Submission 50 — Services for Australian Rural and Remote Allied Health (Attachment 1) — NDIS Workforce

Submission to the

Joint Standing Committee of the NDIS

• Attachment -

National Workforce Plan

August 2021

Contents

Contents ……………………………………………………………………………………………………………………. 2

1. Introduction …………………………………………………………………………………………………………. 3 Background…………………………………………………………………………………………………………………. 4

2. Recommendations……………………………………………………………………………………………….. 4

3. Allied Health services and workforce in rural and remote Australia – update……………….. 6 Positive developments and areas for attention ………………………………………………………………… 7

The National Rural Health Commissioner - Improving access, quality and distribution………………… 7

Appointment of the Commonwealth Chief Allied Health Officer …………………………………………….. 9

Deputy National Rural Health Commissioners …………………………………………………………………… 9

The 2021-22 Budget ……………………………………………………………………………………………………10

The NSC Care Workforce Labour Market Study ………………………………………………………………….11

Report of the Inquiry into Australia’s Skilled Migration Program (August 2021) ………………………..12

Opportunities for distributed and coordinated training pathways & capacity …………………………..14

The Aged Care Royal Commission: NDIS workforces implications …………………………………………..15

A focus on investment – insurance schemes and enablement ……………………………………………….16

The Disability workforce: Investment and enablement ………………………………………………………..16 Areas of concern …………………………………………………………………………………………………………17

Coordination and sequencing of current VET training review processes…………………………………..17

NDIS participation and plan utilisation …………………………………………………………………………….19

Development of the NDIS Workforce Plan – observation on consultations ……………………………….20

4. Addressing the Terms of Reference ………………………………………………………………………. 22 Priority 1: Improve community understanding of the benefits of working in the care and support sector and strengthen entry pathways for suitable workers to enter the sector ………..22

5. Promote the sector ………………………………………………………………………………………………22

6. Develop tools for job seekers………………………………………………………………………………….23

7. Improve jobs boards …………………………………………………………………………………………….23

8. Leverage employment programs …………………………………………………………………………….23

9. Better connect providers to enablers ……………………………………………………………………….24 Priority 2: Train and support the NDIS workforce………………………………………………………………..24

10. Develop micro-credentials and training …………………………………………………………………….24

11. Develop a professional network for the sector……………………………………………………………27 Page | 2

8. Establish a skills passport ………………………………………………………………………………………28

9. Grow traineeships and student placements ……………………………………………………………….28 Priority 3: Reduce red tape, facilitate new service models and innovation, and provide more market information about business opportunities in the care and support sector …………………32

10. Align regulation and worker screening…………………………………………………………………..32

11. Improve pricing approaches ………………………………………………………………………………..33

12. Provide market demand information …………………………………………………………………….34

13. Help participants to find supports online ……………………………………………………………….35

14. More options to use allied health assistants……………………………………………………………35

15. Support telehealth in rural and remote areas………………………………………………………….37

16. Support the Indigenous community controlled sector ………………………………………………38 APPENDIX A: Recommendations from SARRAHs NDIS Workforce Submission (June 2020) ……..44

APPENDIX B: Report of the Inquiry into Australia’s Skilled Migration Program (August 2021): …..46

APPENDIX C: The Priority Migration Skilled Occupation List ………………………………………………..47

APPENDIX D: Aged Care Royal Commission – better allied health workforce & service access ………………………………………………………………………………………………………………………………….48

APPENDIX E: Aboriginal and Torres Strait Islander health professional workforce …………………..51

1. Introduction Thank you for the opportunity to provide input to the Joint Standing Committee Inquiry on the

NDIS Workforce: NDIS Workforce Plan

SARRAH appreciates the work of the Parliamentary Joint Standing Committee in guiding the evolution, quality and impact of the Scheme.

SARRAHs notes that many of the systemic issues and concerns described in our Submission to the Committee’s Inquiry into the NDIS Workforce (Submission No. 50) of June 2020 remain substantially unaddressed at this point.

The focus of this Submission is on the opportunities, potential and risks associated with the NDIS National Workforce Plan, and includes comment against the priorities and actions outlined in the Plan. This Submission Attachment should be read in conjunction with our covering Submission dated 20 August 2021.

As with submissions SARRAH has provided to the Joint Standing Committee previously, our focus is primarily on ensuring the NDIS enables participants to access the most appropriate and beneficial allied health services and care, in line with participants’ interests, ambitions and needs.

DSS has requested that stakeholders interested in contributing to the further development and implementation of the NDIS Workforce Plan contact them directly. SARRAH has indicated to DSS our deep interest in contributing to this work and will write to confirm this in the near future.

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Background

Allied health professionals (AHPs) provide services to people with a disability, their families and others to achieve goals in their lives’, including daily living, maintaining and building functional capacity and independence, social and community participation, work, leisure, learning and relationships.

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 equitabl e 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 disability.

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.

2. Recommendations SARRAH believes the following Recommendations would help ensure the intent of the NDIS Workforce Plan. Eeffective implementation of the Plan is urgent for NDIS participants and potential participants in rural and remote Australia.

Many of these workforce challenges are particularly acute in regional and remote communities and in supporting participants with complex needs

Thin markets face more acute and varied challenges in growing a quality workforce. These challenges include a lower supply of providers and workers already operating in these markets, difficult working conditions and barriers to accessing training and support. Thin markets for the NDIS occur by service type (including supports for participants with complex needs) or by geography, mostly in regional and remote communities.

NDIS National Workforce Plan: 2021–2025 – page 20. https://www.dss.gov.au/sites/default/files/documents/06_2021/ndis-national-workforce-plan-2021-2025 pdf

Progress recommendations of the previous National Rural Health Commissioner’s (NRHC) report: Professor Worley’s Recommendations are well considered and broadly compatible with the objectives of the NDIS workforce Plan. SARRAH urges the JSC to recommend the Government respond substantively and prioritise the earliest possible implementation of the previous National Rural Health Commissioner’s recommendations.

Better coordinated and quality national workforce planning and development capacity: Noting the August 2021 report of the Parliament’s Joint Standing Committee on Migration, SARRAH urges the JSC to support the recommendation that the Federal Government develop a dynamic national workforce plan: to be co-ordinated with State and Territories to ensure

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Australia’s persistent skills shortages and future workforce needs are addressed through coordinated effort across Australia’s higher education and vocational education systems, employment services and the skilled migration program; and that the process be cross-portfolio, cross-jurisdictional and be led by the NSC, utilising improved data collection to identify contemporary skills needs and shortages at a regional level by occupation.

Review the current actual reach and availability of NDIS relevant VET sector courses especially in rural and remote Australia: to ensure that where there is a workforce need, action is taken to ensure local promotion and training delivery capacity is developed to support local workforce development.

Modelling to evaluate and assess the investment return of enabling services as intended in the design of the NDIS: That the JSC recommend independent econometric and actuarial analysis be undertaken of the long-term implications of investments in enabling services through the NDIS, noting, employment, income taxation and other revenue, impact of projected income support and other service demand, across a range of scenarios.

Engagement: That the JSC encourage DSS and the NDIA to ensure strong, ongoing engagement with a broad range of workforce and service delivery stakeholders, including peak and other stakeholder bodies with expertise and demonstrated commitment to ensuring service improvements in areas of particular identified need, such as rural and remote and Aboriginal and Torres Strait Islander communities.

Cross-sector workforce: That the JSC note the National Skills Commissioner is producing a Care Workforce Labour Market Study, to be presented to Minister Robert in the near future, which should have substantial implications for the NDIS Workforce Plan. Pending the contents of the Report, consider re-convening the Workforce Inquiry to examine further opportunities to develop the NDIS Workforce.

Trainee and student placement capacity: That the JSC recommend an urgent review of barriers and gaps in trainee and student workplace /clinical placements relevant to the NDIS and related service sectors, with a view to increasing supply.

Regulation: That the JSC support recommend to the Deregulation Taskforce that a project be developed and conducted with the rural and remote allied health sector to examine the range of regulatory requirements associated with cross-sector/cross-service practice and identify areas for red tape reduction.

Review of existing programs and grants: That the JSC recommend a review be undertaken, possibly led by the Productivity Commission, into whether current Commonwealth Grant and other mechanisms aimed at building service and workforce capacity across the NDIS and other service sectors delivers optimally and what barriers, if any, exist to optimising impacts from current approaches.

Support development of funding and service mechanisms available to and tailored to meet community service needs in communities identified as “thin markets”.

That the JSC continue to oversight implementation of the NDIS Workforce Plan.

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3. Allied Health services and workforce in rural and remote Australia – update The chronic, ongoing mal-distribution of allied health services and workforce Australia is severe, long-standing and highly metro-centric. This is closely associated with poorer health outcomes, including higher levels of chronic disease, potentially preventable hospitalisation and disability. Shortages in service availability also inhibits awareness of and access to services NDIS participants’ would otherwise be able to incorporate into their plans.

A range of actions identified in the NDIS Workforce Plan could help promote participants’ awareness of enabling and other service options. Increasing awareness of enabling services must also be matched with an increase in availability and cost-effective provision of those services. This is essential if NDIS participants living in rural and remote Australia (among others) are to exercise their right to be both informed purchasers of services that impact their lives and have the opportunity to exercise genuine choice.

Further policy action is needed to increase allied health service and workforce capacity in rural and remote Australia: impacting the NDIS and other vital service sectors. Notwithstanding the challenges of rural and remote practice, SARRAH’s membership includes many examples of AHPs and services that have developed viable operating models to provide community-based and outreach services in and to rural and remote communities. Exemplars exist and could multiply if facilitated by informed, purpose-built and coherent policy and program settings1. Unfortunately, the operating environments of allied health service providers, especially in the community and private sectors (actual and potential NDIS providers), have not previously been a major focus for Commonwealth health system policy and decision-making; where mainstream, medically-focussed or related service streams have held focus and investment priority. Consequently, compared with medical services and workforce support, pharmaceuticals and other areas of major Commonwealth Health focus and investment, at the policy and investment decision-making level, knowledge about allied health practice, services and impact is relatively limited: which presents a challenges especially where those services are generally in short supply.

There have been positive developments in this regard over very recent years. Several of those developments are described below. However, there are also several contemporary examples where policy and program developments that purport to improve allied health service access fail to:

 take adequate account of allied health service models that are working well in rural and remote Australia);  refute the assumption that rural and remote allied health practice is not viable in its own right, whereas evidence and innovative models show it is;  comprehend the extent to which allied health services are required across the disability, health, aged care, veterans’ support, mental health, early childhood development and other service sectors – and so the viability and potential growth associated with that breadth of potential practice;  recognise the existing mainstream service systems and structures do not optimise access to important allied health services for many people and can actually inhibit access.

1 Substantial work has been done to identify and address (at least within the remit of practises and serv ice organisations) the factors that contribution to allied health rural attraction and retention. For examples, see Strategies for Increasing Allied Health Recruitment and Retention in Rural Australia: A Rapid Review - SARRAH 2019.

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It is more than appropriate for rural and remote allied health service providers and experts to be closely involved in policy and program design and implementation of allied health services. As noted above SARRAH welcomes DSS’ stated intention for substantive engagement.

SARRAH has described many of the factors contributing to and issues and in detail in previous submissions to the Joint Standing Committee, notably in relation to your Inquiries in the NDIS Planning and Workforce. The Recommendations SARRAH put in that Submission are included at Appendix A.

Positive developments and areas for attention SARRAH has long advocated for policies and programs that recognise the particular circumstances and needs of individuals and communities across rural and remote Australia. The evidence of community need, differential service access and capacity and case for a fundamental shift toward person and place-based approaches to service systems and supports in rural and remote Australia were described in detail in our Submission to the JSC on the NDIS Workforce Inquiry in June 2020.

The National Rural Health Commissioner - Improving access, quality and distribution

In late June 2020, the former National Rural Health Commissioner, Professor Paul Worley,

presented his informed and substantial report Improvement of Access, Quality and Distribution

of Allied Health Services in Regional, Rural and Remote Australia to Government. Professor

Worley clearly articulated the importance of the NDIS, and of various service systems working together to address the chronic allied health service and workforce shortages experienced across sectors in rural and remote Australia.

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The NDIS: Excerpts from Improvement of Access, Quality and Distribution of Allied Health Services in Regional, Rural and Remote Australia (NRHC, June 2020)

The Recommendations of the report would “… enable cross-sector solutions essential to the success of the National Disability Insurance Scheme (NDIS”) – (Page vii)

The Recommendations of the report represented “… a system prepared to respond accordingly to the significant issues raised by the National Disability Insurance Scheme (NDIS) Thin Markets Project” (Page 1)

“Funding models such as those for private health insurance, the Medicare Benefits Schedule (MBS), My Aged Care, and the National Disability Insurance Scheme (NDIS), are designed to be market-driven solutions. However, in smaller rural and remote towns prone to thin markets and market failure, these funding models are not effective and often exacerbate the ongoing challenges to attract, retain and support an allied health workforce.” (Page 3)

“In rural and remote communities, fragmented sector-by-sector funding approaches contribute to the vulnerability of local economies and viability of allied health service models. While rural and remote communities in theory have access to multiple funding sources from sectors and programs such as the National Disability Insurance Scheme (NDIS), Primary Health Networks, aged care services, state health departments, local government, and education and social services, these sources, in reality, are often underutilised or untapped by small rural and remote providers. These fragmented funding systems are administratively burdensome, costly and complex to navigate, each with different payment, registration, reporting and accreditation processes. Faced with such complexity, allied health providers are deterred from expanding to deliver the full range of services to communities who need them.” (Page 16)

Progressing the recommendations of Professor Worley’s Allied Health Report was among the priorities identified for incoming NRHC, Associate Professor Ruth Stewart, in the Statement of Expectations issued by then Minister for Rural Health, the Hon. Mark Coulton MP on 23 March 2021.

SARRAH was one of many stakeholders who contributed substantially to the review and Professor Worley’s Report. On 18 August 2021, SARRAH received a “Google Alert” regarding publication of the Australian Government’s response to the National Rural Health Commissioner’s report on Improving the Access, Quality and Distribution of Allied Health Services in Rural and Remote Australia. The document was posted on the Department of Health’s publications page, with an indication that it was published on 30 July 2021. To SARRAHs knowledge there has been no accompanying advice to stakeholders or advice issued publicly about the Government’s response.

The Government’s response is low-key and points to a range of actions which might be best described as a broad “work in progress”. While the advances identified which actually respond to the NRHC Report are welcome, the extent of the response and the profile given to the response suggests much effort is still needed if the investment that went into the Report is to yield a response commensurate with the systemic shortfalls and high levels of unmet need in rural and remote communities.

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Professor Worley’s Recommendations are also compatible with the objectives of the National Primary Health Care 10 Year Plan, a report on which is currently being prepared for Government consideration by the appointed Primary Health Care Steering Group. SARRAH has recommended the Steering Group also consider and support urgent progress in implementing Professor Worley’s recommendations.

Appointment of the Commonwealth Chief Allied Health Officer

One recommendation of the NRHC was “that the Commonwealth appoint a dedicated full-time Chief Allied Health Officer (CAHO) to work across sectors and departments including health, mental health, disability, aged care, early childhood, education and training, justice, and social services”2. The Government announced the appointment of Dr Anne-marie Boxall into the role on 8 July 2020. Such an appointment had been long-advocated for by the allied health sector. The CAHO’s initial priorities were identified as including to supporting the Australian Government’s Primary Health Care 10-Year Plan, health workforce reforms and the Stronger Rural Health Strategy. The CAHO also has an identified role in liaising across agencies on allied health related issues, including with DSS on the NDIS, and to help progress development of development of an allied health dataset. This a substantial agenda and should proceed urgently, through multi-agency effort and drawing on broad stakeholder input, given the demonstrable shortfalls in service and the impact further delays have on NDIS participants and others in rural and remote Australia.

However, SARRAH is concerned that the CAHO position as structured, notwithstanding the capability of the incumbent, may not have the seniority and influence to facilitate the substantial change from current policy settings needed if rural and remote Australians are to enjoy comparable allied health services through health NDIS, health or other programs 3. The CAHO position is more junior and has a more administrative role to those of the Chief Medical Officer (CMO), the numerous Deputy CMOs and the Commonwealth Chief Nursing and Midwifery Officer4.

Deputy National Rural Health Commissioners

The recent appointment of two Deputy National Rural Health Commissioners (Deputy NHRCs) to assist the NRHC is a potentially important development. The Deputy NRHCs have responsibilities to help improve access to rural health services and to address rural workforce shortages for allied health, nursing and Aboriginal and Torres Strait Islander health workforce. SARRAH welcomes the additional focus the Deputy NRHCs will bring, noting the allied health workforce is the least well distributed of all major health workforce groups, with the exception of non-GP medical specialists. However, SARRAH also notes that:

 Aboriginal and Torres Strait Islander health and wellbeing and outcomes for rural and remote Australians are among the area where improvements in services are most needed;  The health professional groups the Deputy NRHCs are to focus on make up around 85 per cent of the total health professional workforce; and  SARRAH understands the Deputy NRHCs are each engaged to perform their roles on the basis of one day per week.

2 National Rural Health Commissioner’s Allied Health Report to the Minister June 2020.pdf, page ix. 3 See - https://www.croakey.org/other-commonwealth-department-of-health-chiefs/ (20 August 2021) 4 See - https://www.croakey.org/other-commonwealth-department-of-health-chiefs/

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The 2021-22 Budget

The 2021-22 Budget included an investment of $9.6 million over three years to expand the Allied Health Rural Generalist Pathway (AHRGP)5, providing for:  up to 90 workplace training packages to attract and retain allied health professionals, predominantly in Modified Monash (MM) 3-7 locations (i.e. rural and remote)  30 packages allocated to Aboriginal Community Controlled Health Organisations  30 Allied Health Assistant packages to provide tailored practice and workforce support for allied health practitioners to establish and/or maintain viable practices in under serviced communities.

The 2021-22 expansion of the AHRGP, while comparatively modest in workforce outlays, is a highly significant, positive shift in Commonwealth support for rural and remote allied health workforce development and distribution. Demand for the current ‘pilot’ program which will be extended by this measure was high, with substantial involvement and demand from NDIS service providers: which we anticipate will increase places become available. The AHRGP and associated AHA model is extremely well suited to increasing NDIS enabling service capacity in rural and remote settings.

Other 2021-22 Budget measures that do not specifically target NDIS participants or rural and remote Australia, but which could help to support rural and remote allied health services, and thereby enable better NDIS participant access, potentially, include:

 $13.7 million over 4 years for new Medicare Benefits Schedule (MBS) items to reimburse allied health professionals who participate in multidisciplinary case conferences: previously while medical professionals were reimbursed for participating AHPs were not;  $5.4 million over three years to fund 100 new post-graduate scholarships each year for AHPs health professionals with a focus on dementia qualifications (aged care);  $27.8 million to increase the number of nurses, psychologists and allied health practitioners working in mental health settings through 280 scholarships and 350 clinical placements;  Changes in aged care funding that should enable identification of AH service need and potentially access to such services; and  $0.7 million in 2021-22 for an allied health data gap analysis to improve the visibility and impact of allied health services.

SARRAH also notes that existing major Government funding allocations, such as JobTrainer, VET training agreements with and support provided by States and Territories and measures in a range of 2021-22 Budget provide an existing allocation of funding to substantially underpin growth in the much needed VET trained workforce, including for expert therapeutic and enabling workers, especially Allied Health Assistants, and so bolster career and skills development pathways. The NDIS Workforce Plan has potential as a major catalyst to drive

5 The ov erarching goal of the Allied Health Rural Generalist Pathway (AHRGP) strategy is to improv e outcomes for rural and remote consumers by increasing access to a highly skilled allied health workforce and enhancing opportunities for multi-disciplinary care. The three areas of focus for the AHRGP include: Rural generalist service models that support and engage allied health professionals to implement innovative and effective solutions to the challenges of deliv ering care across geographically dispersed and culturally diverse populations; Workforce policy and employment structures that align to dev elopment requirements and facilitate progression; A formal education program that supports the dev elopment of the clinical and non-clinical practice and enhances skills and capabilities of the allied health workforce to meet the challenges of deliv ering serv ices in rural and remote areas. See - https://sarrah.org.au/our-work/ahrgpathway

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skilled workforce growth, other investments and factors are conducive to it and the opportunity should not be lost to leverage these and to address existing systemic workforce development and distribution shortfalls.

The NSC Care Workforce Labour Market Study

In March this year, the Prime Minister set the National Skills Commissioner (NSC) a challenging task “to undertake an in-depth study of the factors affecting the supply and demand of care workers both in the near term and longer term to 2050”6 and report by September 2021. SARRAH welcomed the Study, the approach of the NSC and the Commission to engage early and meaningfully with stakeholders and, even with the tight timeframe, to release for consultation a Discussion Paper that outlined a coherent approach, with scope and balance to facilitate informed advice and decisions across the immediate and longer-term (to 2050).

The growing demand for a skilled Health and Social Assistance (HSA) sector workforce (which includes most to the health professional, therapeutic, care and assistance roles required by the NDIS, aged care, health and other sectors) pre-dates the introduction of the NDIS. There has been marked long-term trend growth for this sector coincident with rising need and awareness of the service implications of structural ageing of the population and other factors. The importance of this jobs sector to not only service capacity but the economy more broadly is immense.

 The HSA sector has been by far the lead jobs growth sector in the economy, with strong long term growth projected to continue with the forward five years holding at around 250,000 new jobs nationally.  To put this in perspective, it means more than 10 new jobs are expected to exist in the HSA sector than for every additional job in the mining sector.

The potential opportunities and opportunity-costs of these workforce trends are serious for rural and remote communities:

 Deliberate coordinated, cross-portfolio action could build a local workforce to substantially address community need and deliver large numbers of stable, skilled local jobs; while  Lack of coordinated action risks exacerbating service shortages, poorer population outcomes and place-based inequalities, increasing downstream outlays (such as preventable hospitalisations and associated with reduced independence) and maintaining an over-reliance on what is often low-efficacy, high cost service options to meet the growing demand.

The following excerpt from SARRAHs Submission on the NSC Discussion Paper states:

The approach described in the Discussion Paper aligns with SARRAHs view that there is an urgent need to build the “care” workforce, and lay the groundwork for a considered, long-term investment strategy so the future workforce is equipped to deliver on community needs and expectations, including to optimise wellbeing, independence and capacity for the longest time possible. The impact would also contribute to social cohesion, productivity and the sustainability of our service and support systems. SARRAH supports the broad cross-sector scope of the Study, and the effort to introduce a better balance of integration with adaptability into our workforce development

6 See - https://www.nationalskillscommission.gov.au/discussion-paper-care-workforce-labour-market-study

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systems. There may be some concern that such an approach involves design complexity however, it also positions us to address existing system constraints that contribute to persistent gaps in the service system and inflexibilities that impede access for many individuals and communities must services that respond to their particular needs.

Considering the Discussion Paper, consultations and, we understand, engagement by DSS and other agencies with the NSC, SARRAH anticipates the work will present a strong case for Australia to embed a more strategic, integrated and responsive system of workforce development than we have for our care service systems at present. Hopefully, the NSC report will clearly complement and reinforce positive aspects of the NDIS Workforce Plan.

DSS also argue there are important differences and common elements and opportunities across the NDIS, aged care and veterans’ care programs - “Strengthening the care and support sector as a whole will increase productivity and consistency across the entire sector to meet demand, and grow the pool of available workers in order for disability support, aged care and veterans’ care programs to meet

Enhancing the disability workforce will also boost the aged care and veterans’ care workforce

Disability support, aged care and veterans’ care programs are highly connected. Around 30 per cent of aged care providers also operate in the NDIS or veterans’ care programs. 36 per cent of veterans’ care providers operate across all three programs. Department of Social Services analysis comparing registered aged care providers, veterans’ care providers and NDIS providers with a claim for support provided to a participant in the 2019-2020 financial year (as at June 2020). NDIS Workforce Plan Page 9.

demand.”7

There is a strong requirement and, often, professional inclination toward “generalist” professional practice in smaller communities. It is well-embedded and strongly support by governments in health and other skilled service provision, not least medical general practice. Enabling similar approaches to NDIS allied health and other services providers in smaller communities could deliver more successfully on the potential for increased productivity and consistency across the entire sector referred to above by DSS above: as there is less demand for or business viability in specialised or narrow service approaches in those communities.

Report of the Inquiry into Australia’s Skilled Migration Program (August 2021)

Taking a broader workforce focus, the Parliament’s Joint Standing Committee on Migration Final Report of the Inquiry into Australia’s Skilled Migration Program, released on 9 August 2021, also identified major shortfalls in coordination, comprehensiveness and currency of information to support Australia’s workforce planning arrangements. If adopted, the Report’s first recommendation would see a major improvement in workforce planning and development arrangements, promoting the effectiveness of the NDIS Workforce Plan and more.

The Committee recommends that building on the work of the National Skills Commission (NSC) and the Skilled Migration Officials Group, the Federal Government develop a dynamic national workforce plan. The plan would co-ordinate the efforts of State and Federal Governments to ensure Australia’s persistent skills shortages and future workforce needs are addressed through Australia’s higher education and vocational education systems,

7 NDIS Workforce Plan, Page 9.

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• SARRAH

Services for Australian Rural and Remote Allied Health

employment services and the skilled migration program. This plan should be regularly updated. In order to develop the plan:

e Across-portfolio, cross-jurisdictional interagency committee (IAC) should be established, meet regularly, and comprise decision-makers from departments and agencies, led by the NSC.

e The NSC and relevant data collection bodies should also develop a data aggregation system that identifies skills shortages at a regional level by occupation.®

SARRAH believes there is scope for a number of Recommendations in the Report, including the Recommendation reproduced above, to be progressed on a non-partisan basis without exacerbating concerns expressed in the dissenting remarks of Committee members to the Report.

Several national organisations pointed to problems with the existing datasets and approaches (please refer to Appendix B for more detail). These technical issues have direct impacts on NDIS service capacity. For instance, SARRAH is aware of members who have tried for extended periods to recruit AHPs domestically have then, reportedly spent tens of thousands of dollars to sponsor a qualified overseas candidate, who ultimately decides not to migrate citing the difficulty of the process in the decision. Such situations are reflected in the observation of the Regional Australia Institute in noting ‘the costs involved in the sponsorship for employers can be prohibitive for small and medium regional businesses”.

The Committee also recommended the Government provide employers looking fo fill jobs on the Priority Migration Skilled Occupation List (PMOSL) with more streamlined processes (noting there were dissenting views on the proposal). However, noting concerns about the efficacy of Australia’s current arrangements it is also apparent that the PMSOL itself gives, at best, a partial view to our national skills and workforce development needs and do not align with other workforce demand — and analysis, oe the Australi ment’s occ tio

There are currently 44 occupations (ANZSCO code) listed on the PMOSL: including professions such as engineers, auditors, ICT specialists and health professional groups including medical practitioners, nurses and midwives, pharmacists and (other AHPs such as) orthotists, prosthetists and social workers. Yet the PMSOL does not include many allied health or other professions in high demand nationally, lef alone in rural and remote Australia. The following table compares health professions Sean inthe PMSOL and those identified by the Government’s occupation

Occupation Listed on Projected employment Projected employment the growth to Nov 2025 growth to Nov 2025

PMSOL _(‘000) (%)

Orthotist or Prosthetist Yes Not identified Not identified

General Practitioner Yes 10.4 15.3%

Resident Medical Officer Yes

Psychiatrist Yes 0.1 5.1%

Midwife Yes 4.6 25.1%

Registered Nurse (Aged Yes

Care)

8 See Final Report of the Inquiry into Australia’s Skilled Migration Program — Parliament of Australia (aph.gov.au), Page ix. ? Ibid: Page 51.

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• SARRAH

Services for Australian Rural and Remote Allied Health

Registered Nurse Yes

(Critical Care and

| Emergency) 46.5 15.6%

Registered Nurse Yes

(Medical)

Registered Nurse Yes

(Mental Health)

Registered Nurse Yes

(Perioperative) _ Social Worker Yes 46 15.2% Medical Imaging No 3.1 15.1% professionals __ Optometrists and No 1:5 18.6%

Orthoptists

Pharmacists No if 7.6% Chiropractors and No 0.4 5.8%

Osteopaths

Occupational Therapists No 3.9 17.1% Physiotherapists No a3 14.0% Podiatrists No 0.7 14.1% Audiologists and No 35 24.1%

Speech Pathologists/

| Therapists

Psychologists No 8.2 22.8%

The Committee noted “recent work of the National Skills Commission (NSC) and the Skilled Migration Officials Group as a good start” but indicated a lack of confidence in the current approach to provide “a comprehensive picture of Australia’s workforce shortages. The Committee is also not convinced that there is sufficient coordination across the Commonwealth, States and Territories in providing the appropriate policy responses to these shortages. There is also insufficient real time information about skills shortages across the co untry but particularly in regional areas.”

The NSC is working to improve the situation, which has clear implications for the NDIS Workforce Plan. SARRAH will seek to contribute to these developments.

Opportunities for distributed and coordinated training pathways & capacity

For rural and remote communities, the education, training, supervisory infrastructure, existing workforce and service systems to enable NDIS and related workforce development and replenishment can be scarce and even non-existent. Yet these same communities often have ample need for services (whether identified or not) and a potential workforce of local, connected and capable people, able to fill positions were the training and employment/ service opportunities available. The consequence too often is that communities with the highest relative unmet need and a local potential workforce are not able to access the training and supports fo fill the local gaps.

The NDIS Workforce Plan draws connections with other workforce and related developments,

including the Aboriginal and Torres Strait Iskander Health Workforce Strategic Famework and

Implementation Plan 2021—2031; the Commonwealth Implementation Plan for the National Agreement on Closing the Gap and related plans: this is necessary, sensible and welcome and positive. SARRAH notes the expertise and capacity building approach of Indigenous Allied

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Health Australia (https://iaha.com.au/) in build the Aboriginal and Torres Strait Islander health and related workforce and pathways; the potential of which was also recognised by the NRHC in his June 2020 report.

IAHAs approach is exemplified by their National Aboriginal and Torres Strait Islander Health Academy Model, which was developed to fill gaps in tailored, culturally-oriented and accessible education, training and careers opportunities. The proportion of the population that is Aboriginal and/or Torres Strait Islander increases with remoteness. Consequently, SARRAH sees the cultural safety and responsiveness of service systems and increasing the Aboriginal and Torres Strait Islander workforce as central to improving rural and remote outcomes in the NDIS, aged care, health etc. For allied health, that workforce needs to increase by a factor of 5-6 times to reach population parity. At current growth rates, we estimate it will take many decades if not centuries to reach that point. While activities continue to increase this workforce (and the rural allied health workforce), necessary to improve NDIS and other outcomes, the situation does not appear to rank the priority or sense of urgency advocates in these sectors believe is warranted. SARRAH is working closely with IAHA to expand the AHRGP and AHA positions into community-based and private settings. The need and scope for expansion is substantial.

These initiatives have been developed to overcome systemic gaps in our existing training and service systems: gaps that continue to exist across much of Australia. The NDIS Workforce Plan has potential to help address those gaps while building the workforce we need.

The Aged Care Royal Commission: NDIS workforces implications

The NDIS workforce – including personal carers, therapy assistants, allied and other health practitioners – where it exists in rural and remote communities, are also likely to be involved and/or in demand by aged care, health and other services, where the same workforce and skillsets are in short supply. In these situations - too often identified simply as being “thin markets”- programs with narrow foci and lacking flexibility can be impediments to service access, quality and sustainability. As discussed elsewhere, more person- or place- based approaches and generalist, cross-sector workforce and skills are needed.

Several of the actions in the NDIS Workforce Plan should contribute to addressing these issues, but to optimise the workforce and service impacts in rural and remote communities, cross sector synergies need to be drawn, including with aged care services. The scope of the NSC Care Workforce Labour Market Study (disability, aged care, veterans’, mental health etc.) promises to, and will hopefully deliver, in reinforcing the requirement for coordinated workforce development. The Commonwealth’s 2021-22 Budget response to the Aged Care Royal Commission (ACRC) and included substantial investment with significant workforce-building elements. Unfortunately, comparatively little of the response is targeted at allied health enabling and therapeutic workforce or service capacity directly, despite the ACRC identifying this as an area of significant need. There are very close synergies between NDIS and aged care workforce needs. Ideally these will be progressed in unison as service and workforce capacity, training and employment options are strengthened in rural and remote Australia.

The ACRC produced detailed 146 detailed Recommendations, spanning 106 pages. The issues identified and options for improvement should not be missed in other service systems where many of the same underlying constraints on service quality and sustainability exist.

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Appendix D provides a truncated summary of ACRC Recommendations where responses could align with, leverage and deliver improved outcomes for NDIS participants and people receiving aged care services.

A focus on investment – insurance schemes and enablement

The NDIS exists to improve the quality of life and opportunity for participants. For that aim to be met on an ongoing basis, the Scheme has to be sustainable long-term, which entailed shifting to an insurance (and investment) model, designed around ‘dividends’ to be achieved through complementary elements:

 the objective of supporting the independence and social and economic participation of people with disability;

   investment in enabling supports  - an ‘insurance-based approach, informed by actuarial

analysis, to the provision and funding of supports for people with disability’ and  the Act, which requires ‘regard must be had to ensuring its financial stability’. 10

The cost of the NDIS has attracted substantial public attention as have measures designed to constrain outlays. There has not been the same level of focus on how or to what extent targeted, enabling investments, as planned, do or could contribute to Scheme viability. If the focus of financing the Scheme becomes essentially a focus on reducing outlays in the immediate term the prospects of sustainability long-term will decrease. Undoubtedly, outlays should be well-targeted, and on the basis of how well they deliver on Scheme objectives and the actuarial and investment requirements of the Scheme. NDIS workforce capacity and the impact of the workforce to enable and support participants’ to achieve goals are crucial to that investment.

It is not clear to what extent actuarial analysis and assumptions are influencing planning and developments, nor whether those factors are subject to external input and scrutiny.

Given the scope of the NDIS and the national implications, this matter deserves attention by the JSC and potentially referral to the Productivity Commission, with Terms of Reference that include the contribution of specific NDIS workforce and services to Scheme effectiveness and sustainability.

The Disability workforce: Investment and enablement

“At a national level, there is a broad economic imperative to support people with disability to work, with greater participation being a key driving factor for economic growth.”11

The National Disability Employment Strategy Consultation paper released in April 2021) presents a substantial case for increasing labour force engagement and employment opportunities and rates for people with disability. The National Disability Employment Strategy and the NDIS Workforce Plan have many clear and overlapping objectives. SARRAH especially regards one of the priority areas identified requires active support as part of the NDIS Workforce Plan:

10 Reference - The National Disability Insurance Scheme: a quick guide – Parliament of Australia (aph.gov.au)

11 National Disability Employment Strategy (Consultation paper April 2021). (Page 3)

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Building employment skills, experience and confidence of young people with disability: ensuring young people with disability are supported to obtain meaningful work and careers of their choice (Page 4).

The Consultation Paper notes the labour force participation rate among people with disability is significantly lower than for the broader Australian population: citing 2018 statistics of 53.4% compared with 84.1%. Positively, however, there is substantial potential to workforce participation among people with disability and the majority work now. Further, young people are overwhelming inclined to and hopeful about working.

“A survey of young people with disability (aged 15-24) found that this cohort are generally positive about their future in employment, and over 90 per cent want to work. However, survey feedback also indicated the employment journey can be complex and noted there are still many opportunities for improvement.”12

As the fastest growing employment sector, with opportunities and/or demand in every Australian community, the disability support and services sector presents employment opportunities for many people with disability, including NDIS participants working in the open labour market. Many people will have other workforce ambitions and no interest in working in the sector, however others will and have the capability as well as valuable lived experience, adding to the attributes they bring to the job.

The National Disability Employment Strategy Consultation paper also reported feedback from individuals about returning to work after acquired disability, noting support providers (e.g. medical professionals) do not always recognise employment as an important part of a person’s rehabilitation.13 This is an important point to highlight about the focus and role of AHPs and the emphasis they bring to treatment, therapy and services: the focus of care is fundamentally about optimising social and economic participation through the provision of therapeutic interventions that empower individuals by enabling capacity, helping them to achieve and maintain independence. The distinction is evident in the make-up of the broader rehabilitation workforce but tends to less understood in health service systems. AHPs are intrinsically aligned to the goals and aspirations of individuals and communities, and uphold the vital benefits of work, volunteering, hobbies and social life to help people find purpose and meaning in life.

SARRAH proposes to investigate with DSS the possibility of developing and trialling a targeted workforce and skills program to assist people with disability, including NDIS participants, interested in taking up a tailored Allied Health Assistant Training opportunity in rural and possibly remote settings, employed by NDIS and/or other allied health service providers.

SARRAH believes this would demonstrate the potential employment opportunities and capacity of people with disability to fill skilled workforce gaps in an of high, continuing employment demand.

Areas of concern Coordination and sequencing of current VET training review processes

Several reviews of VET sector training packages relevant to the NDIS Workforce Plan and SARRAH are currently underway, including Review of the Certificate III and Certificate IV training packages for Allied Health Assistance. The Review is being managed by SkillsIQ, working to the Direct Client Care and Support Industry Reference Committee (IRC). The Review is one of last to

12 Ibid, Page 11, citing the Disability and Career Advice Survey Report | Department of Social Services, Australian

Gov ernment (dss.gov.au) 13 See - Page 9.

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be conducted before new arrangements under the national Skills Reform agenda 14 come into effect. Such reviews are designed to ensure training programs align with quality standards, and meet workforce needs and expectations. Invariably, these processes involve balancing competing priorities, capacity and demands around education and training curricula/content with diverse community service and employer expectations, on top of time and cost limitations: it will also be a feature of the new arrangements. Despite concerns about the timing and scope of the Review, SARRAH has contributed and recognises several of our key concerns are outside the bailiwick of either SkillsIQ or the IRC to address. Those concerns include:

 The precise timing of the Review - especially the push to complete it now, seems to out of sync with broader strategic and context-setting work, especially the NSC Care Labour Force Study being delivered to Government in September;

o  SARRAH  is concerned the process is being driven by administrative and

contractual factors over workforce quality, capacity and community need considerations; o Without negating the specific skills, experience or commitment of IRC members, there appear to be gaps in expertise in important areas of contemporary allied health professional and assistant practice, innovation and emerging roles and it is not clear that advice mechanisms have been adequate to fully inform decisions, despite the process being open to input.  The Review focuses on training package content and does not extend to system limitations; however, these need to be addresses for the training package to be taught or accessed, especially where skills and workforce shortages are often most severe; o For example, the lack of allied health services (often despite high community need (as per the NRHC Report referred to previously), mean no training, supervisory of placement capacity exists in that community; in turn courses are not offered; the consequent lack of service exposure or apparent employment opportunities is mistakenly taken as being a lack of demand and training organisations do not and, practically cannot, offer the AHA training. .

  Another consequence  is that ‘quality’ related curricula and training requirements

cannot be met by available services (e.g. work placements). Service system and capacity limitations inhibit training delivery and workforce development in rural or remote settings. For example: o SARRAH has expressed concerns about the supply implications (but not training quality aspects) of increasing AHA Cert III practical hours requirements from 80 to 120 hours, noting the existing severe shortage in rural and remote settings of placement opportunities and high competition across VET and university students for placements; and o Proposed additional expectations being put on AHAs in rural and remote settings which adds to the existing training burden, when similar expectations are not applied to other services settings, and the content and issues (while important) would be better handled as part of specific workplace induction, supervision and development activity.

A further risk is that multiple, concurrent Review activities (outside of an overarching coordinated framework) will complicate and confuse important skill sets, training and career

14 See - https://www.dese.gov.au/skills-reform/skills-reform-ov erview

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pathways rather than promote structured and flexible skills sets and pathways that optimise workforce capability and cost-effective quality service delivery. The risk includes reducing lateral movement and potentially restraining flexible, skilled workforce development at high cost.

 The links and differences between the current aged care and disability sector focussed qualifications as well as the broader AHA and Personal Care Worker roles need to be worked through carefully, not to constrain but facilitate targeted skills and workforce growth and adaptability.

SARRAH believes these issues require further consideration, including to ensure the NDIS Workforce Plan is able to be implemented effectively in rural and remote Australia.

SARRAH encourages the JSC to refer these and other issues with the potential to adversely impact NDIS workforce development for further consideration and monitoring on a cross portfolio basis as the NDIS Workforce Plan, VET Reform agenda and NSC activities progress.

NDIS participation and plan utilisation

With insufficient AHP service exposure, access and capacity in rural and remote communities, SARRAH remains concerned that potential participants are not being identified. A duty of care exists to access and requires a deliberate and proactive approach. This was evident from the National Rural Health Commissioner’s 2020 Report. It deserves priority, not least because the situation has and will continue to impede NDIS access and impact in rural and remote Australia.

The NDIS is now rolled out national, but SARRAH believes many people who could be eligible for services have not yet been identified - notably in remote communities where individuals’ prior engagement with the disability, health and other service systems have not adequately identified eligibility and/or the potential benefits of engagement.

Lack of knowledge about allied health is a major concerns mong NDIA staff among others remains a concern. SARRAH welcome the JSC recommendation

… 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)

SARRAH argued in our submission to the JSC Inquiry into NDIS Planning:

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….”15

15 Submission 72: https://www.aph.gov.au/Parliamentary Business/Committees/Joint/National Disability Insurance Scheme/NDISPlanning /Submissions

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SARRAH believes these issues are also evident in NDIA reported utilisation rates, being the amount of a participants plan budget that is used. The latest NDIS Quarterly Report to disability ministers (30 June 2021) identified the continuing issue for remote participants:

 More than 10 percentage points below the national average Eyre and Western South Australia 1,276 $90 Far North (SA) South Australia 502 $42 Barkly Northern Territory 157 $14 Darwin Remote

Northern Territory 390 $33 East Arnhem Northern Territory 194 $22 Kimberley-Pilbara Western

Australia 1,253 $97 Further detailed data is available at https://data.ndis.gov.au/explore-data.

Utilisation is one indicator of participant access and system performance: it must be considered alongside indications that eligible populations have been identified and enabled to access the NDIS; whether plans are skewed to what might be available rather than what is of most beneficial and considered in an informed way by participants; whether there are affordable and cost-effective mechanisms to enable service access; and so on. These concerns should inform and shape NDIS Workforce Plan development and implementation on an ongoing basis.

Development of the NDIS Workforce Plan – observation on consultations

SARRAH welcomes the invitation issued by DSS for stakeholders to engage with the further development and implementation of the Plan. Further engagement is needed. SARRAH considers deeper engagement is warranted by stakeholders who are more closely connected with areas where major service gaps exist and are inherently committed to addressing those gaps. As documented in the Plan, consultations over the two year period prior to release of the Plan were extensive. SARRAH accepts the breadth of the consultation task was enormous and valuable. For the next phase, however SARRAH believes it is most beneficial if deeper and more targeted consultation is facilitated and that this is enabled to an extent that enables detailed issues identification, option consideration, contributions to design, implementation monitoring, oversight and ongoing improvement.

Consultation processes can be dominated by large, mainstream, often well-resourced organisations, representative bodies which, in fairness, represent or share concerns with the majority or other major service providers, contractors, workforce bodies, participants and groups. This approach may provide a reasonably accurate overview of issues and the sector, but is generally less effective in profiling the outliers, the concerns and experiences outside of the dominant systems, services and groups. However, the mainstream and dominant services tend not to be where the system design is ineffective, and gaps in service and external support are most prevalent.

The NDIS workforce challenges and gaps can be severe, and as National Disability Services (NDS) outlined clearly in their informative Submission to the JSC’s NDIS Workforce Inquiry in 202016, such gaps can exist anywhere but are more pronounced in rural (or regional) and remote Australia: and especially for high value allied health therapy services. NDS presented NDIS provider survey data (which is reproduced below from page 3 of their submission) which makes it clear that unmet demand for staff, and hence service capacity, have been most severe for allied health professions.

16 See - NDS Submission NDIS Workforce.pdf (especially pages 2-3)

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SARRAH is committed to expanding allied health service capacity and reach, so that NDIS participants and other community members are able to access services that promote their quality, independence, capacity, potential, health and well-being; whether delivered through allied health professionals and allied health assistants or others where safe and appropriate, through innovative and sustainable mechanisms. SARRAH will continue to engage with DSS and seek greater involvement in NDIS workforce developments.

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4. Addressing the Terms of Reference Priority 1: Improve community understanding of the benefits of working in the care and support sector and strengthen entry pathways for suitable workers to enter the sector

“Five initiatives form an integrated user journey to attract new workers with suitable values, attributes and skills to the care and support sector workforce.”

1. Promote the sector “To help raise awareness in the care and support sector, and change public perception of the work, communication activities will promote opportunities in the care and support sector, highlight success stories, promote support work as a career and highlight the benefits of working in the sector.”

SARRAH strongly supports this action, especially if it entails coordinated mechanisms, targeted and sustained investment to identify and develop fit-for-purpose, rurally-oriented, culturally safe and responsive service and workforce capacity and opportunities for work in the sector across rural and remote Australia. These issues are dealt with elsewhere in the submission.

As governments are well aware, the Health and Social Assistance sector (of which the NDIS is a major part) is by far the largest sector of sustained jobs growth across the economy – projected to generate over 250,000 additional jobs in the next 5 years. This continues a long-term growth trend and far exceeds employment opportunities in any other sector. The need for people to do these jobs is also national, mirroring the need for NDIS and similar services among every population and community.

The value of jobs in the sector have yet to be promoted fully or appreciated by the community. For instance, apart from providing direct services and potentially enhancing the social and economic independence and contribution of participants, a job providing NDIS services:

 Contributes income to local communities – with flow on economic impacts;  Enables people develop and be employed to use skills without having to leave the community;  The nature of the work can often accommodate people who need to balance caring or other responsibilities – who may otherwise have limited labour market opportunities;  Potentially provides for a (more stable) income source to offset the risks associated with changes in business circumstances, including agricultural or commodity industries.

It is imperative that actions to promote opportunities working with the NDIS accord with realistic opportunities to do so.

It is also important that information available on line to support the care and support jobs agenda is accurate and well organised. SARRAH support establishment and continuing development of the website and content. Initial exploration of the Care and Support Jobs website indicates (at time of writing) scope to improve the comprehensiveness, quality and placement of / links to material on the website. SARRAH will take this up with agencies separately.

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2. Develop tools for job seekers “As more people become aware of care and support sector roles, they will need to see if the sector is the right ‘fit’ for them. An online tool for potential workers to self-assess suitability and skills required to work in the sector, based on values and attributes, skills and experience, will be an important first step in a more integrated job seeker journey.”

To be effective to a broad cross-section of the community, tools and resources need to reflect and/or be relevant to a full range and variety of audiences (noting people living in rural and remote communities Aboriginal and Torres Strait Islander people among many others).

As with other elements of the Plan, reach action will have greater impact if developed and progressed in an integrated way with other Plan actions.

We would encourage DSS to seek out opportunities to leverage existing on-line resources and communications platforms as a means of contextualising the NDIS Workforce Plan alongside other initiatives (such as the expansion of Allied Health Rural Generalist and associated AHA positions through SARRAH) and generate a richer, ongoing dialogue than to develop and refine tools and approaches for maximum currency and impact.

3. Improve jobs boards “More targeted jobs boards will then better match suitable job seekers to vacancies based on their values, attributes, skills and experience.”

Supported: again, as an element of the entire Plan being progressed.

The potential benefits would increase with the implementation of the skills passport and, importantly, as employers and service providers become more familiar with and engage a qualified to utilise their skills (autonomously and/or under direct or remote supervision as appropriate) to optimise the outcomes for participants.

SARRAH also reiterates that a concerted effort needs to go toward local skills, training and workforce development, to bolster core local capacity particularly important for rural and remote communities.

4. Leverage employment programs “Employment programs will be leveraged to ensure suitable unemployed job seekers can find work in the sector. This will include enhancing the links between care and support service

   employers and employment service providers, possible improvements in the New

Employment Services Model to outcome payments and performance ratings frameworks, and improving information to job seekers.”

Supported. It is essential that greater investment (existing committed funds or other) be leveraged to build this workforce. Australia’s prevailing budget situation and demographic trends reinforce the need to ensure skills and training investment matches workforce demand

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and jobs. Programs for jobseekers and other Commonwealth investment must match sectors of growth and demand and support pathways to enable it.

Jobs in the Health and Social Assistance sector contribute positively to the economy and communities in many ways, including putting downward pressure on avoidable outlays. Optimising skills and employment opportunities in the sector is unarguably positive. Despite being projected to generate more than 10 new jobs for each new job in the mining sector over the next 5 years, its importance to the economy and community overall have been comparatively constrained, outside of (mixed) acknowledgements associated with the profile provided as a result of the current pandemic.

As all Australian jurisdictions recognise these shortages exist and have identified them as priorities. There should be good scope for increased collaboration ion developing and utilising this workforce to optimal effect across portfolios and between spheres of government.

This could include more place-based innovative projects across a range of rural and remote settings, including “thin markets”. Again, SARRAH and partner organisations would be well placed to work with DSS, the NDIA and other stakeholders to develop and support various place-based innovative service and workforce development projects. SARRAH intends to raise this prospect with DSS directly.

5. Better connect providers to enablers “The Australian Government will use the Boosting the Local Care Workforce program to support stronger connections between employment service providers, universities, VET and NDIS providers.”

SARRAH strongly supports this action, especially to strengthen the regional expertise, with workforce capacity and coordination priorities. There is potential for several other areas of activity to be coordinated with this work and contribute to achieving shared workforce development, sustainability and service goals.

The expanded remit to link with and also enable aged care and veterans’ services is fully supported. SARRAH is interested in engaging with DSS, BCLW and others to progress this work.

Priority 2: Train and support the NDIS workforce

“Four initiatives will provide a stronger learning system and culture throughout the career of an NDIS worker”

6. Develop micro-credentials and training “Accredited micro-credentials will enable workers to upskill. Over time, these micro-

credentials and other learning activities based on skill sets may build towards a recognised qualification. Non-accredited training remains an important tool for educating staff on NDIS standards and an organisation’s service expectations.”

SARRAH supports further development and delivery of micro-credentials as a means of increasing workforce skills and enabling career development.

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Micro-credentialing has great potential to expand and extend service reach and capacity where the core skills and appropriate supervision and supports are in place (including digitally enabled or other appropriate innovative and efficient options).

Rural-proof workforce solutions require the flexibility that micro-credentialing and skills training can bring. However, there needs to be close alignment between AHP and AHA skills sets to maintain clear governance frameworks that enable the safe delegation of work by the AHP to the AHA. The assistant worker must be clearly identifiable in their scope of practice and understand their professional boundaries. This relationship between the AHP and AHA must be preserved to ensure that effective models of care that extend the reach of the AHP can be replicated and promoted.

To this end, AHPs and AHAs must be seen as two sides of the same coin, and workforce training and development strategies should be developed together. This will ensure that AHPs are equipped to utilise AHAs to their full scope of practice and facilitate the growth of service delivery models where AHAs can be deployed.

There is also a need to ensure the assistant worker has a qualification recognised by jurisdictional industrial awards to align government and non-government roles and facilitate movement of skilled workers across sectors. Close association of the AHA qualification with the allied health professions will assist this.

Consequently, the approach must ensure micro-credentials build on and complement core capabilities that are fit-for-purpose and that micro-credentials are not used (knowingly or otherwise) to encourage people who do not have core skills and qualifications or appropriate safety and professional clinical supervision arrangements in place to deliver services, regardless of the setting.

Two fundamental issues could inform how core VET training for health and social assistance sector are configured – both will impact NDIS Workforce Plan implementation:

a) Given the aim is to increase skill levels across the board while enabling workforce adaptability and mobility so those skills can be used across a range of settings, should skills training be structured around i) work sectors or ii) role-based skills that can be applied across multiple work settings and sectors?

With SARRAH’s focus on services rural and remote communities, we are concerned that sector– oriented training programs may limit applicability, viability access and opportunities to develop local workforce capacity. Broader, skills-oriented training packages (e.g. AHA) provide scope for sector-oriented electives (including NDIS and disability services). SARRAH suggests developing the package around the required skillset to meet broader community need provides flexibility and builds capacity overall.

Currently, ahead of the transition to the new Skills Reform arrangements which are to come into effect in 2022, multiple training packages directly or closely related to the NDIS workforce Plan are being reviewed through soon-to-be phased on Industry Reference Committee (IRC) structures and arrangements. SARRAHs experience of the process suggests the Reviews, will improve the training packages as distinct items. However, SARRAH is concerned that the impetus to complete (in some cases overdue) Reviews is being driven by administrative rather than workforce and that Reviews could “lock in” training arrangements just as the coincident, strategic NSCs Care Workforce Labour Market Study, which may identify structural problems with

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the current approach is due to report. Additionally, it presents the same risks when details of the NDIS Workforce Plan actions and implementation and components of the Government’s aged care workforce development strategy remain under development.

SARRAH is not seeking to delay workforce development, but is concerned by apparent inconsistencies in how training packages are structured, the potential for increased confusion and the prospect of embedding training arrangements that do not align well with overarching workforce goals and objectives, further frustrating efforts to ensure enhanced and viable workforce training and development pathways are built across rural and remote Australia.

To illustrate, the Direct Client Care and Support Industry Reference Committee (IRC) is currently Reviewing the Allied Health Assistance (AHA) Certs III and IV training packages; the Disability Support IRC and the Aged Services IRC are both updating qualifications and Units of Competency in the Cert III in Individual Support, the Cert IV in Disability and the Cert IV in Ageing Support. 17 SARRAH understands IRCs communicate and that each IRC is expected to work with other IRCs with an interest in qualifications relevant to their sector to ensure industry needs are considered and met. However, the priority for the sector-oriented skills Reviews are, understandably, to meet that specific employment sector’s workforce needs, not broader workforce need or mobility. In a high service demand and low workforce supply situation (as is the case), there are few incentives for employers in sectors facing these stresses to broaden the focus of training (unless it delivers a direct benefit to their sector) or facilitate mobility outside of their sector. Comparing the three Reviews identified:

The Disability Support IRC   The Aged Services IRC is    The Direct Client Care and

is responsible for:             responsible for:             Support IRC is responsible

for:

   Reviewing and updating          Reforming national training       National training package

national training package         package qualifications and          qualifications relevant

qualifications, skill sets and          skill sets needed by the            to Disability, Mental health,

units of competency needed      aged services industry            Alcohol and other drugs,

by the disability support           Examining new approaches        Leisure and health, Allied

sector                              to career structuring and           health assistance, and

   Examining innovative              progression in the sector,         Health services assistance.

training and career and the education pathways

structures etc                  needed to support these          These qualifications are

   The IRC was established to      Scoping opportunities for          included in the CHC

respond to the increasing           collaboration across VET,        Community

demand for disability               higher education and a            Services and HLT Health

support workers, driven in         range of industry sectors to        Training Package.

particular by the rollout of tackle the challenges of an the National Disability ageing society. Insurance Scheme (NDIS).

17 For further detail see - https://www.aisc.net.au/committee/aged-services-industry-reference-committee; https://www.aisc.net.au/committee/direct-client-care-and-support-industry-reference-committee; https://www.aisc.net.au/committee/disability-support-industry-reference-committee.

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Using common training units/modules across various packages can streamline functions, improve system efficiency, support quality and standards and facilitate development of transferable skills.

 However, there are concerns that mixing sector-focused and role-focused structures with subjective adoption of units determined by sector (e.g. aged care provider or disability service provider) specialists risks confusing the roles and potentially missing important core role-based content, safe practice standards (such as consultation and supervision/delegation requirements) that are embedded in structured role-focused packages (such as the AHA package).  The result is a mix of sector-focussed and role-focussed programs, and the risk of continuing fragmentation.

This approach is unlikely to meet the needs of communities, where much of the training needed to develop the local health and social assistance workforce is not supported or available, despite community need.

On a purely practical basis, especially in smaller communities where the opportunity, demand and likelihood of people working as “generalists” across several sectors, structuring programs around core PCA or AHA skills sets, with complementary elective or micro-credentialing to facilitate mobility. The alternative service sector training focus inevitably puts less emphasis on enabling adaptability and mobility across and between service sectors and settings.

b) What is needed to address bottlenecks in delivering workforce training and upskilling / development – whether core qualifications or micro-credentials?  Scoping, assessing and planning for services to meet identified community service need/demand;  Articulating the workforce need and promoting the opportunities associated with it;  Ensure local or reasonable regional access to training courses and infrastructure, including remote learning options where required (i.e. RTOs must deliver programs where needed);  Services must be available to support clinical placement/work experience and supervisory requirements;  Service delivery and employment physical and human infrastructure;  Enabling/flexibility training, service funding and employment conditions.

These are fundamental issues for workforce and service supply and development which impact on the NDIS service deliverability, quality and impact.

SARRAH is in contact with DSS, the National skills Commission and other key stakeholders and will continue to seek opportunities to contribute meaningfully to the development and implementation of the NDIS Workforce Plan.

7. Develop a professional network for the sector “A Care and Support Worker Professional Network will promote excellence via a professional network which provides peer mentoring, professional development, and opportunities to collaborate across, and deepen practices within, disciplines.”

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Professional networking and support is valuable and should be available for care and support workers who undertake important and challenging roles. A professional network would complement the skills passport and other mechanisms designed to strengthen and enable the sector and its capacity.

SARRAH notes there are existing networks which care and support workers may also find of value; depending on the precise nature and context of their work: for example; The Allied Health Assistance Network of Australia (AHANA); the Mental Health Professions Network (MHPN); or others.

Equally, organisations such as SARRAH and IAHA are multidisciplinary and include members other than specific professionals, who value the connection, networks and resources such organisations can provide. Such connections may helpfully complement the support provided through a Care and Support Worker Professional Network.

8. Establish a skills passport “As NDIS workers undertake different training and development based on their needs, training will be recorded on a skills passport. The skills passport will strengthen the recognition of training in the sector and support career development.”

 SARRAH supports the skills passport concept. Recognition of skills and qualifications on a national (cross jurisdiction) and cross sector basis will support skills development incentives, utilisation, career movement and development, efficiency and mobility to both meet shifts in demand and offset negative impacts of service and employment downturns in a given sector or location.  Further, within communities it will assist to facilitate people with skills to apply those skills so as to meet several needs in the community.  The Recommendation is also consistent with other important developments, such as more common, national approaches to working with children and working with vulnerable people checks.

9. Grow traineeships and student placements “Students will be able to discover entry-level pathways into the care and support sector through supported traineeships. These supports will enable providers to offer more entry-level opportunities to inexperienced workers.”

Shortages in traineeships, student placement capacity, supervisory workforce, support and infrastructure are an unfortunate and endemic reality across much of rural and remote Australia. Components of the system needed to build local workforce and service delivery capacity exist but often not in unison or on the scale needed to meet current local, let alone growing, demand. This constrains NDIS VET and university trained workforce growth and development. It is critical that this be addressed. Doing so effectively will require investment in coordinated and distributed workforce development models tailored to local circumstances. The lack of persistent coherence in addressing these issues to date is evident in the chronic skilled workforce

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shortages that impact the disability services, aged care, mental health, broader health, veterans’ and other services.

A strong case exists for increasing supported traineeship programs for AHAs, drawing on similar approaches in some public settings as well as the National Aboriginal and Torres Strait Islander Health Workforce Academy Model (involving school-based traineeships).

The approach involves a formal training pathway overseen by a General training Organisation (GTO) which supports the trainees to gain their credentials on the job, supports the employer in adopting service delivery models that utilise AHAs, and works to reduce some of the systemic challenges, such as finding AHPs to undertake competency assessments. Promulgating the approach requires recognition of pathway and enabling funding (which may be primarily a responsibility of the Department of Education, Skills and Employment (DESE).

Workforce and service capacity development also requires career pathways to be facilitated, including through VET and higher education. Additionally, there is industrial relations work to be done to recognise and grow roles for assistant workers with advanced skills.

 For example, a Cert IV AHA may go on to acquire a science degree as a fore-runner to an entry-level masters in an AH discipline. But at this point there is no recognised pay point for a degree-qualified AHA (such as, for example, a “Health and Rehabilitation Science” degree).

 These workers can have important roles in care coordination and be highly qualified and capable participant-focused navigators of capacity building service systems. However, enabling this may need an intermediary pay point to be established for workers who hold a three-year science degree and as a precursor to studying an AH discipline and to incentivise this transition.

Workforce development and growth, especially on a national scale, is complex and dynamic and requires coordination of educating and training systems/providers, students, placement supervisors and employers.

 Arguably in previous decades professions, tradespeople and employers had a stronger workplace, service or enterprise level commitment to employing, training and developing a workforce or professional not least because the employee was more likely to stay with that workplace or employer for a lengthy period, developing capacity, skills, output and productivity over time and hence ‘repaid’ the investment.  Shifts in workforce mobility have resulted in a coincident reluctance by many employers to engage staff in the training or early career stage. This reluctance limits work-based training capacity and, unsurprisingly, contributes to dissatisfaction by (often the same) employers about the level of work readiness among early career staff.

Fortunately, other employers, including NDIS providers, recognise the attraction and retention value of development opportunities and this often extends to a willingness to take on student placements.

Australia’s effort at major health workforce reform is highly instructive given the current situation and the NDIS Workforce Plan. COAG led a major national health workforce reform process in the late 2010’s – early 2020s was partially successful in that it:

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 led to substantial increases in the health workforce (and university education capacity) overall:  improved national supply issues and consistency in regulatory (mobility enabling and more efficient) requirements for many professions; but the reforms  proved less successful in delivering on reform objectives such as distribution (a key and continuing challenge), workforce flexibility and optimising scopes of practice and embedding stronger interdisciplinary and collaborative practice.

The shortfalls in continuing to deliver on those reforms underlie many of the service and workforce challenges the NDIS and other services face today.

As with the NDIS, COAG engaged the Productivity Commission to conduct a detailed study to assist governments implement a national reform process to meet contemporary and future needs18. Like the NDIS, prevailing workforce shortages were identified as a major threat to our health system’s capacity to meet community need. A summary of the ensuing reform process (in 2008) and key the elements of the package are available here. There was substantial, national and cross sector engagement in the reform process, with a strong emphasis on growing trainee, student and early career work-based capacity. An issues paper produced by SARRAHs Executive Officer at the time (2007) Clinical Education for allied health students and Rural Clinical Placements19 remains pertinent and details fundamental actions that are needed to support the NDIS Workforce Plan.

Structural issues already exist in placement capacity – for VET and university students, with massive demand and pressure for necessary places (required to graduate) that are in limited supply, especially in rural and remote areas. Increasing that supply is crucial to the NDIS and other workforce development plans. There are several mechanisms that could be employed to increase training and placement capacity, including:

 Increasing the priority given to implementing Recommendations in the NRHCs allied health report of June 2020;  Urgently reviewing barriers and gaps to student placements and implementing mechanisms to increase supply, drawing on existing studies and analyses of the barriers and mechanisms to address them20.

There is considerable scope to better support and inform service providers of the benefits of clinical placements to their operations, especially in the medium to long-term, or to promote approaches that have proven to be more conducive to placements optimising the value to trainees/students and to services. For instance:

18 Health Workforce - Productivity Commission (pc.gov.au) 19 https://www.sarrah.org.au/sites/default/files/docs/rural clinical education for allied health students issues paper aug ust 2007.pdf 20 For instance, see http://www.ruralhealth.org.au/15nrhc/sites/default/files/D8-5 Stronach.pdf; https://pubmed.ncbi.nlm.nih.gov/25916254/; https://www.rcslt.org/wp-content/uploads/2021/02/RSPH-Expanding public-health-placements-to-AHP-students-report.pdf (evidence from the UK); and https://www1.health.gov.au/internet/main/publishing.nsf/Content/2922D6D8BBCE122FCA2581D30076D09A/$File/Nation al%20Rural%20Health%20Commissioner’s%20Allied%20Health%20Report%20to%20the%20Minister%20June%202020.pdf

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 Research from several academic practitioners in this area point to the workforce capacity and financial gains to service providers of well-constructed and supported placements21 22;  Use of clinical educators, employed by the education or training provider, to work closely with service providers and deliver workplace supports directly as a means of reducing pressure on providers; o This mechanism is often cited positively and as an alternative to placement payment arrangements which can have perverse and inflationary impacts on placement supply overall;  Where trainees and students are already connected to a community, the value and the longer-term prospect of building local capacity through viable placements (and course offerings) could be a highly effective investment;  Exemplar placement arrangements possibly identified by existing placement (NDIS or other) providers working with education and training providers could be examined for further roll-out – noting what works for them and why;  Note that several public health services are using students to deliver services (including COVID 19 vaccinations in NSW and possibly other states).

As a final note to demonstrate why greater coordination of the training, placement and workforce development activities are needed:

 During the recent Review of AHA VET training packages, many stakeholders supported an increase in there the work placement requirement for Cert III trainees from 80 hours to 120 hours. SARRAH agrees that work placements are of critical value to training and do not oppose the increase. The emphasis of the Review was on the training content.  However, as we have noted, allied health services in rural and remote Australia are in chronic short supply, which means shortages in work placement opportunities and very high competition for limited placement opportunities.  Increasing placement time supports quality training, but in these circumstances, also has practical implications, adding impediments to course enrolment and completion, with consequent negative impacts for workforce supply.

These are important contextual considerations that need to be addressed at a more systemic level.

21 https://search.informit.org/doi/abs/10.3316/ielapa.704872374543034 22 https://www.publish.csiro.au/ah/pdf/AH18088

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Priority 3: Reduce red tape, facilitate new service models and innovation, and provide more market information about business opportunities in the care and support sector

“Seven initiatives have been identified to remove red tape, encourage new service models and improve market information to enable efficient operation”

10. Align regulation and worker screening “Aligning provider regulation and worker screening requirements across the care and support sector will increase the number of workers and providers able to operate in the market, providing greater choice and control for participants without compromising on quality and safeguarding.”

Reducing the regulatory burden for service providers, especially given many operate across multiple service sectors would promote potential provider incentives to engage (or remain engaged) and to increase capacity and incentives to employ. The issue has been raised consistently by SARRAH members, including during SARRAHs Summit in February 2020, A pathway to improved allied health for rural Australians - SARRAH. Government agencies responsible for service systems would know a high proportion of service providers work across multiple sectors, each with their own (often overlapping as well differentiated) regulatory and compliance requirements.

Regulatory and compliance requirements provide important safeguards for safety and quality, and these should not be diminished by streamlining those arrangements. The findings of the Aged Care Royal Commission and the Disability royal Commission both demonstrate the need for quality based regulation and performance monitoring, and the need for some providers to substantially improve their adherence to appropriate service and delivery standards, including AHP and AHA services, in line with the requirements described elsewhere in this Submission.

SARRAH is encouraged by the focus of the Government’s Deregulation Agenda, notably the emphasis on addressing “duplication, interaction and cumulative burden of regulation imposed within and across Commonwealth, state, territory and local jurisdictions”23 .

 SARRAH notes the additional 2021-22 Budget commitment to progress the agenda and believes the allied health service sector in rural and remote Australia, presents an important focal point for the Deregulation Taskforce to identify the overall regulatory impact of multiple requirements across the NDIS, aged care, mental and other health, veteran’s and other service systems utilising the same workforce and essential service capacity.  To this end, SARRAH will seek to promote, in consultation with DSS and others, a project to highlight and enable these issues to be addressed as a priority, noting the imperative to remove service barriers for NDIS participants and others.  SARRAH believes our members and key stakeholders could provide ready and well informed insights to such a process, and that it would contribute tangible service benefits to advance the NDIS Workforce Plan.

23 See - https://pmc.gov.au/domestic-policy/deregulation-taskforce/terms-reference

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As to the costs borne by allied health rural and remote practices and efforts to alleviate them, SARRAH has previously proposed work to enable capacity, but as yet have not secured funding support to conduct the project. The proposal is designed to assist business development and (re-)structuring supports designed to:

 Enable efficient internal business operations such as: service level guidance and resources on scopes of service; funding/income stream mechanisms, procedural, process and claiming supports; compliance and reporting frameworks and resources; case study examples; ICT platforms and tools (subject to resourcing); and

 Promote engagement and opportunities to develop and participate in multi-sector / shared service / coordinated patient care with:

o Other allied health practitioners (inter-professional) / communities of practise;

o Leveraging and engaging with and through:

• Local Health Networks (LHNs) and Primary Health Networks (PHNs);
• General practices;
• Local government;
• University Departments of Rural Health and Rural Workforce Agencies
• Relevant peak bodies, such as National Disability Services (NDS), Aged and

Community Services Australia (ACSA) and Leading Age Services

Australia(LASA); and

• Aboriginal Community Controlled Health Organisations, local aged care providers, disability service providers and relevant care planners (such as NDIS Local Area Coordinators).

The project could be developed with a central focus on increasing NDIS service capacity and complement other Grant and related developments currently underway or being developed.

11. Improve pricing approaches “The sustainability and effective operation of the market will also be supported by continued improvements to NDIS pricing approaches.”

SARRAH would welcome the opportunity to be engaged directly with DSS and the NDIA in any future pricing reviews, especially as they impact rural and remote service provision and access.

Pricing is an essential consideration for determining access in “thin markets”. However, pricing strategies, without developing workforce and service system supports described are likely to result in increased costs overall and long-term and/or poorer participant access and outcomes that could be otherwise be achieved. SARRAH notes that a key principle “underlying NDIA’s pricing philosophy include: … to intervene where necessary to support developing markets.”24 And was pleased to be able to contribute to discussions in early 2021 conducted by the NDIA to inform pricing arrangements for therapy supports within the NDIS.

24 From page 4 of the Sector Consultation Interview Provider Peak Interview Guide .

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SARRAH acknowledges that NDIA pricing arrangements are generally better aligned to service costs than are other potential funding sources (e.g. the limited scope and amount of MBS subsidised AHP items and, generally, in aged care). The provision of loadings in respect of remote provision are also an important aspect of NDIS pricing. The NDIA’s approach in setting pricing needs to be better informed by the actual participant and practitioner relationships and service need and of the various effective delivery options and costs involved, but provides a sound basis from which fit-for-purpose, flexible and sustainable service improvements could be achieved. Developments should include arrangements that:

 Facilitate tele- or other remote servicing options, where the participant and service provider are able to establish an appropriate and effective relationship and where continuity of care and outcomes are best facilitated by a mix of face-to-face (including establishment) and remote service options; and  Enable services to be provided to participants on a viable ongoing basis where direct delivery may involve an AHA (preferably local) working to and under the direction of an AHP, who may be located elsewhere.

There is considerable scope for pricing strategies to be modified to better suit the varying circumstances and needs of rural and remote communities. Applying flexibility to service and funding mechanisms puts the integrity, sustainability and public support for the Scheme at considerably less risk than persisting with comparatively rigid approaches that misconstrue system uniformity as equitable access. The objectives of the Scheme, as reflected in the outcomes sought for participants, should be paramount in service system design and for people living in rural and remote Australia that means service and workforce systems are developed on the basis of:

 in-depth understanding of how therapy supports are currently delivered and the gaps in (assessment and) delivery  challenges and opportunities for improvement in funding and delivering therapy supports  objective, access and outcomes based, assessment of alternative funding models and how they may improve outcomes – including potentially, bundled payments, outcomes based payments and/or capitation.

12. Provide market demand information “Providers will be able to expand services across government programs and in thin markets through access to market demand information across the care and support sector.”

Addressing demand in “thin markets” requires knowing what the actual level of (legislatively supported) demand is, not just current service levels; and what services exist and/or potentially could deliver services into that community. SARRAH acknowledges recent improvements in NDIS data availability, but to SARRAHs knowledge considerable further work is needed. In many communities (as discussed elsewhere) services are very limited or do not exist.

However there are also circumstances where allied health services exist but the impediments to engage or to increase the service offer to NDIS participants is constrained. These were among the issues discussed at a SARRAH National Forum held in February 2020 involving then Minister for Regional Health, the Hon Mark Coulton MP, Professor Paul Worley (then NRHC), several officials

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from the NDIS, DSS, Health and other agencies and a range of rural allied health services providers, services and other key stakeholders. A report on the Forum is available here. An example research article describing some of the challenges of providing NDIS-commissioned rallied health in rural areas is available here.

Rural practitioners, those who provide NDIS services and those who have considered it but decided not to, offer a wealth of insight to NDIS Workforce Plan development and implementation if connected effectively to that process. SARRAH would welcome the opportunity to facilitate deeper engagement of rural practitioners with the process.

SARRAH supports better, more meaningful and timely information about the NDIS Scheme, being available about participant populations and needs information (subject to privacy considerations), service demand and gaps. SARRAH notes the availability of data has been improving, which indicates a helpful maturing of the Scheme.

As part of these developments (e.g. the Demand map), SARRAH suggests DSS also a number of conduct/ support independent assessments to identify the potential participant population across a selection of rural and remote communities (to compare with identified participant numbers). The results could inform further engagement strategies, service and workforce developments and demand map refinement. The information would particularly assist the development of innovative market responses in ‘thin markets’, and enhance service viability and cost effective expenditure.

13. Help participants to find supports online “Participants will be able to more easily identify services and supports online.”

Supported. More accessible and accurate information on-line should enable many participants’ to access a fuller range of services and supports. Improvements in connectivity and other access issues are also welcome as many people continue to experience difficulties in the regard.

SARRAH stresses that online options must be seen as a complement to other, local and/or face to-face services and supports and not a replacement alternative to them.

14. More options to use allied health assistants “Improved connections between allied health professionals, assistants and support workers will improve participant supports and health outcomes.”

Allied Health Assistants are a key potential workforce that is increasingly proving its capacity and value across and between the NDIS, aged care, health and other service systems, but has yet to be recognised and supported at the system level to deliver participant/client/patient impacts and/or the service reach and sustainability benefits their training and skills are tailored to achieve. AHA skills sets and capability are extremely well designed to meet the needs of communities trying to meet disability related service demands, shifts in the burden of disease toward lifestyle related illness and reduced independence, management of chronic conditions, rehabilitation, restorative care and healthy ageing.

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Despite this, AHAs as a broadly-skilled and specialised, cross-sector and adaptable workforce do not receive the systemic support needed to ensure their skills and capacity can be drawn on where they could be. As discussed above, micro-credentialing for staff without the core AHA skillset will improve overall workforce, but the inherent nature of core AHA training is ideally suited to the delivery circumstances other options are being worked around to meet. There are many examples where AHAs are being utilised in public, private and community service settings with impressive results25. These should be drawn upon, with a view to promulgating their use within frameworks of appropriate AHP/AHA supervision and delegation (which exist) and where the full scope of practice of AHAs can be utilised to complement those of the AHP(s) they work with and for the overall benefit of the participant. It is clear from the National Disability Services’ (NDS) workforce surveys that AHP workforce access and shortages are a major constraint on NDIS services, and that expanding service capacity utilising AHAs should be an immediate priority. As the table on page 20, copied from the taken from the NDS Submission to the JSCs NDIS Workforce Inquiry, illustrates the extent to which the sector currently struggles to deliver on AHP service needs.26

In terms of ensuring there is an accurate framework ins applied in developing the workforce, it is imperative to recognise that AHAs can only (under regulatory and safety and quality requirements) deliver services when they are working with and under the supervision of an AHP, even where the specific skills and experience of the AHA enable that supervision to be at a distance and on a relatively infrequent and as needs basis. As indicated earlier, AHAs should not work beyond their scope of practice or outside of an appropriate supervisory relationship, however this does not unduly constrain their immense value in delivering NDIS services.

Nit is noteworthy that the NDIS is the only regulatory framework that recognises and remunerates work undertaken by an AHA: a very positive approach. However, this does not offset the costs borne by the AHP in supporting the AHA to deliver services safely and to a high quality. There are options to address this concern, such as:

 The work of the AHP being be recognised separately and remunerated;

 Alternatively do not distinguish different pay rates based on who is delivering it.

The second option recognises AHPs are intrinsic to the service model and are ultimately professionally responsible for the work undertaken. It would also contain process related administrative burden.

There is a strong argument that in a fee-for-service where participants have choice as to provision arrangements remuneration should be based on the service model, and be agnostic about whether it’s the AHP or the AHA delivering the service, given the AHP is ultimately required and is responsible for delivering services.

As noted previously, SARRAH is currently implementing an expansion of the AHRGP pathway into private and community based settings across rural and remote Australia. The next phase of this approach, announced in the 2021-22 Budget includes funding for 30 AHA places to work in conjunction with AHPs in a variety of settings, including services working with NDIS participants. There is great potential for the initiative to be further expanded, with a specific focus on NDIS

25 For example, see Vitality Passport program wins the 2020 Primary Healthcare Award for Promoting Healthy Living —

Murrumbidgee Primary Health Network (mphn.org.au)

26 See - NDS Submission NDIS Workforce.pdf (especially pages 2-3)

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service capacity and expansion. Further, during the implementation of the AHRGP SARRAH has identified a high demand for, and is in the late stages of developing, specific (on-line) training modules to support AHPs to work more effectively with AHA staff. The need for such development has been regularly identified by AHPs and AHAs and cited as a gap in existing curricula, which adds to the practice challenges of graduates. SARRAH will, given capacity, further develop these training resources and delivery capacity, with CPD recognition.

Another resource that was developed specifically to assist AHPs and others (including disability service provision) is SARRAHs Transition Toolkit for Rural and Remote Practice. The Toolkit is available on-line, was originally developed with content developed and provided free and on a voluntary basis to SARRAH and has been a highly regarded resource for health practitioners’ moving to and/or commencing practice in rural and remote Australia and by universities in their health student curricula. The Toolkit continues to be used but much of the content requires updating and the technical and presentation aspects brought up to contemporary standard. While SARRAH is able to source the content providers who are willing to develop, provide and assess content we have yet to source the project resourcing to enable this update, including specific NDIS content, to be developed and made available.

These resources would complement and add to existing, quality resources, such as those available through the NDS.27

15. Support telehealth in rural and remote areas “Access to professional support via telehealth will allow allied health professionals in rural and remote areas to deliver a greater range of supports in regional and remote communities.”

There focus on telehealth as an enabler of allied health service access, reach, continuity and quality of care is reasonable and justified. It potentially improves NDIS participants’ options, choice and control considerably.

Coupled with other allied health workforce and service access and distribution measures (already discussed) the impact on service capacity and quality should be substantial and positive: with additional benefits in terms of teaching and training capacity and impactful, cost effective service, sustainable delivery. SARRAH members are expert in and closely engaged in telehealth developments already, having adapted practice and service delivery modes to suit the circumstances they and clients face. SARRAH members, including members of our Digital Health Community of Practice (representing multiple service types and remote service settings) could be a ready and informed source of input and advice to DSS and others, were that input to be sought. It is being offered.

In addition to the often cited limitations and challenges with digital and t elehealth (connectivity, hardware capacity, privacy and confidentiality considerations etc.) the biggest risk to telehealth improving service access and outcomes for NDIS participants and others is the risk that telehealth is used (deliberately or otherwise) as a service replacement or simplistic cost cutting measure, without the necessary concomitant local workforce development (e.g. AHAs) and service capacity infrastructure to leverage the value for participants. Other enablers, such as support for software and other supports, presently provided to GPs but generally not other

27 For example, see Allied Health Workforce Resource (nds.org.au) and Supervision and Support of Allied Health Professionals and Therapy Assistants working remotely in Disability

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health practitioners, would also assist to support overall service capacity in rural and remote settings.

SARRAH would welcome substantive engagement in this area.

16. Support the Indigenous community controlled sector “Building the Aboriginal and Torres Strait Islander community-controlled sector will enhance culturally safe NDIS services.”

SARRAH strongly supports measures to increase the capacity of the Aboriginal and Torres Strait Islander community controlled sector to provide much needed culturally safe and responsive to NDIS services, and to improve cultural safety and responsiveness of NDIS services more broadly, to further enable access and quality of care. Advocacy bodies, such as First Peoples’ Disability Network (FPDN) and Indigenous Allied Health Australia (IAHA), have long argued that addressing the level of need, under-assessed eligibility and access to appropriate and effective services through NDIS require major improvements in NDIS assessment and service capacity, not least in development and distribution of a skilled workforce.

The National Partnership on Closing the Gap, was agreed by the Commonwealth Government, state and territory governments and the Council of Aboriginal and Torres Strait Islander Peaks in July 2020. The Partnership Agreement commits parties to shared decision-making and acknowledges that past approaches, while often well meaning, have been ineffective and even reinforced Aboriginal and Torres Strait Islander disadvantage. The Agreement sets clear directions and priorities that should be pursued vigorously under the NDIS Workforce Plan. Specifically:

The Fours Priority Reform Areas are:

 Formal Partnerships and Shared Decision Making

 Building the community-controlled sector  Improving mainstream institutions and  Shared Access to Data and Information at a Regional Level.

For the specific purposes of the NDIS Workforce Plan, all priorities are relevant, with two especially needed to build workforce and service capacity immediately:

a. Building the community-controlled sector: There is a strong and sustainable Aboriginal and Torres Strait Islander community-controlled sector delivering high quality services to meet the needs of Aboriginal and Torres Strait Islander people across the country.

b. Improving mainstream institutions: Governm ents, their organisations and their institutions are accountable for Closing the Gap and are culturally safe and responsive to the needs of Aboriginal and Torres Strait Islander people, including through the services they fund.

The Disability sector is identified as one of four to be prioritised for “joint national strengthening effort” in the first instance, with sector strengthening plans are to “be in line with the strong community-controlled sector elements and the following four streams:

a. Workforce b. Capital infrastructure c. Service provision Page | 38

d. Governance.”28 The paucity of underlying health, disability and other underlying service system infrastructure, workforce capacity and culturally safe services appears to have been massively underestimated at the commencement of the NDIS and clearly impeded access, take-up and effective delivery for Aboriginal and Torres Strait Islander people, most obviously but not exclusively in remote and rural communities. The most developed and well known service system for Aboriginal and Torres Strait Islander people is the community controlled health organisation (ACCHO) sector. There appears to have been a strong assumption that ACCHOs would fill NDIS service gaps, especially as other efforts to draw on more mainstream, (often) metropolitan-based providers without strong community connection or cultural knowledge and capacity to address “thin markets” were demonstrably inadequate. However, many ACCHOs were hesitant to engage in NDIS service delivery for a range of reasons, including (among other issues) financial concerns and the capacity to deliver often complex disability-related services. In a 2018 Submission on the NDIS, NACCHO stated:

“Based on our experience providing health services (emphasis added by SARRAH), we suspect that Aboriginal people are less likely to use disability services than non indigenous people owing to:

 lack of available disability services, especially in remote areas  lack of available disability services that are culturally competent  lack of accessible disability services (owing to barriers faced by some Aboriginal people including the need to use interpreters, lack of access and skills to use on line information, needing to travel long distances, not having transport, unstable housing and many other potential issues).”29

The highlighted wording in the above quote reflects a key point Aboriginal and Torres Strait Islander people, disability advocates and other stakeholders have been making for years: health and disability issues, populations, services and policies are distinct: they overlap and need to coordinate/interact effectively to deliver results for people, but they are not the same. That factor has to be addressed seriously going forward. The NACCHO Submission profiled other factors and concerns regarding NDIS service capacity and expectations.

These issues are crucial to understand, not only for ensuring the workforce and service capacity for Aboriginal and Torres Strait Islander people, but everyone. The health and disability support systems are not the same and while there are commonalities, not least in the need for allied health and related enabling and therapeutic service capacity, the system, funding and operational requirements applied to service providers preclude holistic and/or tailored care to individuals and communities. The NDIS Workforce Plan, implemented well, could contribute substantially to addressing these service quality, access and efficiency impediments.

Over the past 12-24 months especially, the Commonwealth has sought to work with the ACCHO sector to increase NDIS service capacity, such as by providing $5.9 million in October 2020 to “help build capacity for these organisations to transition to and operate as NDIS providers and,

28 https://www.closingthegap.gov.au/national-agreement/national-agreement-closing-the-gap/6-priority-reform-areas

29 https://nacchocommunique.com/wp-content/uploads/2018/02/naccho-ndis-submission.pdf (page 4).

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in turn, grow the Aboriginal and Torres Strait Islander NDIS market and workforce”30, and enabling NDIS Ready: Aboriginal and Torres Strait Islander Market Capability, to “address the basic establishment costs, and/or business and technical challenges in registering and delivering services under the NDIS to equip themselves to operate more effectively long-term under the NDIS… ”. These measures should help ACCHOs to build business capacity to increase NDIS services, but, a far more deliberate, focused and long-term commitment is needed to build the necessary workforce and service capacity.

Aboriginal and Torres Strait Islander Australians are more likely to be employed in the Health and Social Assistance sector than any other sector of the economy.

The Census recorded that Health Care and Social Assistance (23 per cent) was the most common employment industry for Aboriginal and Torres Strait Islander females aged 15 to 64 years, followed by Education and Training (14 per cent) and Public Administration and Safety and Retail Trade (both 11 per cent).31

Given the projected growth of 250,000 new jobs in this sector over the next 5 years, this should present a major opportunity for increased employment for Aboriginal and Torres Strait Islander people, well aligned with CtG National Partnership priorities in employment, education, disability and health. There is clearly strong interest, capacity and a growing cohort of role models for the sector. As Universities Australia report, Indigenous students are more likely than non-Indigenous students to enrol in courses in health courses (20.8 per cent), which is the second highest area broad field of study for Indigenous students behind “society and culture”. (Source: Universities Australia - Indigenous Strategy Annual Report, March 2021, page 39).

30 Deliv ering the NDIS: Improving access for Aboriginal and Torres Strait Islander Communities | NDIS

31 https://www.abs.gov.au/ausstats/abs@.nsf/mediareleasesbyReleaseDate/142C08A784A1B5C0CA2581BF001EE22C?Ope nDocument

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Similar patterns might be expected for VET sector training enrolments, noting the NCVER Report (2017), Indigenous VET participation, completion and outcomes: change over the past decade found “Graduates from the Health and Education fields of education are most likely to be employed after training, with the majority of these graduates already employed before training” (page 12). However, despite employment demand in the HSA sector, NCVER data shows 4.2% of 2020 enrolments in VET Health courses identified as Aboriginal or Torres Strait Islander, proportionately lower than in several other areas of study, including engineering, architecture and building, agriculture and environmental studies and management and commerce. 32

That Aboriginal and Torres Strait Islander people are enrolling in a broad range of education and career pathways is welcome news, especially where their under-representation signals systemic barriers to employment. Nonetheless, considering a) jobs growth opportunities b) existing sector connections c) apparent preferences for university education d) the relatively high proportion of Aboriginal and Torres Strait Islander people in the 15-34 age group33 and persistently and significantly higher levels of unemployment for this cohort compared with the non-Indigenous population, current enrolment levels appear unreasonably low. This warrants urgent analysis and action, especially recognising the gaps already known to inhibit participation in training and career pathways and initiatives demonstrated to address them. SARRAH refers the JSC to IAHA’s workforce development initiatives in this respect.

Allied health services area major and fundamental component of NDIS services. Based on service system investments and funding structures, allied health services are recognised and valued more strongly in the NDIS for their enabling, therapeutic and preventative focus than

32 https://www.ncver.edu.au/research-and-statistics/data/databuilder - accessed 3 September 2021. 33 https://www.abs.gov.au/statistics/people/aboriginal-and-torres-strait-islander-peoples/estimates-aboriginal-and torres-strait-islander-australians/latest-release

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they are in Commonwealth health and aged care policy and programs, which remain inherently medico-centric. While acknowledging some important (although comparatively small) developments in support for allied health service capacity in the 2021-22 Commonwealth Budget, the relative shortage of allied health service focus in Commonwealth primary health and other service investments is also reflected in the staffing profile of the ACCHO sector: which must be addressed if Aboriginal and Torres Strait Islander people are to access NDIS services on an equitable basis through that sector.

 Precise figures on the proportion of ACCHO sector staffing who classified as allied health is not readily available publicly;  The most detailed public information available classifies Allied Health Professionals together with (non-GP) Medical Specialists – and dates from June 2018;34  That information shows that on an FTE basis AHPs and Medical Specialists (together) made up 5.6% of the total ACCHO clinical/health workforce (reported) and 3.3% of the total workforce – less than half the proportion of GPs and less than a quarter of the each of the broader nursing and Aboriginal and Torres Strait Islander Health Worker and Health Practitioner workforces.

The level of AHP staffing across the ACCHO sector as a whole (notwithstanding the exceptional services delivering extensive, high quality allied health services to NDIS participants and other members of their communities already) must increase markedly to ensure the appropriate mix of skills and capacity is available to meet community need. This will require a major shifts funding approaches as well as coordinated investments to increase the Aboriginal and Torres Strait Islander workforce and pathways.

Aboriginal and Torres Strait Islander people make up over 3 per cent of the Australian population, but only 1 per cent of the health professional workforce regulated through the Australian Health Practitioner Regulation Agency (Ahpra).

For Ahpra regulated AHPs, the proportion who identify as Aboriginal and/or Torrs Strait Islander is around 0.5 per cent of the workforce;

This means a 6-7 fold increase is needed immediately to even reach broad population parity, and a considerably higher increase if the proportion is to reflect levels of community need and/or support a system-wide shift toward more culturally safe and responsive care.

Ahpra data, provided at Appendix E, also shows the increase in Ahpra registrants who identify as Aboriginal and/or Torres Strait Islander over the period 2014-2019: a period during numerous national plans and strategies were in place or developed that aimed to increase this workforce. Despite those efforts, analysis of this data and extrapolated, suggests that on recent trends it will take several decades and in some cases centuries to achieve workforce population parity.

The Commonwealth, States and Territories and Aboriginal and Torres Strait Islander health

workforce leaders are currently finalising the development of a detailed, long-term health workforce, which is expected to be complete in the near future. There should be considerable

34 https://www.aihw.gov.au/reports/indigenous-australians/atsi-health-organisation-osr-key-results-2017 18/contents/staffing

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opportunity for the NDIS Workforce Plan and that strategy to be leveraged to maximise workforce opportunities and service capacity for Aboriginal and Torres Strait Islander people.

The NDIS Workforce Plan has great potential to improve this situation and simultaneously progress its other objectives. Working with IAHA to expand their Academy model and with SARRAH and IAHA to expand the AHRGP pathway and associated AHA positions into NDIS service settings would be a practical way of demonstrating the intent of and commitment to the Plan.

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APPENDIX A: Recommendations from SARRAHs NDIS Workforce Submission (June 2020)

SARRAH made a number of Recommendations in our original submission to the Joint Standing Committee’s Inquiry into the NDIS Workforce. As noted at the time, SARRAH believe the actions identified in the recommendations 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.”

The following table

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

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NDIA support a substantial stakeholder engagement strategy to enable ongoing input and participation. 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.

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APPENDIX B: Report of the Inquiry into Australia’s Skilled Migration Program (August 2021):

The Parliament’s Joint Standing Committee on Migration Final Report of the Inquiry into Australia’s

Skilled Migration Program was released on 9 August 2021.

It became apparent to the Committee throughout this inquiry that there needs to be greater coordination of effort across governments and across jurisdictions to identify labour shortages and put in place the appropriate policy response. (Foreword: Page xviii)

The following excerpts point to systemic problems with the existing mechanisms in identifying workforce shortages not only for Australia’s skilled migration program but with implications across education, skills development and workforce development settings and sectors.

Several national organisations, pointed to problems with the existing datasets and approaches:

….“skills assessment approach has significant shortcomings, …such an assessment cannot identify ‘the shortages experienced by an individual business, in a particular location, at a particular point in time” (citing the Australian Chamber of Commerce and Industry, page 7)

the various data sets “only produce a limited insight into one aspect of the workforce’, and ‘are not collected consistently over time, reducing the ability to understand trends in the workforce” (citing the National Agricultural Workforce Strategy, Page 6)

Making decisions “at the national level that particular occupations, are in ‘approximate balance’ masks shortages in regional areas due to oversupply in capital cities. This leads to occupations being in shortage in regional areas, which causes regional communities to go slowly in a ‘death spiral’ due to the lack of skilled workers to support local hospitals, infrastructure, the local economy et al.” (citing Australian International Skilled Recruitment Services (AISRS), Page 6)

“If an occupation is not listed on ANZSCO, the Federal Government will be unable to report on the occupation being in demand as technically it does not exist,….” (citing Mr Mark

Glazbrook, Page 8)

ANZSCO has become outdated – “no new or emerging occupations have been added’ for almost 18 years, which reduces its effectiveness as the basis for the current skilled migration program.” (citing the Migration Institute of Australia, Page 18)

Please refer to the Report for a fuller discussion of these technical problems and the implications across employment sectors.

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APPENDIX C: The Priority Migration Skilled Occupation List

The 44 occupations (ANZSCO code) are:

 Chief Executive or Managing Director (111111)  Construction Project Manager (133111)  Accountant (General) (221111)  Management Accountant (221112)  Taxation Accountant (221113)  External Auditor (221213)  Internal Auditor (221214)  Surveyor (232212)  Cartographer (232213)  Other Spatial Scientist (232214)  Civil Engineer (233211)  Geotechnical Engineer (233212)  Structural Engineer (233214)  Transport Engineer (233215)  Electrical Engineer (233311)  Mechanical Engineer (233512)  Mining Engineer (excluding Petroleum) (233611)  Petroleum Engineer (233612)  Medical Laboratory Scientist (234611)  Veterinarian (234711)  Hospital Pharmacist (251511)*  Industrial Pharmacist (251512)*  Retail Pharmacist (251513)*  Orthotist or Prosthetist (251912)  General Practitioner (253111)  Resident Medical Officer (253112)  Psychiatrist (253411)  Medical Practitioners nec (253999)  Midwife (254111)  Registered Nurse (Aged Care) (254412)  Registered Nurse (Critical Care and Emergency) (254415)  Registered Nurse (Medical) (254418)  Registered Nurse (Mental Health) (254422)  Registered Nurse (Perioperative) (254423)  Registered Nurses nec (254499)  Multimedia Specialist (261211)  Analyst Programmer (261311)  Developer Programmer (261312)  Software Engineer (261313)  Software and Applications Programmers nec (261399)  ICT Security Specialist (262112)  Social Worker (272511)  Maintenance Planner (312911)  Chef (351311)

• Indicates occupation added in July 2021 Source: Priority Migration Skilled Occupation List (homeaffairs.gov.au) - accessed 15 August 2021

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APPENDIX D: Aged Care Royal Commission – better allied health workforce & service access

Reference source: *Aged Care Royal Commission Final Report: Recommendations

The following are excerpts from the 146 detailed ACRC Recommendations. This is a selection only: many other recommendations relate to allied health services directed. SARRAH supports the majority of the Recommendations. In some cases SARRAH supports the principle and intent of the Recommendation but has reservations about the means of delivery proposed.

The Recommendations are about improving allied health workforce and service capacity and indicate areas where workforce development activity could align with, leverage and improve outcomes for both NDIS participants and recipients of aged care services.

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SARRAH

Services for Australian Rural and Remote Allied Health

Recommendation 25: A new aged care program

By 1 July 2024, the System Governor should implement a new aged care program that the Cc alth Home Support Pri

Pack Pre and ial Aged Care Program, including Respite Care

and Short-Term Restorative Care. The new program should retain the benefits of each of the while deli care for older people with the following core features:

a. je -common| set of eligibllty coteria Identifying need (whether ofa social,

| or phy top or delay

in a person’s to fi tion ind dently, or to i the effects of such di and to enh the person’s ability to live

as well as ible, for as long as possible

Recommendation 50: Prioritising Aboriginal and Torres Strait Islander

organisations as aged care providers

1. The Australian Government should assist Aboriginal and Torres Strait Islander organisations to expand into aged care service delivery, whether on ane

ow of i eoruverar ip with Gos including with At Cc led Organi: and existing Aboriginal and Torres pit Islander providers.

2. TheA and the should tel and support additional Aboriginal and Torres Strait Islander aged care providers by flexible ap; and I of them to

a. existing Aboriginal and Torres Strait p are not di and should continue to provide high quality and safe aged care while being assisted to meet the new provider requirements

Chapter 8: Aged Care in Regional, Rural

and Remote Areas

Home Care

Recommendation 54: Ensuring the provision of aged care in regional, rural and remote areas The System Governor should ensure that older people in regional, rural and

remote locations are able to access aged care in their community equitably with other Australians by:

a. identifying areas where service supply is inadequate, and b. ively responding by for, and services to meet entitlements and needs.

Recommendation 76: Aged Care Workf Industry C: il Limited

1. By 1 July 2021, the Aged Care Workforce Industry Council Limited should: a. invite the A lian G tob a ib b. review membership of the Council to ensure it is comprised of individuals, ling worker rep who the breadth and diversity of the aged care with an appropriate mix of skills

and experience to lead and drive change across the sector.

2. By 30 June 2022, the Aged Care Workforce Industry Council Limited should:

a. review the qualifications and skills framework to address current and future competency and skill requirements and to create longer-term career paths for aged care workers, in conjunction with the work to be undertaken to seek review of award rates in aged care

b. Neakite ie cee Ga ee they reflect the skills, capabilities, as well plese tal pein renga aceon

c. revise the competency and accreditation requirements for all job grades in the aged care sector to ensure education and training builds the required skills and knowledge

Commissioner

Briggs

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F dation 34: Assistive technology and home modifications category From 1 July 2022, the A should an

technology and home modifications category within the aged care program that:

a. provides goods, aids, equipment and services that promote a level of independence in daily living tasks and reduces risks to living safely at home

Recommendation 51: Employment and training for Aboriginal and Torres Strait Islander aged care

4:

By1D ber 2022, the A (es es

a. developa t i ional Aborigi land Torres Strait Islander Aged Care Workfi Plan in i with the N | Adi y

Group for Aboriginal and Torres Strait Islander Aged Care,

i. the refi of existing Ab and Torres Strait Islander ining and empl progr

ii. targets for the training and | of Ab and Torres

Strait Islander people across the full range of aged care roles

b. pi the funds y to i the Plan and meet the training and employment targets

Recommendation 69: Clarification of roles and responsibilities for delivery of health care to people receiving aged care

1. By31D ber 2021, the A and State and Territory Governments should amend the National Health Reform Ag! to include an explicit of the roles and ilities of aged care i and

State and Territory health care providers to deliver health care to people receiving aged care, similar to the Applied Principles and ‘tables of supports’ for the i Disability on the basis that, among other things:

a. allied health care should generally be provided by aged care providers b. jialist services, includi: ialist palliative care and subacute rehabilitation, should be provided by State and Territory health care providers, even if these services involve allied health practitioners

c. less complex health conditions should be managed by aged care providers’ staff, particularly nurses.

The Aged Care Workforce Council Limited should work collaboratively

with the Aged Care Workforce Planning Division so that its work complements aged care workforce design and planning.

From 1 July 2022, the Aged Care Workforce Industry Council Limited should

map career pathways for the aged care sector. These career pathways should:

a. highlight opportunities for nurses to advance in clinical and managerial roles in the aged care sector

b. facilitate | care work having opp ities to move laterally

across aged care, disability care, community care and primary health care and vertically in aged care by ad\ ing into specialist care roles and supervisory or managerial roles

SARRAH

Services for Australian Rural and Remote Allied Health

Recommendation 79: Review of certificate-based courses for aged care

1. By January 2022, the Aged Care Services Industry Reference Committee, ing with the i Human Services Skills Organisation as required, should:

a. review the need for specialist aged care Certificate Ill and IV courses, and b. regularly review the content of the Certificate III and IV courses and consider if any additional units of competency should be included.

2. As part of any such review, the Aged Services Industry ‘Commienioner requi Veclinvad, ad GOPLIIAE W aity 6 ts toaSionigy ORISA units of competency should be included as core competencies:

a. personal care modules, including trauma-informed care, cultural safety, mental health, physical health status, wound care, oral health, palliative care, falls prevention, first aid, monitoring medication and dysphagia management

b. quality of life and wellbeing, including the use of technology, interventions for older people at risk, and recognising and responding to crisis situations.

Recommendation 83: Funding for hing aged care prog!

By 1 July 2023, the Australian Government should fund teaching aged care programs for delivery to students in both residential aged care and home care settings. The ing aged care p should have desi

Ri dation 114: | diate funding for education and training

to improve the quality of care

1. The G should lish a sch ing on 1 July 2021, to improve the quality of the current aged care workforce. The should until ind pricing of aged care services by

the Pricing Authori The sct should reimt of home support, home care and residential aged care for the cost of education and training of the direct care workforce employed (either on a part-time or full-time basis, or on a casual basis for employees who have been employed for at least three months) at the time of its commencement or during the

period of its ion. Eligible ed ion and training should i

a. Certificate Ill in Individual Support (resi ‘ial care and home care streams) and Certificate lV in Ageing Support

b. inuit di ‘ion and i (includi of training courses, such as ‘skill sets’ and ‘micro-credentials’) relevant to direct care skills, including, but not limited to, dementia care, palliative care, oral health, mental health, pressure injuries and wound management.

2. Reimbursement should also include the costs of additional staffing hours q to enable an i ployee to attend the training or education. The scheme should be limited to one qualification or course per worker.

Recommendation 81: Ongoing professional development of the aged care workforce

From 1 July 2021, the Australian Government and the States and Territories, through the Skills National Cabinet Reform Committee, should fast-track the

areas and should:

a. collaborate with educational institutions and research entities b. facilitate clinical for and and training sector students

Recommendation 121: Incentives for an enablement approach to residential care

From 1 July 2022, the ing i ives should be i d into the rules, inciples and guidelines for and funding eligibility:

a. an approved provider should be paid retrospectively from the date when a was i where it is di i on

that a person is entitled to a higher level of funding, and the provider can demonstrate that it has been providing the higher level of care

b. aresident should not be ired to be d for funding eligibility if their condition improves under the care of a provider.

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by the ian Industry and Skills Committee of accredited, II ised short skills sets and micro-credentials for the aged care workforce. The courses should be designed to:

a. imp PPI ities for | jing and professional devel and

b. Je the skills, and capabilities of the existing workforce.

APPENDIX E: Aboriginal and Torres Strait Islander health professional workforce

Professions registered under the National Registration and Accreditation Scheme (NRAS) for health professions.

Note:

1. Many of the allied health professions who provide services under the NDIS are not included in the NRAS and consequently there is generally a lack of detailed information about these professions to inform workforce and service planning nationally. The professions include, among others, speech pathologists, exercise physiologists, dieticians, nutritionists, audiologists, social workers and more.

2. While the Ahpra Annual Report 2019-20 generally includes data on health professional registrants as at 30 June 2020, it provides data on people who identify as Aboriginal or Torres Strait Islander as at June 2019.

Table Source: Ahpra Annual Report 2019-20: https://www.ahpra.gov.au/Publications/Annual-

reports/Annual-Report-2020.aspx, page 58.

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