Submission to the Joint Standing Committee on the
NDIS – ECEI Approach
August 2017
Background
Scope Australia was established as the Spastic Children’s Society of Victoria in 1948, and our organisation has been delivering services and supports to individuals and their families for well over 60 years. As a not for-profit organisation, we support children and adults with developmental delays and disabilities to achieve their goals in life. We aim to provide support when and where needed, whether in the family home, at child care, kindergarten or school, in the community or at one of our service locations. Our mission is to enable each person we support to live as an empowered and equal citizen.
As one of the largest providers of early childhood intervention services across metropolitan, regional and rural areas of Victoria, Scope currently assists over 1,000 children and their families. We are funded by the
Victorian Department of Education to deliver Early Childhood Intervention Services (ECIS), Early
Childhood Intervention – Flexible Support Packages, the Kindergarten Inclusion Support Packages and the
Pre School Field Officer Program. We are a registered service provider of the Australian Commonwealth
Government - Helping Children with Autism, the Better Start Initiative and the Better Start Early Years
workshops. We are also currently delivering an NDIS ECEI service to 135 participants and their families in Victoria.
The early years are a core component of our organisation’s services, and Scope is committed to ensuring that our early childhood intervention services reflect current best practice and are evidence based. We adopt a family-centred, strengths-based approach in supporting families and children, with our service model guided by the significant evidence-base for effective early childhood intervention services, including the 2009 Department of Education ECIS Literature Review. Our service delivery principles include:
o Family centred practice
o Family partnerships
o Delivery within everyday learning environments and family routines
o Recognition of a child and family’s individual resilience and strengths
o Capacity building approach
o Recognition of diversity
o Inclusion in a universal continuum of early childhood services
o An ecological perspective (emphasis on the fit between child and family and their environments)
o Parents as experts on their child and advocates for their child
o Children’s rights to education, social inclusion and quality of life
o Families’ rights to respect and access to community activities
The NDIS ECEI Approach
We support the ECEI’s evidence-based approach to achieving the best outcomes for children, including the development of national guidelines and endorsing key principles. This is assisting the effective transition of early years clients into the NDIS and enabling the early identification of supports that lead to an effective
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planning phase for the NDIS. Additionally, this is supporting new families who are unfamiliar with navigating a service and may be experiencing anxiety as a result. The ECEI Early Years Partner is will provide independent advice to families.
Recommendation: We recommend an approach that reflects both the National Quality Framework and the Victorian Early Years Framework to enhance inclusion and participation opportunities for children and families in early childhood education and care services, and in the wider community.
Eligibility criteria for determining access to the ECEI pathway
Meeting the NDIS early intervention requirements will depend on factors such as overall functional capacity to undertake daily routines, and is not based solely on a child’s diagnosis. This is a broad domain that will ensure that no eligible child will be missed. The adoption of functional based assessments reflects current best practice, as it demonstrates the degree of delay/strengths for effective intervention that are relevant and deemed effective to the child, with appropriate expected outcomes. This incorporates a strengths based approach in comparison to a deficit based model that is diagnosis driven.
PROS:
Early Years partners are able to:
o Connect children and families of the most appropriate local supports
o Provide some short-term early intervention where appropriate
o Facilitate NDIS access and develop an NDIS plan for participants
o Offer a ‘no wrong door’ approach
o Build pathways to supports around the context and capacity of the child and the family
o Utilise functional evidenced based assessments and developmental screening tools
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CONS:
o The execution of assessment of eligibility requires further consideration. NDIA’s decision against utilising existing providers to avoid a conflict of interest may have resulted in partners with no background or expertise in early intervention.
o The use of these assessments requires a practitioner with competent exposure to early intervention, but it is our understanding that this requirement is not always being met, resulting in the poor execution of eligibility assessments
o Victoria and NSW have a different approach to the ECEI pathway, with Victoria securing Early Years Partners in each roll out area, and NSW continuing to fund current ECIS providers to support new and existing participants on the ECEI pathway until full scheme roll out in 2018, upon which tendering for Early Years Partners will commence.
Recommendation: It is our recommendation that there is a nationally consistent approach, where current providers assist with transitioning new customers in consultation with the ECEI Early Years partner. We also recommend that key safeguards are out in place, similar to those provided for Support Coordination, where there is a transparent offering of all options to potential customers.
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Service needs of NDIS participants receiving support under the ECEI pathway
Service Needs of Participants ECEI pathway as delivered by NDIA / ECEI services delivered by registered NDIS
receiving support under the Early Years Access Partners - Victoria service providers - Victoria
ECEI Pathway Do they meet the service needs of Do they meet the service needs of
participants? participants?
Services need to be easily ECEI Early Years Access Partners Limited choice of registered ECEI providers
accessible and locally based. (EYAP) either established or to be in rural areas.
established in the local area. Service delivery in the community (including Committed to delivering services based in home and at child care) is restricted by the on family preference e.g. in home. As cap on travel charges per NDIS package. EYAP are either not experienced ECEI service providers (Brotherhood of St Lawrence) or current providers in the allocated areas, they have limited current knowledge of local referral/service support points e.g. medical practitioners, MCH, Early Childhood education and care services. Best practice shows services Approach reflects best practice as identified are most effective when by the ECIA national guidelines and is delivered in natural settings. committed to deliver based on the recommended guidelines, in home or community. The natural environment provides the best opportunities for learning, helps children apply and use the skills they learn in the right setting and in unrehearsed conditions (rather than try to generalise across different settings), and places emphasis on the importance of collaborating with parents to explore and enhance the naturally occurring learning opportunities that are present in day to-day life.
Services need to be timely The ongoing capacity to respond in a There is an adequate and skilled workforce
and responsive, and research timely way is unknown, as EYAP is willing and able to provide services to
suggests early support and currently being established in Vic roll out eligible participants in a timely and
intervention results in better areas. EYAP capacity to transition defined responsive manner, in line with best practice
outcomes for children and participants will require an adequate and guidelines.
increased capacity for skilled workforce, and there is difficulty There is limited community-based generic
families to support a child’s with EYAP recruitment, particularly in services to refer non-eligible NDIS children
ongoing development. rural areas. to.
Concern regarding new NDIS eligible participants and continuity of supports when transitioning from EYAP to selected NDIS service provider as requires retelling story, building report and trust. In some cases participants have waited 12 months from being identified to commencement of planning with NDIA,
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Service Needs of Participants ECEI pathway as delivered by NDIA / ECEI services delivered by registered NDIS
receiving support under the Early Years Access Partners - Victoria service providers - Victoria
ECEI Pathway Do they meet the service needs of Do they meet the service needs of
participants? participants? with no access to state funded service during this wait time. In some roll out areas there is limited feedback for referrers regarding the outcomes of referrals.
Services need to be VIC EYAP - early childhood intervention There are NDIS registered service providers
experienced and skilled in experience varies from experienced ECIS with staff experienced and skilled in family
family centered and social providers (Merri), providers with a centered and social models of early
model of early childhood medical approach to intervention (Link), childhood intervention, tailored to individual
intervention, tailored to to providers with limited early childhood needs and be strengths based.
individual needs and be intervention experience (Brotherhood of strengths based. St Lawrence). VIC EYAP who are not currently direct providers in areas of responsibility will require time to understand the local sector and establish necessary networks.
Support for families and Will the EYAP have capacity for Potential for increased referral to State
carers to access information, counselling? funded carer and parent support services
emotional and peer-to-peer Potential to duplicate state funded which are limited particularly in rural area,
support services such as VIC Strengthening Parent and have no opportunity to increase capacity
Support Program. without additional funds. Early roll out customers are missing out on the ECEI approach and are going straight to a plan with limited information or support.
Participant choice No choice of EYAP in Vic for In most metropolitan areas there are
participants. sufficient services providers to allow participant choice, but there are thin markets in many regional areas.
Inclusion support Focus on inclusion with little mention of The social model of service delivered in the
participation or how services will be natural environment promotes inclusion. delivered in the context of the universal service system (e.g. partnerships connections)
Outcome measures that are A lack of reference to outcome A lack of reference to outcome
meaningful for families and measurements in the ECEI framework. measurements in the ECEI framework.
children Outcome measures are important to Outcome measures are important to ensure
ensure proper continuity and relevant proper continuity and relevant supports supports The Pedi – cat is a robust tool for assessment The Pedi – cat is a robust tool for of function but is inadequate as an evaluation assessment of function but is inadequate tool to measure progress and goal attainment. as an evaluation tool to measure progress and goal attainment.
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Timeframe in receiving services under the ECEI pathway
A quarantined waiting list from VIC ECIS services has meant that some families have waited 12 months since being identified to the commencement of planning with the NDIA, with no access to state-funded ECIS services during this wait time.
We anticipate long timeframes for the transition of defined participants as it is our understanding that partners are required to commence planning for defined participants and assess/process new referrals, while staff are yet to complete their training and have limited knowledge in the sector/local area.
We commend the NDIA identify the inadequacies of fast tracking first plans, as the commitment to a more robust planning process enables greater family consultation and participation.
Recommendation: Consider utilising current service providers to support a streamlined transition for defined participants.
Adequacy of funding for services under the ECEI pathway
Funding needs to be adequate to ensure access to reasonable and necessary supports that reflect the individual child and family’s local community. Our experience and modelling shows that funding is insufficient to provide service in the natural environment that is consistent with best practise guidelines.
Costs associated with ECEI services, including costs in relation to initial diagnosis and testing for potential ECEI participants
Currently, access to testing and diagnosis can be difficult, with long wait lists for public health services, for example regional Autism Spectrum Assessment Teams. Access to the health system can be costly as gaps payments through Medicare are limited, and access to specialists, medical diagnosis and testing is costly and unaffordable for many families.
Recommendation: NDIA subcontract organisations to facilitate the fast tracking of diagnosis and testing for the purposes of establishing ECEI participant’s eligibility for access to ongoing NDIS supports. (eg. DET model for assessment for eligibility for school supports)
Evidence of the effectiveness of the ECEI Approach
As per the NDIS quarterly reporting dashboard for December 2016 and March 2017, the outcome domains are robust measurements and reflect the intentions of the ECEI approach and evidence. A decrease in the outcome domains for children 0 to school age could be an indication of difficulties identified in the transition process, due to the late establishment of the early year’s partners in the roll out areas thus far.
A measure of effectiveness should NOT be the number of children diverted to state based services.
Robustness of the data required to identify and deliver services to participants under the ECEI
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We encourage the NDIA to finalise the Outcome Measurement Framework and develop a consistent reporting framework for providers regarding participant goal attainment against the identified domains to enhance effectiveness.
Adequacy of information for potential ECEI participants and other stakeholders
Information from the NDIS/ Early Years Partners changes, often without notice, resulting in confusion about how processes work and directly impacting on engagement in services. (e.g. referrals slow down, necessary supports are missing in plans and more reviews are sought) There can be minimal engagement between stakeholders and early years access partners, leading to confusion about referral processes, for example paediatricians referring directly to service providers.
There seems to be inconsistency in the communication of eligibility to stakeholders. One early years access partner states on their referral form, that eligibility to receive ECEI services is ‘a disability or a developmental delay which is the result of an impairment and causes substantial functional limitations, and requires a coordinated, long term, multidisciplinary service response.’ This would indicate that the example of “Jason” from the NDIS website would not be eligible as he does not require coordinated, long term, multidisciplinary supports. This could result in families self-selecting as not being eligible to take up the ECEI referral option.
Early Years partners are struggling to engage families in these early stages, and this could be as a result of engagement strategies not being tailored to family needs, for example offering group workshops without child care, or short time frames to organise focus groups.
Accessibility of the ECEI Approach, including in rural and remote areas
The use of interpreters supports access for those from CALD backgrounds, however there is extremely limited inclusion of interpreting in NDIS plans. Based on feedback from parents, there is also limited use of interpreters when setting up plans together, and this is occurring in metropolitan as well as rural and remote areas.
Because the establishment of partners in the Victorian roll out is in its infancy, it is difficult to quantify and comment on their adequacy in terms of accessibility, however early communication from the partners demonstrates a commitment to a place-based, family-centred approach in the local area. Partners are indicating that they will meet with families where ever families feel most comfortable, whether that be in the home, kindergarten or other requested location, and offer supports in the child’s key environment.
The principle of choice of ECEI providers
There is no choice in Early Years Access Partners, with one partner contracted and designated for each region, and we feel that this contradicts the NDIA principal of choice and control. There is a need for a robust quality and safeguarding framework that ensures families have access to a diverse range of providers delivering best practice.
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We appreciate the opportunity to make a submission to the committee’s inquiry into the implementation, performance and governance of the NDIS, and will continue to work in partnership with all stakeholders to provide the best possible support for people with a disability, their families and carers.
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