Submission 52 — Tasmanian Government — NDIS Workforce | External submission

Tasmanian Government

Submission

JOINT STANDING COMMITTEE ON THE NATIONAL

DISABILITY INSURANCE SCHEME

INQUIRY INTO THE NDIS WORKFORCE

20/39635

Introduction ………………………………………………………………………………………….. 2
Areas of Relevance …………………………………………………………………………… …2 2.1 The current size and composition of the NDIS workforce and projections at full scheme………………………………………………………………………………3

2.2 Challenges in attracting and retaining the NDIS workforce, particularly in regional and remote communities…………………………………………………………..4

2.3 The role of Commonwealth Government policy in influencing the remuneration, conditions, working environment (including Workplace Health and Safety), career mobility and training needs of the NDIS workforce………………………………6

2.4 The interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care……………………………………………………..7

2.5 The interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care……………………………………………………..8

2.6 The opportunities available to, and challenges experienced by, people with disability currently employed, or wanting to be employed, within the NDIS workforce………………………………………………………………………….9

2.7 Any other matters…………………………………………………………………9

Conclusion ………………………………………………………………………………………….. .10

1 INTRODUCTION

The Tasmanian Government welcomes the opportunity to provide a submission to the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Inquiry into the NDIS Workforce.

The NDIS is one of the most complex and important reforms that Australia has seen in recent years and it has already transformed the lives of many Tasmanians living with disability. Tasmania moved to full scheme NDIS on 1 July 2019 and is now operating under a Bilateral Agreement between the Commonwealth of Australia and the State of Tasmania. This Agreement reflects the shared NDIS responsibilities of both Governments and locks in arrangements for on-going funding contributions to the Scheme. The Tasmanian Government will contribute over $233 million to the NDIS during 2019-20.

Transitioning to the NDIS remains a key focus for the Tasmanian Government. From 2013 to 2016, Tasmania was an NDIS trial site for young people in the 15-24 year age group and during that time over 1,000 young Tasmanians transitioned into the Scheme. In July 2016, Tasmania commenced its three year transition to full scheme. It was estimated that 10,587 Tasmanians would be supported through the NDIS by 30 June 2019, the end of the transition period. Tasmania, like many other jurisdictions, has not yet reached its target number of participants, but numbers continue to increase.

With the introduction of the NDIS, the disability services market in Tasmania has expanded well beyond its traditional boundaries with supports and services now being purchased from a much broader market. Genuine choice and control over the supports necessary to attain personal goals and aspirations can only be achieved when Tasmanian participants have access to an effective NDIS market and workforce able to respond to their needs. In its Review of the National Disability Agreement1, the Productivity Commission states ‘a ready and capable workforce, both within and outside the NDIS, is essential to providing high quality supports and services and improving the wellbeing of people with disability’. The Tasmanian Government supports this view, and agrees a workforce that is diverse, agile, and one that can deliver high quality, person-centered NDIS supports is critical to the successful implementation and performance of the NDIS in Tasmania.

There is much work still to be done in this area. The Tasmanian Government is participating in work through the Council of Australian Governments Disability Reform Council (DRC) to develop a National NDIS Workforce Plan that includes initiatives to strengthen and stimulate the national and local workforce. The Tasmanian Government looks forward to the timely progression of this Plan.

This submission does not seek to address each aspect of the Inquiry’s Terms of Reference. Rather, areas of relevance to Tasmanian Government services are highlighted as they relate to the workforce providing NDIS services in Tasmania.

1 Review of the National Disability Agreement, Productivity Commission Study Report, Jan 2019

2 AREAS OF RELEVANCE

2.1 The current size and composition of the NDIS workforce and projections at full scheme.

In 2019. Minister for the National Disability Insurance Scheme, the Hon Stuart Robert MP, announced that the National Disability Insurance Scheme (NDIS) is expected to create up to an additional 90,000 full time equivalent (FTE) workers across Australia by 2023. In its 2016 Market Position Statement (Tasmania)2 the National Disability Insurance Agency (NDIA) forecast that:  the Tasmanian market for disability supports would grow from 4,300 people accessing supports in 2014 to 10, 587 by 1 July 2019, an increase of 6,300 people  the level of annual expenditure would grow from $220 million to $480 million; and  an additional 1,450 to 1,750 FTE jobs would be required across Tasmania to meet demand at full scheme

The extent to which these predictions are accurate is unclear, as understanding the size of the current workforce is complex due to increased casualisation, limited access to relevant workforce data and an NDIS market that is not yet fully mature.

In its most recently published quarterly report3 (the quarterly report), the NDIA advises that as at 31 March 2020, 8,554 Tasmanians were being actively supported through the NDIS. Further, the number of NDIS plans approved (versus the bilateral estimate of 10, 587) had increased to 82 per cent, compared to a national average of 89 per cent.

Although, the number of Tasmanians supported by the Scheme is lower than expected, the Tasmanian NDIS market has experienced significant growth over the last three years. In December 2016 there were 5114 registered providers in Tasmania. By 31 March 2020, a total of 996 registered providers were active across the State, an 11 per cent increase from the previous quarter. A total of 75 per cent (746) of these were companies or organisations and 25 per cent (250) were individuals or sole traders. When looking at types of supports, the largest proportion of active providers (40 per cent of sole traders and 60 per cent of organisations) are registered to provide therapeutic supports in Tasmania.

While this has created opportunities for existing providers and new entrants to the Tasmanian market, gaps remain in workforce provision which affect participants’ capacity to achieve their goals. Evidence suggests the size of the workforce is still insufficient to meet demand with the quarterly report showing the average number of active providers per active participant had decreased from 1.68 in prior quarters to 1.63, with the average plan use rate of 70 per cent as at 31 March 2020. Although there are a multitude of reasons why this is the case, market supply issues linked to a workforce shortage, is almost definitely a factor, particularly in areas of thin markets.

As the NDIS matures, more participants are choosing to self-manage or engage a plan manager for part or all of their plan. This means there is a much broader market for participants to purchase services from as they can choose to purchase supports from non-registered or

2 www.ndis.gov.au/providers/working-provider/market-information/market-position-statements 3 www.ndis.gov.au/about-us/publications/quarterly-reports - COAG DRC Quarterly Report Q3 – Tasmanian Dashboard as at 31 Mar 2020 4 www.ndis.gov.au/about-us/publications/quarterly-reports/archived-quarterly-reports-2016-17 - Tasmania Dashboard as at 31 Dec 2016

mainstream providers. The quarterly report shows that 26 per cent of plans are either fully or partially self-managed as at 31 March 2020, 23 per cent are plan-managed and 51 per cent are managed by the NDIA.

The need for service providers to be responsive in a competitive market means increased demand for flexible working arrangements. This has led to a highly casualised NDIS workforce. National Disability Services (NDS) Workforce Census, December 2019 Snapshot5 shows 43 per cent of disability support workers are employed on a casual basis, 79 per cent work part-time and the workforce turnover for casual workers is 29 per cent. Although these are national results, the composition of the Tasmanian workforce is consistent with these findings.

The Tasmanian Government recognises the need for workforce growth in the areas of disability support; behaviour support; allied health; health; supports to enable participants to meet their personal goals (e.g. personal trainers) and those engaged in employment related activities. A lack of clearly defined baselines across different NDIS workforces has made it difficult to ascertain how much progress has been made, where further growth is required and how much, and to what extent specific workforce groups/professions require market intervention and stimulation.

2.2 Challenges in attracting and retaining the NDIS workforce, particularly in regional and remote communities.

Tasmania, like many regional and remote regions, has experienced challenges in attracting and retaining NDIS providers. These recruitment and retention issues tend to be more pronounced outside the major cities. For many Tasmanians access to affordable, appropriate supports of their choice, depends largely on where they live and the types of services they need to access.

In general, the challenges and issues in regional and remote communities are well understood as many existed prior to the introduction of the NDIS. Issues such as shortage of disability support and allied health workers, lack of training and support and difficulties recruiting people from within and outside of the area are still present at full scheme NDIS in Tasmania.

Prior to implementation of the NDIS, Tasmanian Specialist disability services were outsourced to the community sector, resulting in a relatively mature provider market at the time the NDIS was introduced. This left providers well-placed to respond to changes in the way supports are funded under the NDIS (i.e. a shift away from ‘known’ block funding to a ‘fee-for-service’ funding model). The vast majority of providers were able to successfully transition their business models to support delivery of quality services and remain viable in a competitive market. However, for some, the move to demand-driven supports has created a less-certain service and funding environment. For example, where a participant’s needs change, a provider may need to cancel or extend shifts at short notice and cannot ‘guarantee’ hours or patterns of work for support workers. This can affect their capacity to attract and retain staff.

The block-funding model gave jurisdictions flexibility to provide critical supports for people in rural and regional areas through purchasing ‘service capacity’ or bulk purchasing arrangements, either outsourced or directly delivered (for example, services funded to provide additional hours or accommodation services). Under the NDIS, funding is available to a participant to

5 www.nds.org.au/news/latest-workforce-census-data-now-available

purchase approved supports, not to individual providers to purchase capacity. This has led to confusion over what and how services should be provided, and who is responsible to provide them in cases where participants experience unforeseen circumstances or emergencies.

Nationally, work is progressing in this area and the Tasmanian Government notes and welcomes the significant improvements in processes to respond to participants’ needs in times of crisis. A Tasmanian provider has recently been contracted to deliver the NDIA’s Exceptionally Complex Needs program and will focus on operationalising the service to ensure the immediate needs of Tasmanian NDIS participants in crisis are met.

In regard to the broader workforce challenges faced by the disability sector, the Tasmanian Government, based on feedback from Tasmanian providers, notes the following:  additional administrative complexity and burden as an outcome of individualised funding and individualised claiming;  acknowledgment that although the NDIA provider portal has improved, there is still a significant number of provider payment issues which impact on business cash flow;  the need for more complex, more expensive and often bespoke rostering systems with the required agility to respond to changes in demand from participants;  claims that some providers are selecting participants on the basis of price and complexity and choosing not to take on people with complex support needs and/or complex behaviours because the ‘price’ is not a sufficient incentive or because of the challenge of securing staffing teams to provide more complex supports;  providers are still adjusting to the NDIS Quality and Safeguards Commission regulatory framework with reports that some are choosing to exit the market or deregister as a result of the additional administrative and regulatory requirements. Of particular concern is the cost of undertaking independent audits and the reporting requirements relating to restrictive practices which require interaction with both the Commission and the State Government; and  a shortage of skilled staff from chief executive officers (and board members) to supervisors, team leaders and disability support workers noting all positions are critical in order to provide good governance, maintain positive workplace culture, ensure business viability and deliver quality service provision for participants.

Access to allied health services is a particular challenge in Tasmania. Allied health professionals are in short supply across the State and providers report long waitlists resulting in delays for participants. The Tasmanian Government is working collaboratively with the Australian Government’s Boosting the Local Care Workforce program as they undertake to investigate allied health workforce issues in Tasmania. Challenges identified through this work include:  the lack of jobs in regional and remote communities due to a relatively small number of participants, resulting in thin markets or competition for work rather than collaboration and support;  allied health workforce shortages resulting in small pools to recruit from and difficulty retaining staff;  workforce capability issues, due to the requirement for a more nuanced or specific skill set compared to that required working in the broader health sector;  few networking, training and professional development opportunities to attract, retain and support staff;

 limited access to appropriate allied health courses and qualifications; and  more opportunities for allied health professionals to be supported by allied health assistants.

An investigation is also underway into career pathways within the Tasmanian disability sector, looking at opportunities for disability support workers, allied health assistants and allied health practitioners. The project also seeks to engage school students to consider a career in the disability sector. Events organised and delivered statewide, in collaboration with the Tasmania’s Department of Education, include high school and University of Tasmania career days to promote allied health education and career pathways within the sector. Feedback from students indicates that concerns for mental health are a major barrier when considering a career in the disability sector.

In its Workforce Census, December 2019 Snapshot, the NDS advises that the results show ‘some positive signs of a sector starting to consolidate after the comparative volatility of the NDIS roll out’. However, the Tasmanian Government recognises there are challenges in delivering demand-led, individualised disability supports with a highly-casualised workforce. For example: disability support workers are often required to work fragmented hours to respond to participant need; greater job and financial insecurity; limited career pathways and ‘unpaid’ professional development and training. From a provider perspective, recruiting and retaining staff to enable effective rostering can be administratively complex and costly.

The Tasmanian Government’s Department of Health advises that remuneration rates for allied health professionals and nurses working in the NDIS are relatively generous at face value. However, allied health professionals and nurses report that the time required to navigate NDIS administrative systems and processes and the documentation required is onerous, often requiring hours of additional report writing. As a consequence, it is generally felt that the remuneration rates do not reflect the level of administration required to support the provision of therapy and assistive technology for NDIS participants.

Further, the NDIS individualised funding model does not cover generic organisational training for trainee supervision or training of the NDIS workforce, as funding is directly linked to participant goals and their individual needs. For example, health professional training often incorporates clinical education placements, which to be successful, need to be coordinated, supervised and resourced.

The Tasmanian Government acknowledges the importance of teaching, training and research within the health sector and contributes to funding these functions through the National Health funding model. Exploration of an NDIS funding model that better supports teaching and training within the NDIS would be welcome.

2.4 The role of State, Territory, Commonwealth Governments in providing and implementing a coordinated strategic Workforce Development Plan for the NDIS workforce.

States and territories are partners in delivering the NDIS. The Tasmanian Government welcomes the decision made by the DRC at its December 2019 meeting to: use a more flexible approach to address market challenges in the NDIS, recognising that a ‘one-size-fits-all’ approach to delivering the NDIS is not suitable to address market gaps faced by certain geographic locations, particular cohorts or disability support types. Projects to address thin markets in all jurisdictions, including Tasmania, have been initiated to address specific needs such as specific disability support types and professional groups like allied health.

As an active partner in the NDIS market, the Tasmanian Government has a significant interest in the market’s success and has invested effort and funds into supporting the training and workforce development of the Tasmanian community services sector including support to peak bodies as follows:  Tasmanian Council of Social Services (TasCOSS): $1 million over four years, supporting the Community Services Industry to remain strong and sustainable and includes the development of a comprehensive Community Services Industry Plan: and  National Disability Services Tas: o $200,000 per year for three years to support the disability sector to operate in a NDIS market, including projects that support workforce attraction and retention; and o funding of $200,000 over two years to support Workforce Development in Disability Sector - Career and training pathway development and delivery which will define career pathways relevant to the Tasmanian sector and promote these careers to: potential new workforce entrants, including schools and mature age students; the existing workforce who may be looking at further training and up-skilling opportunities and the existing and future Allied Health Workforce.

The health care and social assistance sector receives the highest proportion of Tasmanian government training funding (over 18 per cent in 2018). Of this, almost 40 per cent was allocated to TasTAFE and private training providers to provide training in disability-related qualifications and skill sets. Further, in 2018, the Tasmanian Government subsidised 1,763 enrolments for qualifications related to the disability sector and under the Skills Fund (demand led training) directed 44 per cent of funding to support training in the disability sector. Since 2017, over $430,000 has been provided under the Training and Work Pathways Program for training and other support to disadvantaged cohorts facing barriers to employment and education.

The Tasmanian Government is working collaboratively with the NDIA to support NDIS participants in Tasmanian Government schools. The Department of Education is a registered NDIS service provider, delivering personal care in schools (PCIS) and Early Childhood Early Intervention (ECEI) services. The Tasmanian Government is aware of situations where external providers, often allied health, request access to students during school hours. This can result in students being away from school for significant periods throughout the school day which may adversely affect students’ individual learning capacity. The presence of other external providers,

for example those delivering PCIS, can also affect delivery of teaching and learning programs in some Tasmanian Government schools.

In January 2020, the Tasmanian Government endorsed an NDIS Market Roles and Responsibilities paper which sets out the roles and responsibilities of the Australian Government, the NDIA, the NDIS Commission and jurisdictions in relation to market oversight and stewardship. At a local level, Tasmania has worked with the Boosting the Local Care Workforce Regional Coordinator and the Australian Government Department of Jobs and Small Business to consult with the sector on local workforce strategies and best practice examples or workforce attraction. Tasmania also participates in a local level market readiness working group with the NDIA to ensure oversight of any local market challenges or opportunities.

The Tasmanian Government has been actively engaging with NDIS providers, through local engagement and provider consultations across the State to capture and understand the regional issues and developing concerns of the Tasmanian community and disability sector in the new NDIS market. The information gathered highlights that Tasmania is engaged in a new environment with developing regional complexities including geographic distances and gaps in services.

The Tasmanian Government is participating at a national level, in collaboration with other states and territories, to deliver a consistent national approach to addressing workforce demand issues through the National NDIS Workforce Plan.

2.5 The interaction of NDIS workforce needs with employment in adjacent sectors including health and aged care.

The Tasmanian Government recognises that the NDIS workforce cannot be viewed in isolation. Interaction between adjacent sectors including health and aged care, particularly in regional areas, is critical in understanding and addressing NDIS workforce issues and challenges.

For example, the shortage of allied health professionals across the disability health, aged care and community sectors requires a broader approach that facilitates a net increase in the number of allied health professionals. This would avoid a simple redistribution of professionals across sectors, influenced by single market interventions.

The limited availability of allied health courses in Tasmania through the University of Tasmania exacerbates this issue. The Tasmanian Government is working closely with the University on its allied health expansion project, and it is anticipated that additional programs of study will commence from 2022. This will have a positive impact on the supply of allied health professions in Tasmania, but there would still be a four-five year lead time until the supply is increased.

The NDIS has resulted in some senior, experienced staff leaving the Tasmanian Health Service to pursue employment opportunities in the NDIS either with NDIS provider organisations or establishing themselves as sole trader NDIS providers. These allied health professionals are difficult to replace, and the Department of Health and Tasmanian Health Service are considering strategies to improve recruitment and retention in the Tasmanian health sector.

2.6 The opportunities available to, and challenges experienced by, people with disability currently employed, or wanting to be employed, within the NDIS workforce.

Many of the challenges experienced by people with disability currently employed or seeking employment in the disability services sector, and more generally, existed prior to the introduction of the NDIS. These include: discriminatory attitudes and behaviours during recruitment, and in the workplace; low levels of awareness of rights; lack of availability of jobs and assistance in finding, securing and maintaining employment; difficulty in accessing skills training and education; potential reduction or loss of the Disability Support Pension; difficulty accessing flexible work arrangements; health issues; difficulty in negotiating reasonable adjustments/accommodation in the workplace and the lack of availability of accessible transport and technology in the workplace.

The NDIA’s Information, Linkages and Capacity Building (ILC) commissioning framework allocates grants to eligible organisations to deliver projects in the community that benefit all Australians with disability, their carers and families. The Tasmanian Government welcomes further investment through the ILC commissioning to remove employment barriers.

2.7 Any other matters.

In March 2020, the Federal Minister for the National Disability Insurance Scheme announced measures to ensure essential support is in place for NDIS participants and providers through the COVID-19 outbreak. These measures are being put in place by the Australian Government Department of Social Services, the NDIA and the NDIS Quality and Safeguards Commission, working with the Australian Government Department of Health and state and territory governments.

The Tasmanian Government acknowledges this ongoing and rapidly changing situation in which all levels of government must work together in partnership to ensure that people with disability, their families, friends, carers, and people who work with them, continue to be safe in their home, their workplace and in their community. The impact of the pandemic on the Tasmanian NDIS workforce is still emerging but it is clear there will be opportunities for innovative practice that will shape future service delivery for people with disability in Tasmania.

Emerging themes from the response to the COVID-19 pandemic include:  There has been no major workforce impact to date from COVID-19. However, it is possible that the sector could face a significant shortfall of workers should infection rates change.  Ongoing workforce monitoring is necessary in Tasmania to ensure appropriate and rapid action can be taken to address workforce shortages, if and when required.  The need for an agile workforce that can scale up quickly to respond to particular areas of need i.e. surge capacity (for example, in Tasmania we have seen larger providers redeploying workers from community access services to residential settings as the need for community access reduced - other providers have developed Memoranda of Understanding to redeploy workers between services during the crisis period).

 Innovation in the way supports are delivered to respond to changing demand, for example technology to support outcomes for participants, including use of social media platforms to facilitate group or one-on-one interactions where preferred by the participant  The importance of inclusive, accurate, timely and accessible communication resources for providers, the broader disability sector and people with disability their families, friends and carers, particularly in the event of a disaster or national emergency  The need for robust contingency planning to ensure continuity of supports for people with disability.

The Tasmanian Government has implemented a number of response measures to support the NDIS market and workforce during this time including: expansion of an existing Rapid Response Skills Initiative through Skills Tasmania to help redeploy people who lost their job as result of the impacts of COVID-19; establishment of a Rapid Response Skills Matching Service to help match and prepare job ready workers with industries and businesses (which includes support for the disability sector) and adjustments to the Tasmanian worker screening process to ensure it continues to operate during the crisis period.

As part of the broader Tasmanian market and workforce, the Tasmanian Government has developed a plan to ‘Rebuild a Stronger Tasmania’. This plan supports businesses and workplaces in Tasmania to continue to operate, or reopen, while protecting Tasmania’s health and safety during the COVID-19 pandemic. All workplaces will be required to have a COVID-19 Safety Plan that complies with minimum COVID-19 safety standards.

3 CONCLUSION

The Tasmanian NDIS market and workforce has, as predicted, experienced significant growth over the last three years creating opportunities for existing providers and new entrants to the Tasmanian market. Despite this period of unprecedented growth, gaps remain in workforce provision which affect Tasmanian participants’ capacity to achieve their goals. For many Tasmanians, access to affordable, appropriate supports of their choice, depends largely on where they live and the types of services they need to access.

The key NDIS workforce issues for Tasmania are:  Tasmania, like many regional and remote regions, has experienced challenges in attracting and retaining NDIS providers. These recruitment and retention issues tend to be more pronounced outside the major cities, resulting in thin markets across many parts of the state.  A shortage of skilled staff from chief executive officers (and board members), to supervisors, team leaders and disability support workers, noting all positions are critical in order to provide good governance, maintain positive workplace culture, ensure business viability and deliver quality service provision for participants.  In particular, there is a shortage of allied health professionals across the state, with providers reporting long waitlists and lengthy delays for participants.  The casualised, part-time nature of the NDIS workforce presents benefits and challenges for providers operating in Tasmania. Increased flexibility allows providers to better respond to the individual needs of participants and has potential to enhance viability in a competitive market. To achieve this agility, workers are often required to work fragmented hours, have

increased job and financial insecurity and limited career pathways and opportunities for professional development. The extent to which these issues are experienced by workers affects providers’ capacity to attract and retain workers.  In a competitive market meeting individual needs, there is a risk that participants may be selected on the basis of NDIS price and complexity rather than need for supports  Providers are still adjusting to the NDIS Quality and Safeguards Commission regulatory framework with reports that some are choosing to exit the market or deregister as a result of additional administrative and regulatory requirements.

In participating in work through the DRC the Tasmanian Government looks forward to the development and implementation of the National NDIS Workforce Plan. This Plan will build on lessons from the COVID-19 pandemic to strengthen and stimulate the national and local Tasmanian workforce.

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