Submission to the
Joint Standing Committee of the NDIS
4 June 2020
Contents
Contents ……………………………………………………………………………………………………………………………………. 2
- Introduction ……………………………………………………………………………………………………………………….. 3
- Recommendations ……………………………………………………………………………………………………………. 4
- Rural allied health workforce and services – short supply and high need ……………………….. 5
- A strategic approach to rural and remote NDIS workforce development ………………………. 6
- Addressing the Terms of Reference ………………………………………………………………………………….. 7 a) current size and composition of the NDIS workforce and projections at full scheme ….. 8 A coherent and comprehensive rural and remote allied health workforce strategy is needed ……………………………………………………………………………………………………………………………. 11 NDIS staff: understanding of participant need and allied health …………………………………… 13
A national allied health workforce dataset ……………………………………………………………………. 14
b) challenges in attracting and retaining the NDIS workforce, particularly in regional and remote communities ……………………………………………………………………………………………………………. 15
Rural and remote allied health service and workforce viability ……………………………………… 15
The National Rural Health Commissioner’s report on allied health access and distribution …………………………………………………………………………………………………………………………………………. 17
The Allied Health Rural Generalist Pathway (AHRGP) - workforce development initiatives …………………………………………………………………………………………………………………………………………. 17
c) the role of Commonwealth Government policy in influencing the remuneration, conditions, working environment (including Workplace Health and Safety), career mobility and training needs of the NDIS workforce ………………………………………………………………………….. 19
d) the role of State, Territory, Commonwealth Governments in providing and implementing a coordinated strategic workforce development plan for the NDIS workforce; ……………………………………………………………………………………………………………………………. 20
e) the interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care; ……………………………………………………………………………………….. 21
f) the opportunities available to, and challenges experienced by, people with disability currently employed, or wanting to be employed, within the NDIS workforce; ………………….. 23
g) any other matters. ……………………………………………………………………………………………………….. 23 Attachment A: Joint Standing Committee (JSC) on the NDIS – selected Recommendations to improve allied health workforce and service capacity in rural and remote Australia ….. 25
Attachment B: Allied Health Workforce Data ……………………………………………………………………. 27
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- Introduction Thank you for the opportunity to provide input to the Joint Standing Committee inquiry on the NDIS Workforce. We provide this submission on behalf of the members of Services for Australian Rural and Remote Allied Health (SARRAH).
SARRAH is the peak body representing rural and remote allied health professionals (AHPs) working in the public and private sector, across health, disability, aged care and other settings. SARRAH was established in 1995 and advocates on behalf of rural and remote Australian communities in order for them to have access to allied health services that support equitable and sustainable health and well-being. AHPs are tertiary qualified health professionals who apply their clinical skills to diagnose, assess, treat, manage and prevent illness and injury and support people with disability1.
The primary focus of SARRAHs submission is the allied health workforce, specifically those providing services in rural and remote Australia.
Allied health professionals provide services to people with a disability, their families and others to achieve goals in their life, including daily living, social and community participation, work, leisure, learning and relationships.
SARRAH maintains that every Australian should have access to equitable health and disability services wherever they live and that allied health services are fundamental to the well-being of all Australians.
SARRAH is a strong supporter of the NDIS and its focus on providing individualised support for participants with informed choice and control over their lives. Allied health professionals in rural and remote areas have been actively engaged, trying to facilitate improvements in design and implementation of the scheme to support participants as we move to full roll out.
SARRAH welcomes the scope of the Joint Standing Committee’s remit - considering the implementation, performance and governance of the NDIS, and the focus of this inquiry into NDIS Workforce. SARRAH is committed to promoting allied health and related workforce development, distribution and capacity to enable equitable access for NDIS participants to the services they need. For this to occur the Scheme must be built around effectiveness and long-term sustainability, which means having viable services to deliver it.
1 There is no hard and fast definition that is universally accepted. However, while the term is not rigid and reflects the evolving nature of health and related therapeutic knowledge, treatment and skills development rather than fundamental questions of value, it is also based on recognised health-related scientific and associated knowledge and practice capability. The Australian Health Leadership Forum (AAHLF) describes allied health as Allied Health Professionals are qualified to apply their skills to retain, restore or gain optimal physical, sensory, psychological, cognitive, social and cultural function of clients, groups and populations. Allied Health Professionals hold nationally accredited tertiary qualifications (of at least Australian Qualifications Framework Level 7 or equivalent), enabling eligibility for membership of their national self-regulating professional association or registration with their national board. https://aahlf.com/what-is-allied-health/. Among the defining features of allied health is the application of specialist, recognised knowledge and skills and an emphasis on person-centred and collaborative, multi-disciplinary / team-based care. Hence, while there is a generally a core group of over 20 separate professions that are generally recognised as allied health (including but not exclusively those variously recognised through the NDIS and MBS) with several other professions that are authorised to practice in Australia but are not necessarily recognised by all professional, sector or regulatory bodies as coming under the allied health” umbrella.
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- Recommendations SARRAH makes the following Recommendations. They are required to deliver a skilled and sustainable allied health workforce and the necessary access and service capacity for NDIS participants and communities across Australia, including rural and remote Australia.
i. Ensure the Work of the Joint Standing Committee (JSC) coordinates with and informs both the: NDIS Workforce Development Plan and the
National Rural Health Commissioner’s work on Rural Allied Health Quality, Access and
Distribution: Options for Commonwealth Government Policy Reform and Investment
to ensure allied health workforce and service capacity in rural and remote Australia is addressed strategically and systemically.
ii. The JSC make representations to the Department of Social Services to ensure broad and in-depth consultation with stakeholders informs final the NDIS Workforce Development Plan and that the consultations provide ample opportunity for input by small rural and remote allied health practices, service providers and their representatives consumer and community representatives – especially where services have been lacking / missed and Aboriginal and Torres Strait Islander workforce, organisation and community representatives. iii. The JSC consider referring the matter of allied health workforce mal-distribution and the implications to service access for Australians living in rural and remote Australia, including NDIS participants and potentially eligible people, to the National Cabinet. Further, that the JSC recommend to the National Cabinet that the scope of their inquiry include a cross-portfolio, cross-sector and intra-Governmental review of allied health service capacity in rural and remote Australia with a view to enabling workforce distribution, sustainability and growth. That the review also: assess of current and potential NDIS eligible populations, service demand, location and capacity of crucial workforce and supports be commissioned, informed by participant profiles, thorough assessments and participant preferences, and assess whether payment arrangements and structures as apply in rural and remote service locations require further structural change or adjustment to facilitate access equivalent to that achieved in metropolitan settings. iv. That a review be commissioned to assess: the extent to which NDIS expenditure has been directed to and succeeded in optimising participant outcomes and independence; and upheld the insurance-based principles of reducing future risk and supporting Scheme sustainability; and that such a review compare performance to date with assumptions and cost estimates used at the commencement of the Scheme, including whether: interventions to enable individual capacity-building and independence have been adequate and service and workforce gaps have impeded participant engagement and outcomes, with specific consideration of participants living in rural and remote Australia, among others.
v. That the NDIA provide more detailed and up-to-date information about work being undertaken by the NDIA on Thin Markets (including trials) be provided publicly and that the NDIA support a substantial stakeholder engagement strategy to enable ongoing input and participation.
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vi. That the JSC: note the lack of a current or complete allied health workforce data and the limitations this places on effective workforce planning and investment; and recommend that development of a national allied health workforce data be prioritised by governments nationally. vii. That the JSC note and support calls for the establishment of a Commonwealth Chief Allied Health Officer (CAHO), to help address system-wide allied health workforce concerns, such as those raised in this submission. viii. That the JSC support the further expansion of the Allied Health Rural Generalist Pathway (AHRGP) as a means of increasing the supply and capacity, recruitment and retention of allied health professionals in rural and remote Australia. ix. That the JSC support cross-government action to better utilise vocational training systems to build the Allied Health Assistant (Certificate IV) workforce, with a strong focus on disability services, while enabling career pathways and increased local service capacity across a variety of settings.
x. That the JSC refer the need to address the mal-distribution and shortage of the allied health workforce to National Cabinet for oversight. xi. That the JSC consider and/or recommend that work be conducted to inform and develop an implementation plan to increase the number and proportion of people with disability, including NDIS participants, working in and with the Scheme; including all levels and roles, including allied health clinical and service delivery roles. xii. That, in the recovery and future preparedness phase of the COVID19 response, jobs growth in the NDIS and other elements of the health and social assistance sector be targeted by National Cabinet as a priority, especially in rural and remote Australia, where service demand is unmet, demand is growing and the prospects for skilled and sustainable employment is strong.
- Rural allied health workforce and services – short supply and high need The mal-distribution of allied health professionals in Australia is severe, long-standing and highly metro-centric. Workforce distribution is significantly worse than for either the nursing workforce or the GP and hospital-based medical workforce. Many factors contribute to this situation. However, notable issues include the comparative low number of publicly funded positions (as remoteness increases) and the inadequacy of service subsidy arrangements that enable viable private and community-based practice in lower population centres. Notwithstanding some of the issues raised in this submission, the NDIS is vital and its introduction has improved the potential to address these underlying allied health service and workforce distribution challenges.
As this submission argues, many of the factors that constrain allied health workforce and service distribution and growth in rural and remote Australia are systemic. The NDIS has helped to improve the viability of rural allied health practice and service provision in many cases, but not sufficiently to enable substantial redistribution of the workforce into areas of major need or to provide assurance of service to NDIS participants and potential participants.
Chronic shortages in allied health workforce and services in rural and remote Australia preceded the NDIS, had been apparent for at least a decade, as highlighted in multiple review processes and reports. The NDIS was therefore rolled out into “thin markets” which lacked not only the capacity to service many NDIA participant needs, but to provide the
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baseline allied health services required to maintain health and wellbeing or to recover well from illness and accident.
- A strategic approach to rural and remote NDIS workforce development Addressing NDIS allied health service and workforce capacity issues in rural and remote Australia requires a specific rural and remote response. It must involve coordinating and enabling workforce and service capacity development and sustainability across all service sectors in a community where allied health services are required. Ideally, local workforce development should be an inherent part of this approach, and would be enabled using pathways approaches that leverage and, where required, supplement existing VET and university training courses and infrastructure.
Fortunately, there are several national policy review and development processes underway which would also contribute to addressing these long-standing concerns. Two which must address systemic issues, and inform strategies to build the rural and remote allied health and associated workforce fundamentally are:
The current policy and implementation development process being undertaken by
the National Rural Health Commissioner (NRHC) into Rural Allied Health Quality,
Access and Distribution: Options for Commonwealth Government Policy Reform and
Investment;
o The Commissioner’s report and recommendations are due to be provided to
the Minister for Regional Health, Regional Communications and Local
Government, the Hon Mark Coulton MP, by the end of June 2020; and
The development of a National Workforce Plan for the NDIS through the Department of Social Services (DSS), working with the states and territory disability and skills officials. We understand the Plan was to be provided to the Disability Reform Council under COAG for consideration in the next few months, however these plans will have been impacted by the decision to extend the National Cabinet and related arrangements.
o Development of a national workforce plan presents a crucial opportunity to address key issues of concern to the Joint Standing Committee and as outlined in this submission. o SARRAH is aware of the consultation process to develop the Plan and have had some, ad hoc, involvement in the consultation. SARRAH believes the process must be as open, extensive and actively engaging of stakeholders as possible. We believe some important groups have not been represented adequately in NDIS decisions to date or to contribute to the Plan during its development. Given the fundamental importance of workforce to the NDIS, it is vital that stakeholders with insight to existing NDIS shortfalls and where the Scheme continues to struggle, have substantive input to the Plan.
Other areas of policy priority which require improved allied health and related workforce and service capacity in rural and remote Australia, include:
The COVID19 response and future preparedness: Strengthening the health capacity, resilience and preparedness of rural and remote communities for future risks and events;
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Improving Aged services access and quality - to reduce avoidable deterioration, support healthier ageing, resilience and independence, as highlighted by the Aged
Care Royal Commission; and
Closing the Gap in Aboriginal and Torres Strait Islander disadvantage, in which appropriate culturally safe and responsive NDIS service, training and workforce elements could make a substantial and tangible difference.
The findings and recommendations of these processes often impact the same people. They should be assessed carefully in their own right and together – as complementary interactive parts of a coordinated service system. The Joint Standing Committee’s Inquiry into the NDIS Workforce could be a catalyst to improve the coherence, impact and sustainability of the NDIS and other service systems. The issue could be raised as a priority for early and substantive oversight by the National Cabinet.
Current arrangements have been criticised for being siloed, program- rather than person- or patient- centric, inflexible and lacking coordination. At a local level the situation complicates and presents barriers to access and service impact. Crucially, these factors also undermine capacity for local services to provide patient or client-focussed care or to operate on a sustainable basis even when several programs might be available. If coordinated better, these programs would help enable growth or continuation of viable services - which should be available and accessible to the 7 million Australians living in rural and remote Australia, including NDIS participants.
Australia needs better coordinated cross-sector and cross-system allied health and assistant workforce development, distribution and funding strategies than has been facilitated to date. SARRAH urges the Joint Standing Committee to encourage a deliberate process of cross portfolio, cross-sector and intra-Governmental review of allied health service capacity in rural and remote Australia that builds on the work of the NRHC and others and enables capacity and workforce growth for allied health services in rural and remote Australia.
Put simply, the NDIS will not deliver on its objectives without the right mix of workforce where it is needed. That is not presently the case for much of rural and remote Australia and it undermines the purpose, impact and sustainability of the Scheme.
- Addressing the Terms of Reference The Terms of Reference for the inquiry are to inquire and report on the workforce providing NDIS services (the NDIS workforce), with particular reference to:
a. the current size and composition of the NDIS workforce and projections at full scheme;
b. challenges in attracting and retaining the NDIS workforce, particularly in regional and remote communities;
c. the role of Commonwealth Government policy in influencing the remuneration, conditions, working environment (including Workplace Health and Safety), career mobility and training needs of the NDIS workforce;
d. the role of State, Territory, Commonwealth Governments in providing and implementing a coordinated strategic workforce development plan for the NDIS workforce;
e. the interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care;
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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 In addition to the discussion of key issues in the introduction to this submission, we offer SARRAHs perspective and specific comments against each of the terms of reference.
a) current size and composition of the NDIS workforce and projections at full scheme Our submission focuses on the allied health workforce primarily as a provider of essential services for many NDIS participants.
There are currently around 250,0002 university-trained allied health professionals in Australia.
Allied health professionals (AHPs) specialise in working with people to develop, retain and/or recover their individual capacity. Inability to access these services reduces the NDIS participants’ opportunities to optimise their potential social, economic or other engagement.
Allied health professions are in high demand and among the fastest growing professions.
The Australian Government’s National Health Workforce Data shows that for the period 2015 2018 allied health professions were the fasting growing registered professions for professions regulated by the Australian Health Practitioner Regulation Agency (Ahpra). Allied health professions, and Aboriginal and Torres Strait Islander Health Practitioners, were the fastest five professions and other allied health professions also showed strong growth.
Further, the Health and Social Assistance sector (which includes allied health professionals (AHPs)) has been the lead sector of employment growth for the past decade. Projections over the next five years, show this demand trend will only strengthen. This is being driven in part by demand associated with the NDIS. AHPs are also among the fastest growing and most in demand professions within the sector3, with demand for most AHP professions projected to increase by between 15 and 40 per cent. Consistent with this, health professions are the fastest growing areas of university study nationally and have been for the past decade at least4: allied health disciplines are among the fastest growing.
However, AHPs are the least evenly distributed of the health workforce categories.
The Australian Government’s National Health Workforce Dataset shows5 the geographic
distribution of allied health professions regulated by Ahpra is heavily skewed toward major
2 Due to the absence of a national allied health dataset it is not possible to provide definitive allied health workforce estimates. This issue is addressed later in the body of the submission. 3 See https://lmip.gov.au/default.aspx?LMIP/GainInsights/EmploymentProjections 4See https://www.education.gov.au/higher-education-statistics 5 https://hwd.health.gov.au/publications.html#alliedh17 Note – there is no reliable data on the number or location of around half of all allied health professions in Australia. Reliable data is only available for professions registered under the National Registration and Accreditation Scheme (NRAS) for health professions, and so excludes professions such as speech pathologists, audiologists, dieticians, social workers and exercise physiologists to name a few.
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population centres6, where financially sustainable and professionally supported practice is more viable under present policy and program settings.
The following table illustrates the geographic distribution and practitioner to population ratios of a selection of allied health professions. The table uses 2016 data, however later data shows the same distribution pattern. It is important to note that the distribution of allied health professions outside of major population centres is considerably worse than for nurses and midwives and worse than for medical practitioners.
Table reproduced from Strategies for increasing allied health recruitment and retention in Australia: A
Rapid Review. Services for Australian Rural and Remote Allied Health (SARRAH, 2019).7
Given the importance of allied health in providing therapeutic and other services for people living with disability, the mal-distribution of this workforce poses major service access, quality and service impact challenges for the NDIS and participants.
Skilled workforce shortages have inhibited the roll-out and success of the NDIS in some areas. The size and capacity of the pre-NDIS allied health and related service workforce appears to have been seriously overestimated, especially in areas that continue to struggle to assess and meet participant needs.
The following table (again, reproduced from Strategies for increasing allied health recruitment and retention in Australia: A Rapid Review. Services for Australian Rural and Remote Allied
6 Ibid – drawn from the 2017 Factsheets - using the latest available data. 7 Page 10. Battye, K., Roufeil, L., Edwards, M., Hardaker, L., Janssen, T., Wilkins, R. (2019). Strategies for increasing allied health recruitment and retention in Australia: A Rapid Review. Services for Australian Rural and Remote Allied Health (SARRAH). https://sarrah.org.au/publication/strategies-increasing-allied-health-recruitment-and-retention-rural-australia
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Health (page 11) provides a detailed list of allied health professionals and their distribution across NSW. (SARRAH is aware of no information showing a significant shift in this distribution pattern since 2016).
The effectiveness of the Scheme relies fundamentally on the availability of a diverse workforce able to deliver interventions that:
At an individual participant level, will help enable optimal participant engagement and outcomes; At a system or Scheme level, will deliver the impacts, operational effectiveness and longer-term budgetary implications on which the NDIS was established; and At a service level, will enable viable ongoing services to be established and/or maintained so that individual and system objectives are met.
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At this stage of NDIS implementation, a detailed re-assessment of potential population eligibility, service demand, the location and capacity of crucial workforce and service and workforce needs, matched to participant profiles and preferences would be highly valued. This would contribute to an informed assessment of whether the Scheme’s objectives are being met and the prospects for its future success and sustainability.
The durability of the Scheme depends on workforce driven interventions to enable individual capacity-building. Yet major workforce gaps and structural impediments to facilitating services to meet the needs NDIS eligible (and potential) participants living in rural and remote Australia persist. These aspects of the Scheme do not appear to have been planned for or prioritised adequately to date. The Joint Standing Committee may wish to consider that as part of the current Inquiry.
A coherent and comprehensive rural and remote allied health workforce strategy is needed
SARRAH commends the Joint Standing Committee (JSC) for addressing this matter through Recommendation 9 of the Inquiry into market readiness for provision if services under the NDIS: The committee recommends that DSS develop and publically release a national strategy to develop the disability workforce8.
We also note that the Department of Social Services is now managing, through a consultancy, development of a National NDIS Workforce Plan. We understand this will be put to the (COAG) Disability Reform Council for consideration in mid-2020.
Development of the Plan has included a relatively targeted consultation process. SARRAH has been involved on an ad hoc basis, at the invitation of DSS. With the emergence of COVID19 and related events we expect consultation around the Plan may have been interrupted. Nonetheless, SARRAH will seek stronger and more consistent engagement with the process and advocate around issues raised in this submission, with a strong focus on workforce development and services for currently under-serviced communities.
SARRAH is keen to ensure the draft Plan and any recommendations reflect a deep understanding of issues constraining workforce development and supply in areas where current NDIS service capacity and access are least developed: namely rural and remote Australia and in many Aboriginal and Torres Strait Islander communities.
National NDIS Workforce Plan (source DSS website 14 May 2020)
To meet the needs of people with disability in Australia and fully realise the benefits of the National Disability Insurance Scheme (NDIS), the NDIS workforce will need to grow significantly.
While governments and industry have invested considerably in the NDIS workforce, it is clear that a cohesive, nationally agreed approach to workforce development is needed to deliver the size and capability of the workforce required.
The Department of Social Services, in partnership with the Commonwealth, states and territories, is developing a National NDIS Workforce Plan. This action-oriented plan will assist governments to maximise effort and guide investment to support the NDIS workforce, which includes support workers, allied health professionals and others.
The National NDIS Workforce Plan will capitalise on the work already undertaken by governments and industry. https://engage.dss.gov.au/national-ndis-workforce-plan/
8 Page 9. Australian Government response to the Joint Standing Committee on the National Disability Insurance Scheme report: Progress Report, 2019. (Government response issued February 2020.)
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Further, SARRAH is concerned that the National NDIS Workforce Plan, essential if these issues are to be addressed, is robust, coherent, well informed and draws together what is required to build capacity. The Plan must enhance service access, quality and service sustainability for communities where this has proven most challenging.
SARRAH believes the development and consultation process must deliver a draft Plan that:
Recognises program arrangements designed for the majority of people and circumstances often do not translate effectively (in terms of impact, equity, operational or cost efficiency) to smaller, more remote or other communities. This is a fundamental design issue and must be treated as such; Reflects the specific concerns and issues of stakeholders who may be a relatively small and/or under-represented population in consultation processes (e.g. small rurally-based providers and providers who have decided against or withdrawn from NDIS work, despite community need). These issues need to be assessed, prioritised and responded to appropriately; Avoids introducing or reinforcing arrangements that apply equally across the system, but deliver more onerous service requirements and/or impede participant access and outcomes in different locations and circumstances; and Addresses underlying causal factors (beyond the Scheme) that have constrained local workforce and service capacity development to date.
In line with the fundamental principles of any insurance-based Scheme, funding must be directed to optimise participant independence and to contain potential outlays while reducing risk. It is not clear that these principles have been prioritised in NDIS workforce engagement and development to date.
SARRAH acknowledges the NDIA has been adapting and responding to issues in a very challenging situations. Several developments and initiatives demonstrate the Scheme is evolving responsively: including rural and remote pricing differentials, targeted plans (such as the Rural and Remote Strategy) and the development of initiatives such as the Thin Markets trials, with which SARRAH and other stakeholders has sought and would welcome the opportunity to engage and contribute.
Nonetheless, operational tensions remain, that could be ameliorated by a well-formed workforce development strategy. These include:
Enabling well informed assessment processes and decision-making backed by appropriate service availability; Delivering adequate services to low population areas within a reasonable and sustainable cost, while facilitating participant choice and control; Quality of care, appropriateness of service allocation and value for money - for the participants and the Scheme.
Service capacity is inseparable from workforce capacity. They are fundamental to enabling market-driven or other service responses, facilitating participant efficacy and choice and supporting Scheme sustainability long-term. Coherent, local workforce development and support structures are needed and the scale of the challenge nationally suggests these should be built within an overarching national workforce development framework.
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NDIS staff: understanding of participant need and allied health
SARRAH also commends the JSC for addressing this question with Recommendation 9 of the Inquiry into NDIS Planning, being
The committee recommends that the National Disability insurance agency (NDIA) ensure that additional training and skills development is provided to all persons involved in the planning process (particularly NDIA officers and LACs), to ensure that all such persons: are familiar with allied health expertise. (among other points)
Lack of knowledge among staff, including NDIS planners and participants about allied health is a major concern and SARRAH welcomed the JSC’s recommendation. SARRAH would welcome and will seek information from the NDIA about how this recommendation is being acted on.
Similarly, informed knowledge and understanding of rural and remote service environments and issues is crucial, not only for Planners and LACs but also NDIA staff in central policy and operational-decision making roles.
As SARRAH argued in our submission to the JSC Inquiry into NDIS Planning:
“Undoubtedly the availability or otherwise of specific allied health services impact the content of some plans when the availability of services do not match an objective and informed appraisal of the participants’ aspirations and needs. This is a separate issue to the knowledge and skills of the planner, and may be influenced more by considerations of what services are actually available rather than whether they are optimal, for example.
The relationship between the quality and appropriateness of NDIS plans for participants in rural and remote Australia and the limitations of service knowledge and availability is complex and highly iterative. Plans may include allied health services that are not accessible or available in the participants’ community or region – so go unused. Planners and participants may have no awareness of interventions that could be of great benefit to the participant – so are missed. Planners may be aware of beneficial services but not suggest or include them in a plan because they are not aware of suitable service provider for the participant to access.
A major factor contributing to plan (and as importantly) service gaps is the shortage of allied health professionals and service capacity in rural and remote Australia….”9
SARRAH believes that workers with allied health assistant qualifications, for example, would be well-placed for LAC and planner roles given their specific understanding of the benefits of allied health services.
While SARRAH has commended these Recommendations of the JSC specifically, we also appreciate they should be considered and responded to as a whole. We note, the Government has provided responses to the Recommendations, with many supported. However, those responses have not always indicated the urgency of action required, the need to work strategically and systematically, and in some cases that the implications of further action or inaction has been taken on board.
The Committee has made several other Recommendations which SARRAH believe warrant continued and substantive consideration, as elements contributing to NDIS workforce development, capacity and sustainability. These are identified at Attachment A.
9 Submission 72: https://www.aph.gov.au/Parliamentary_Business/Committees/Joint/National_Disability_Insurance_Scheme/NDISPlanning/Submissions
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A national allied health workforce dataset
A major impediment to strategic and practical allied health workforce planning and development is the lack of allied health workforce data.
Currently there is no comprehensive, up-to-date database describing the allied health workforce in Australia and no clear responsibility for mapping the allied health workforce at national, state and territory or more local levels.
A core dataset, based on annual registration data, exists for health professions registered through the Australian Health Practitioner Regulation Agency (Ahpra) under the National Registration and Accreditation Scheme (NRAS). This is the main source of health workforce data in Australia.
The Ahpra data excludes many allied health and associated professions eligible to deliver NDIS services. As the Australian Institute of Health and Welfare among others have noted, there is little workforce information available for professions such as dietitians, speech pathologists, audiologist, sonographers, social workers and prosthetists among others.
This too, has been a longstanding issue of concern to the allied health sector, as was noted in a major review of the Australian Government’s health workforce programs delivered in 2013 (the Mason Review10), which noted
“The consultations as part of this review highlighted the frustration of allied health peak bodies at the lack of allied health workforce data and priority of data analysis. There is limited data available on the allied health disciplines, especially those who fall out of the registration scheme of NRAS.”(page 311)
Health Workforce Australia (HWAs) was in the process building these data assets when it was disbanded in 2014. Some of HWAs functions were transferred to the Department of Health. Little has been done to address the shortfall since.
The lack of a comprehensive national data base covering all health and related workforce sectors and professions severely limits the effectiveness of workforce planning and investment; by the Commonwealth, states/territories and local government, the non government sector, and private providers. It compromises the capacities of stakeholders to plan and develop services capable of meeting the service needs of Australians living in many parts of the country.
The National Rural Health Commissioner has taken up the issue in his recent interim report to the Minister for Rural Health on policy options to improve access, distribution and quality of rural allied health services, in which he has advised of the need for exploration of
“… options to invest in the development of a comprehensive national allied health workforce dataset, which includes geographical data.” The purpose he suggests would be to “… capture, store and disseminate data and evidence required to inform allied health workforce planning and policy development.”
In the view of the Commissioner, the development of such a workforce data set warrants focused investment. Such a database would:
10 Review of Australian Government Health Workforce Programs (Australian Government, April 2013) Jennifer Mason,
Chair
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Enhance and support allied health workforce planning and development at local, regional and national levels and Improve capacity to assess the workforce capacity and delivery impact of initiatives.
Further information regarding allied health workforce data is at Attachment B.
b) challenges in attracting and retaining the NDIS workforce, particularly in regional and remote communities
Rural and remote allied health service and workforce viability
As noted above, poor access to allied health services in rural and remote Australia is a chronic issue. Many of the employment positions, supervision and professional support, income, practice and service subsidy schemes available that facilitate the distribution of other health practitioners into rural settings are either not available to or more limited for allied health professionals. This limits the viability of rural and remote allied health practitioners and services who might otherwise be available to meet community need.
Again, this has been a longstanding issue and the current difficulties in delivering allied health services for NDIS participants and others were understood and highlighted in the Mason Review of 2013 (as highlighted by the excerpt in the following text box).
Private practice allied health professionals in rural and remote practice, commonly work across multiple settings (including public and community settings). That is reality for many rural practitioners, and needs to be understood if the NDIS is going to effectively utilise and/or promote the growth of this workforce. It would be useful to conceptualise the allied health workforce in rural and remote settings at least, as allied health professionals who provide NDIS services, rather than as an NDIS workforce per se.
Service viability often means practitioners balance various service arrangements, and service (and retention) decisions have to be made around issues such as relative income potential and assurance as well as administrative and regulatory burdens associated with providing service. In this respect, NDIS service pricing may be seen as competitive or preferable, but the volume and costs associated with regulation and administration overly burdensome. For small rural practices, working across multiple service and income streams, these requirements are burdensome. SARRAH is aware of examples where these requirements have deterred practitioners from and who have ceased to provide NDIS services.
The expense of delivering services in many rural and remote settings deters establishment of private allied health services. Significant travel time and expenses associated with regional, rural and remote services are not sufficiently offset by provisions under present funding instruments to support small rural business models. The significance of these issues could be better appreciated in reflecting on the practicalities of servicing a similar population over an area of several city blocks versus an area the size of Victoria. In addition, even with the opportunities presented by the NDIS, rural and remote allied health practitioners face other service and viability challenges including, lower population income levels and private health insurance coverage which might otherwise facilitate access and service viability.
To bolster the viability of rural allied health practices, the Commonwealth might consider changes to the way services are remunerated, such as supplementary funding, infrastructure grants, loading of fee schedules based on rurality, and practice incentive payments to ensure that rural and remote clients can access allied health interventions to an equivalent level with their metropolitan counterparts. Changes of this type may be difficult to achieve quickly, however a more immediate option to improve access to allied health services for
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rural NDIS clients may be to enable participants to utilise local service providers who may not be registered with NDIS.
Issues influencing allied health rural practice decisions are described extensively in Strategies for increasing allied health recruitment and retention in Australia: A Rapid Review. Services for Australian Rural and Remote Allied Health11 referred to earlier. SARRAH was commissioned by the New South Wales (NSW) Ministry of Health to develop a paper outlining evidence that answers the question:
What strategies have been proven effective or ineffective for increasing the efficacy of allied health rural recruitment and retention in Australia?
The strongest evidence concerning recruitment of Allied Health Professionals to rural and remote practice relates to:
Rural background Curriculum that reflects rural health issue Quality rural placements.
Recruitment and retention
Recruitment of allied health practitioners is generally not problematic in metropolitan areas but in rural and especially in inland areas, there can be recruitment difficulties to long-term vacancies. While reliable data is not available at the national level, there is a well-recognised mal-distribution of allied health professionals in rural and remote areas, in both the private and public sectors.
There can often be long-term vacancies and often positions in public health will ‘disappear’ with the fiscal restraints of the public health system. This means that some rural and remote communities can have limited or no services for specific disciplines. Smaller rural and remote communities also often rely on outreach service provision from larger centres, however these services are often irregular and dependent on staffing levels at the larger centres.
Distribution
Certain health areas are likely to experience higher demand for allied health services over the coming years. For example, a significant number of allied health professionals work in the area of disability, managing clients from childhood through to adult. The recently announced National Disability Insurance Scheme (NDIS) is likely to increase demand for allied health services in this sector and this may have an impact on health services staffing.
Review of Australian Government Health Workforce Programs (Australian Government, April 2013)
Jennifer Mason, Chair – page 308
Factors that influence retention are broadly categorised as professional and organisational, social (family and personal), and financial. These are modifiable to varying extent.
Non-modifiable factors include location and community amenity, modifiable factors include: Safe and supportive work environments Career development
11 Battye, K., Roufeil, L., Edwards, M., Hardaker, L., Janssen, T., Wilkins, R. (2019). Strategies for increasing allied health recruitment and retention in Australia: A Rapid Review. Services for Australian Rural and Remote Allied Health (SARRAH). https://sarrah.org.au/publication/strategies-increasing-allied-health-recruitment-and-retention-rural-australia
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Nature of the work and outreach support Professional networks Public recognition of the role Appropriate financial incentives.
The National Rural Health Commissioner’s report on allied health access and distribution
These issues are central to the National Rural Health Commissioner’s (NRHC) report into Rural
Allied Health Quality, Access and Distribution: Options for Commonwealth Government
Policy Reform and Investment, being prepared for Ministers.
In SARRAHs view, the NRHC process is of fundamental importance and overdue. SARRAH anticipates NRHC will make strong recommendations to enable the viability and growth of allied health professional, assistant and other workforce capacity in rural and remote Australia. While the NHRC reports to the Minister for Rural Health and is focussed primarily on the health portfolio responsibilities, he has been highly cognisant of the necessary cross portfolio interests (including NDIS) associated with allied health service capacity on the ground in rural Australia. These agendas must be progressed in unison to support patient /participant focus, professional/provider workability and program, administrative and cost efficiency and effectiveness.
Improving coordination across and impact of relevant Australian Government programs is one of the key reasons SARRAH, the Australian Allied Health Leadership Forum (AAHLF), the NRHC and many others have advocated for the establishment of a Commonwealth Chief Allied Health Officer (CAHO). Such a position could be vital in assisting DSS, NDIS and other agencies to address endemic workforce concerns, such as those raised in this submission.
The Allied Health Rural Generalist Pathway (AHRGP) - workforce development initiatives
A core focus for SARRAH is to facilitate and promote development of cross-sector collaborative initiatives to deliver sustainable allied health workforce and service capacity in rural and remote Australia.
In line with that, SARRAH is working with a range of stakeholders nationally to expand and embed the Allied Health Rural Generalist Pathway (AHRGP)12. The AHRGP is a multijurisdictional workforce development initiative that aims to support the growth, sustainability and value of the rural and remote allied health workforce and the proliferation of rural generalist service models that deliver accessible, safe, effective and efficient health services for rural and remote health consumers.
The AHRGP is relevant and should be applied in providing disability and related services. Indeed, it is a central element of the formal training program and pathway and is crucial to the expansion of the model. The AHRGP which is now well established in the Queensland public health system especially, due to development and leadership undertaken by Queensland Health in conjunction with James Cook University and other stakeholders over the past decade, has immense potential to be applied across the private, community health, disability, aged care and other settings.
SARRAH, with funding allocated through the Department of Health, is working with stakeholders to facilitate an initial expansion of the AHRGP into private practice and
12 https://sarrah.org.au/ahrgp
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community health settings in rural and remote Australia: through the Allied Health Rural Generalist Workforce and Education Scheme (AHRGWES). ARGHWES is expanding the AHRG pathway into non-government allied health services, including for disability service providers. It will see local service providers with (new or existing) early career allied health professionals implement and support an AHRGP training position, with workplace grants paid to employers to support the implementation of traineeships and scholarships for trainees to cover the coursework component of the scheme.
SARRAH strongly recommends and has sought to promote awareness of the AHRGP among disability service providers, and offers support to identify training positions to improve recruitment and retention of allied health professionals in rural and remote Australia. ARGHWES includes incentives to service providers to consider training positions, including backfill support for trainees. ARGHWES was launched by Minister for Rural Health, the hon Mark Coulton MP in Dubbo in November 2019. More information on ARGHWES is available at: https://sarrah.org.au/content/ahrg-workforce-and-employment-scheme-0.
The maximum capacity for places under ARGHWES is estimated at forty places nationally. Based on the response to date, SARRAH anticipates demand for ARHGWES places will well exceed supply capacity.
In rural and remote settings and in Aboriginal and Torres Strait Islander service settings, workforce pathways are vital. They enable entry to and development in careers for local people and where university training is not a current option. SARRAH supports the development of the Allied Health Assistance (AHA) workforce and notes the introduction of fees for services delivered by AHAs is an important development in enabling AHA workforce development and growth in rural and remote Australia. The AHA workforce offers a vital and complementary workforce to enable allied health service reach, continuity of service, viability for participants together with local workforce development and employment opportunities and pathways.
AHAs “support and enhance the work of allied health professionals by undertaking duties within Allied Health practice that facilitate care (for example, administrative or support tasks related to the patient or client) and delivering components of clinical care that are necessary to the treatment episode but do not entail clinical reasoning skills”13. AHAs require supervision by an allied health professional, who would have first undertaken a comprehensive assessment of a patient, developed a care plan, and determined that the AHA has the necessary competencies to carry out elements of that care plan. However, once established, many experienced AHAs are fully able to deliver services continuing therapeutic care to participants without the immediate presence of the supervising AHP, thereby enabling increased access to and consistency of services and extending the reach of the Allied Health practice.
AHA training at VET Certificate IV level includes core and multiple elective modules that specialise in disability related service (while allowing AHAs to work across a variety of settings). They are distinct roles and complement the work of disability support workers and carers.
SARRAH has had preliminary discussions with representatives of DSS and the NDIA about expanding the AHA workforce as part of a broader strategy and will be seeking further engagement on these issues.
13 Firth, A. (2012) Delegated clinical roles of Allied Health Assistants: Final Report of the Health Education and Training
Institute (HETI) Rural Research Capacity Building Program, NSW Health
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Other opportunities exist to strengthen and build the NDIS workforce and pathways in rural and remote Australia. For example, engaging key stakeholders to explore options to:
Engage more rural allied health university in paid employment with the NDIS; and Strengthening NDIS service linkages with University Departments of Rural Health (UDRHs), which are funded through the Commonwealth-funded Rural Health Multidisciplinary Training (RHMT) program14 and tasked with contributing to the “rural health pipeline” – to enable student clinical placements, enhance disability service sector exposure, promote recruitment, career development of the existing workforce and retention strategies.
c) the role of Commonwealth Government policy in influencing the remuneration, conditions, working environment (including Workplace Health and Safety), career mobility and training needs of the NDIS workforce
Commonwealth policy and funding frameworks have an enormous impact on service supply and capacity, service distribution and location-based service limitations. That influence is most obvious when it relates directly to remuneration rates, but other factors also have profound impacts, including: the nature and extent of regulation – registration, compliance and reporting arrangements and the associated cost and administrative burden; complex and diverse policy and program parameters, including participant and provider eligibility requirements; and lack of coherence (from either a participant or provider perspective) in program arrangements to enable patient/participant coordination, continuity and effectiveness of services and care.
In February 2020, SARRAH hosted a forum in Canberra, providing an opportunity for rural and remote practitioners to discuss with and inform other stakeholders, including the Minister for Rural Health, the National Rural Health Commissioner, officials (e.g. DSS, NDIA and Health representatives) about how access to effective and sustainable allied health services might be improved in rural and remote Australia. The Forum included substantial discussion of how practitioners were or had attempted to work with the NDIS, challenges, areas of success and potential, and potential changes to better enable practice and sustainability. A summary and report of the Summit is available here.
SARRAH noted earlier in the submission that systemic issues contribute to the maldistribution of allied health workforce and services in rural and remote Australia. Those issues, within the Commonwealth’s remit to influence, include:
The proportion of total Commonwealth Health Workforce Program funding that is allocated to allied health rural workforce development, distribution and sustainability o Allied health makes up around 25 per cent of the health workforce with chronic and severe shortages in rural and remote Australia, but attracts a minute portion of Commonwealth health workforce support funding; The need for greater allied health expertise and stakeholder input to development, design and decision-making processes around Commonwealth health and related policy and programs; and Financing mechanisms and support (including the NDIS, MBS, grant funding arrangements etc.).
14 A formal review of the RHMT Program is nearing completion. The recommendations of the review and the Government’s response may support better integrated workforce development opportunities.
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The government’s role in ensuring the operational environment supports service delivery in rural and remote settings should not be underestimated, and there is considerable potential for current policy and program levers to be coordinated and leveraged differently to improve workforce and service access where they are currently in short supply.
With regard to funding levels, in many cases allied health services receive have no subsidy at all, and any cost applied is borne by the patient/participant. Where subsidies/rebates are available for allied health services, the rates of subsidy can vary greatly between Commonwealth programs, even when the same service or procedure is delivered. In this respect the service coverage and subsidy rates provided through the NDIS often compare favourably with other Commonwealth programs (including the MBS).
This issue has been highlighted recently by an example of a veteran receiving occupational therapy services through the Department of Veterans’ Affairs (DVA). The veteran raised concerns that the therapist providing services to him received considerably less than if she were to provide a similar service to an NDIS participants. This example profiled concerns about the (dis)incentives, and that would influence care provision and access decisions15.
Based on feedback from SARRAH members, we understand the viability of allied health service access in rural and remote locations may depend as much on reducing the administrative burden of NDIS registration, accreditation requirements and reporting as any other factor. Taken together with other regulatory requirements on small rural practices, this issue warrants serious consideration, including potentially by the needs
Other considerations, based on members’ advice include:
Whether all clients in remote locations might be considered complex regardless of their condition due to the additional challenges faced because of reduced access to specialist service and fewer resources available to assist them to cope with their condition; and infrastructure grants, loading of fee schedules based on rurality, or practice incentive payments to ensure that rural and remote clients can access allied health interventions to an equivalent level with their metropolitan counterparts.
d) the role of State, Territory, Commonwealth Governments in providing and implementing a coordinated strategic workforce development plan for the NDIS workforce;
The differential funding arrangements, including the absence of funding for allied health services in many cases, influences/distorts practice decisions and introduces behavioural and practice incentives that conflict with some practitioner’s sense of service and patient/client obligation.
Clearly, cross-Government (and cross-portfolio) collaboration is vital. SARRAH notes the recently announced changes to inter-governmental arrangements with the extension and expansion of the National Cabinet model to replace COAG. If the new arrangements can address fundamental difficulties with the pre-existing arrangements they will be welcome.
Without going into the complexities of COAG and related Ministerial Councils and officials committees, there are several issues that consistently challenge the delivery of policy,
15 https://www.abc.net.au/news/2020-05-22/health-workers-for-veterans-paid-less-than-ndis/12274208
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program and service impact on the ground. These are in addition to the difficulties of coordination across portfolios within any single level or sphere of government. They include:
Coordination of priorities and actions between Ministerial Councils and their support structures. For instance: o How extensively have the Disability Reform Council worked with the Health Ministers’ Council to ensure allied health and other services are or will be available to people living in rural and remote Australia? o Has the shortage of rural and remote allied health services and hence student clinical placement capacity – which is known to be an impediment to rural practice post-graduation – been a joint focus for the Health Council and the Education Council, or officials? The relative priority given to the potential and risk of cost shifting between Governments, compared with: o The net overall cost in public expenditure to deliver the outcome sought for the community; o The seamlessness or otherwise of a participant or patient journey through the health and social service systems; or o The return on investment in terms of community outcomes, future capacity and productivity, government outlays and revenues from coordinated and longer term policy objectives. The extent to which non-government stakeholder concerns and capacity are a focus during intra-government negotiations. For instance: o Recognising that around 70% of allied health practitioners operate as and work in small private businesses outside of the employment and funding structures associated with public hospital and MBS systems (as examples), is there role in delivering major programs, such as the NDIS, represented adequately in negotiations and decisions? o If other avenues of input are considered more practical, how can they be strengthened?
Fortunately, the NDIS enjoys a high degree of community, bi-partisan and intra-Government support. Consequently, there are good prospects that key and complex issues may be addressed through NDIS deliberations. Coordinated planning and commitment across the Commonwealth and States would be welcome and potentially reduce risks of cost shifting, mismatch of services to need, and enable appropriate flexibility so that available services and workforce can be applied to have greatest impact for people at the most efficient cost.
Areas of focus might include streamlining of primary health care, aged care and the NDIS service system requirements, such as registration and accreditation frameworks. For clients, eligibility assessments might also be coordinated and streamlined. This could reduce administrative burden on everyone, including allied health professionals and service managers who may be providing services to clients eligible for services in multiple streams.
e) the interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care;
Approaches that focus on the disability sector in isolation of other service needs of rural communities risk ongoing fragmentation of supports and development programs. SARRAH
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recommends service development programs targeting thin markets, especially, adopt a cross-sector focus to build capacity and gain optimal benefit from the resources invested.
Our response in relation to point b) challenges in attracting and retaining the NDIS workforce, particularly in regional and remote communities (above) outlines the key issues and opportunities with regard to workforce coordination.
SARRAH also reiterates the need for these issues to be considered and addressed in concert with the National Rural Health Commissioner’s (NRHC) report into Rural Allied Health Quality,
Access and Distribution: Options for Commonwealth Government Policy Reform and
Investment, being prepared for Ministers.
Pooled funding streams and “bundled” services hold some promise for identifying place based solutions to unmet service demands. As the NRHC has noted, regional partnerships and networks between public sector, non-government and private providers, including shared care, optimised the use of the available workforce and contributed to the delivery of more comprehensive services16. Further, “…Opportunities for integration with the NDIS, My Aged Care and other sector revenue streams could … enable greater growth in the private sector.”16 The Commissioner concludes:
“At the regional level, patient-centred service planning and coordination of public and private providers underpins access to more comprehensive and high quality services. For smaller communities, outreach and virtual consultations are critical for early intervention and continuity of care, but viable business models and an adequate staff base are essential to improve service distribution. A number of these areas have direct application to Commonwealth Department of Health policy and equally require strong engagement with jurisdictions and rural representation across the sector”.
Commonwealth agencies with an interest in improving access to allied health services in rural and remote Australia must collaborate to ensure that policies and programs are aligned in such a way as to maximise the impact for rural and remote communities. Further, disability service providers should be encouraged to collaborate with state-based health services and the private sector to pool resources in order to create viable service delivery models that meet local needs.
For Aboriginal and Torres Strait Islander communities it is crucial that local Elders, community controlled health and community service organisations, and national organisations such as Indigenous Allied Health Australia (IAHA) are involved in leading and developing strategies for service and workforce capacity that are effective, integrated and culturally safe and responsive.
Primary Health Networks are also potentially well-positioned to facilitate collaborations, drawing on their health needs assessments, mapping of local services and engagement with local providers in public, private and non-government sectors.
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f) the opportunities available to, and challenges experienced by, people with disability currently employed, or wanting to be employed, within the NDIS workforce;
As noted previously, the demand for people working in the Health and Social Assistance sector is large and growing. The range of skills and capacities required across this workforce, including AHP and AHA roles is extensive and presents opportunities for people with disability, who would in turn bring skills and capacity to a workforce in high demand.
Enabling people with disability in rural and remote Australia to gain skills, qualifications and work in this sector would support both the objectives of the Scheme and the provision of quality services in areas where they are needed.
g) any other matters. SARRAH recognises the scope of the NDIS entails major challenges and it will take time for the Scheme to mature and perform optimally. The transition will be supported by open and robust assessment, constructive feedback and iterative improvement.
There have been positive developments. SARRAH applauded NDIA amendments to enable AHAs to be rebated through the Scheme. This has enabled potential access and increase in the frequency of allied health services in rural and remote communities.
On this issue, there is also a need to ensure effective governance arrangements exist and are widely understood for services delivered by allied health assistants. Safe delegation of work to allied health assistants requires a supervising allied health professional to have first undertaken a comprehensive assessment of a patient, develop a care plan, and determine that the allied health assistant has the necessary competencies to carry out elements of that care plan. This is an important implementation issue, but one that will ensure greater coverage and access to quality services.
The potential for jobs growth in rural and remote Australia in the health and social assistance sector – across all skill levels – is enormous, but continues to attract relatively little attention as a source of skilled, productive jobs, especially in regional, rural and remote Australia.
With the Government’s focus on employment (re-)creation in the COVID19 recovery phase, this should be an area for intense development, especially as:
o The Government’s own projections indicate over 250,000 new jobs will be created (or in demand) in the next 5 years, with around 80,000 of these outside of the metropolitan centres. o There is already a shortage of this workforce and further, unmet, demand will entail pressures around reduced service quality, worse service access, increased service costs, inflationary and cost pressures, and possibly all of these. o Preliminary analysis by SARRAH suggests the severe shortages in rural and remote allied health services, may not worsening with growth not keeping pace with increases elsewhere, in some instances, may be getting worse. This would be consistent with anecdotal advice from some SARRAH members. We are continuing to examine the issue.
The experience of COVID19 has further highlighted key health and social assistance workforce shortages in rural and remote Australia. The NDIS is one of several assets that could be applied to improve the situation.
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Another issue highlighted in the response to COVID19 has been the increased use of telehealth and related service arrangements. The Joint Standing Committee might consider how telehealth might be effectively to a larger extent into NDIS service arrangements, especially as a potential enabler of service access improvements, in concert with a broader package of measures. However, SARRAH also stresses that telehealth measures do not provide an appropriate alternative to face-to-face service provision, but can be incorporated as part of an effective service and treatment program.
To conclude, SARRAH strongly supports the NDIS and the opportunities it offers to participants. We believe people with disability living in rural and remote areas should have the same opportunities and prospects to engage with and contribute to their communities, their wellbeing and to the economy as other people. Enabling this to occur requires a coordinated and effective NDIS workforce strategy that includes allied health services and access for rural and remote participants. SARRAH offers our support to achieve these outcomes. We are committed to working in partnership with the NDIA, DSS and other organisations to develop culturally appropriate, financially viable services that meet the challenges presented in Australia’s small rural and remote communities.
If you require further information please contact me
Yours Sincerely
Cath Maloney
Chief Executive Officer
4 June 2020
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Attachment A: Joint Standing Committee (JSC) on the NDIS – selected Recommendations to improve allied health workforce and service capacity in rural and remote Australia
SARRAH appreciates that the NDIS and its implementation is complex. As such the JSC role of in contributing to the oversight and refinement of the Scheme is extremely important. Consequently, while SARRAH believes Recommendations of the JSC should be considered in their entirety we highlights the following as having clear and direct implications for NDIS allied health related workforce development, capacity and sustainability.
2019 Inquiry into the general issues around the implementation and performance of the NDIS
Recommendation 11: The committee recommends NDIA start trialling alternatives to a fee for-service delivery model to address thin markets in rural and remote areas by the end of 2019.
Recommendation 12: The committee recommends the NDIA make public how it will ensure the provision of services in case of market failure in rural and remote areas.
Recommendation 17: the committee recommends that the NDIS Quality and safeguards Commission urgently review the impact of its regulatory requirements on sole providers and small to medium sized businesses providing disability services and report to the parliament on its findings.
2019 NDIS Planning Interim Report
Recommendation 9: The committee recommends that the National Disability Insurance Agency (NDIA) ensure that additional training and skills development is provided to all persons involved in the planning process (particularly NDIA officers and LACs), to ensure that all such persons:
are familiar with a range of disabilities experienced by participants, and develop specialisation in particular disability areas; are familiar with allied health expertise; understand the specific needs of Aboriginal and Torres Strait Islander participants, and participants for culturally and linguistically diverse backgrounds, to ensure that they are able to deliver culturally appropriate services; and receive training in domestic violence awareness.
2019 Inquiry into market readiness for provision of services under the NDIS
Recommendation 1: The committee recommends the DSS and the NDIA urgently develop a strategy document that clearly articulates the roles, responsibilities and activities of all those responsible fo4r market stewardship.
Recommendation 6: The committee recommends the NDIA urgently implement the tailored pathways designed to support:
Participants with complex support needs Children aged zero to six Participants with psychosocial disability Participants for culturally and linguistically diverse (CALD) backgrounds Aboriginal and Torres strait Islander communities Remote and very remote communities and LGBTQIA+ communities.
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Recommendation 8: The committee recommends the Australian Government fund the ABS to regularly collect and publish information on the qualifications, age, hours of work and incomes of those working in disability care works (sic), including allied health professionals.
Recommendation 9: The committee recommends that DSS develop and publically release a national strategy to develop the disability workforce.
Recommendation 10: The committee recommends the Australian Skills Quality Authority undertake consultations with the industry, state and territory governments on the adequacy of current Vocational Education and Training (VET) programs offered in disability care.
Recommendation 21: The committee recommends the NDIA work with allied health professions peak bodies and service providers to co-design a suitable methodology for pricing supports to participants with high and complex needs.
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Attachment B: Allied Health Workforce Data
The lack of a comprehensive national data base covering all health and related workforce sectors and professions severely limits the effectiveness of workforce planning and investment; by the Commonwealth, states/territories and local government, the non government sector, and private providers. It compromises the capacities of stakeholders to plan and develop services capable of meeting service needs; and is a major impediment to social service and health service and workforce planning for communities where there are clear shortages, notably rural and remote Australia.
Addressing this issue would:
Greatly enhance and support allied health workforce planning and development at the local, regional and national levels Improve ability to measure impact of any allied health workforce reforms applied at various levels Inform stakeholders (government, NGO, private, consumer) regarding the state of the allied health workforce in particular sectors or geographic settings Enable the Commonwealth to plan and support rural allied health workforce developments.
Around half of all allied health professions are not included in Ahpra data and there is no reliable alternative dataset. This means no comprehensive or reliable information is available about a range of allied health professions that are central to providing disability, preventive, therapeutic and rehabilitation services; A list of professions not registered through AHPRA, and about which little national workforce data exists, follows (noting, this may not be comprehensive): o Arts therapist o Audiologist o Dietitians and nutritionists o Exercise physiologist o Genetic counsellor o Music therapist o Orthotist/Prosthetist o Orthoptist o Perfusionist o Rehabilitation counsellor o Social worker o Sonographer o Speech pathologists and therapists o Aboriginal and Torres Strait Islander mental health practitioner o Allied health assistant
This is not a new situation. Australia needs a medium-term strategy to address this shortfall in the capacity to plan and deliver allied health services across health and social assistance systems nationally.
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