix
APS Member comments about the I am very concerned about what is being told to cost-shifting to Medicare clients by NDIS planner about psychology and how it should be funded. Many clients would not be able
• I attended a meeting with my brother and his to advocate for themselves very well nor would they
primary support worker funded by the NDIS funds. have the knowledge or professional background I did not introduce myself as a psychologist nor was that I have and would likely just accept what they anything said during the meeting that indicated are being told.
my profession, as I was attending as my brother’s • I have a young client who was referred to me for
endorsed plan nominee and at that stage, I was management of anxiety and depression associated self-managing his funds. with high functioning autism … but the planner When I raised the issue of funding for psychological refused to include psychological services … [and it] services for him the planners response was so has been difficult to achieve good clinical outcomes prompt and delivered so authoritatively that I had because the 10 x 50 minute sessions under no doubt that it was established policy, albeit a Medicare are inadequate given the client’s disability policy that I was confident was incorrect, in which and the client has insufficient funds to extend the the assessors had been well drilled. That response number of sessions. The mental health issues are was, “Have you a Mental Health Care Plan for now impacting on the client’s level of functioning B?” . I indicated we didn’t and said that it was my and community involvement. understanding that Medicare was not intended nor appropriate for the psychological outcomes my Member comments about the cost and brother required. impact of Third-Party Verification She indicated that he wouldn’t get weekly or Having to go through a very costly audit which means fortnightly funding for psychological services I will not be renewing my NDIS registration
under the NDIS and we should get a MHCP. She • As a sole practitioner I deemed the requirement
further stated you might get monthly funding for way too onerous and the auditing process psychology. Given the assessor’s confidence in her too expensive to complete (especially as NDIS advice, there seemed to be no point in discussing it participants make up a relatively small part of my further with her. case load). I did not renew my registration
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We were registered as providers and we have now When I raised the issue of other recommendations unregistered due to the auditing requirements in reports provided for example; physical training being unmanageable for a sole practitioner clinic. for him, the assessor asserted a similar theme to
• The difficult and expensive process of maintaining that of the question of psychology sessions; i.e.,
registration status as an NDIS registered provider. he wouldn’t get weekly funding for an exercise (I was registered with them until Feb 2020 when it physiologist and would likely only get 4 sessions ran out. I did not re-register due to the exorbitant approved to develop the program that would then costs of preparing for audit, etc.). have to be carried out with him by others.
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Openness of the audit process, particularly the costs She stated again, “you can get a Medicare referral involved. These are significant and could be termed for that too”. I replied that from my understanding crippling for a small Psychology practice.
the Chronic Diseases Medicare (EPC) referral only • I used to be registered with the NDIA but the audit
gave 5 sessions and did not pay the whole fee for process has made it unworkable. Why would I pay any service used so it was unlikely to go very far for thousands of $$ to get registered for one or two clients?
his needs. The planner then stated that we wouldn’t • The audit required to remain a registered provider
receive all of what was requested and would have is extremely onerous and expensive and for this to prioritise what we used it on. reason after April 2020 I do not plan to remain
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registered with the NDIS one day to go through the policies and procedures
• It became apparent that the auditing process and explain how you interact with clients and
would cost more than the entire fees of service conduct your work). I have several issues with my provided to clients of the NDIS I reluctantly vulnerable client group being asked to interact discontinued the process. As they are mostly directly with the auditor. children with autism spectrum disorder and the The audit process involves checking that you have a work involves long hours of communication with range of policies and procedures in place – to ensure the school, other providers, teachers and parents, you work according to the NDIS Practice Standards, but the paperwork hours (no fee) far exceed therapy there is no assessment of clinical skills. hours, and together with the cost of auditing it has made seeing clients of the NDIS an act of charity At every opportunity during the audit process I and not sustainable for a small business have directed the auditor to the existing Code of
• They now want me to pay for my own audit, by Conduct and APS suite of policies that I adhere to as
their own auditors with no information about a registered psychologist. I also refer to these in my how much it will cost. They will de register me in self-developed policies and procedures. I estimate the December 2020 if I don’t comply. It’s not worth the I have self-developed approximately 20 policies and money so I won’t comply. procedures especially to satisfy the NDIS registration
• I am abandoning my NDIS registration due to the requirements.
expensive annual audit costs.
As a registered psychologist, who has provided • I am a small business provider and these expenses
specialist behaviour support since 1995, it seems are not viable.
amazing that no credit is given for this in the • I have consequently knocked back several NDIS
registration / audit requirements. It seems a range referrals
of unqualified people are being allowed to register • The NDIS Commission audit process was too
as providers of specialist behaviour support, or be expensive and burdensome. As such, I ceased employed by people / organisations under their providing Specialist Behaviour Management Specialist Behaviour Support registration. and Early Childhood Support and only provide
• We are likely to remove our registration next year therapeutic support
because the cost of audit is well above what is • I am registered for psychological therapy until
feasible for a small practice. March, when I shall no longer be registered as the audit and process involved is too time consuming and expensive for a sole practitioner. Similarly, despite decades of behaviour intervention work, I was unable to register with the NDIA due to onerous requirements.
- The time and cost involved to undergo the audit process are excessive. For a 3-year audit cycle, I need to pay approximately $16000, and this does not include the time spent preparing (i.e., creating, reviewing and updating policies and procedures, contacting clients to ensure some can be available for direct contact with the auditor, and being available to sit with the auditor for a minimum of
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