SDN Children’s Services
Response to the Inquiry into the Provision of Services under the
NDIS Early Childhood Early Intervention Approach, August 2017
- Introduction SDN Children’s Services (SDN) welcomes the opportunity to respond to the Joint Standing Committee’s Inquiry into the Provision of Services under the National Disability Insurance Scheme (NDIS) Early Childhood Early Intervention (ECEI) Approach.
SDN has significant experience and knowledge delivering early childhood intervention programs in NSW, and supports a nationally consistent approach to deliver best-practice early childhood intervention services. In this regard, SDN welcomed the inclusion of the ECEI Approach into the Scheme rollout as much of it was designed using best practice, evidence-based early childhood intervention practices. A successfully implemented ECEI approach has the potential to ensure that those children with the highest need enter the NDIS, while still providing appropriate information and referral services to families with children who do not require reasonable and necessary supports from the NDIS.
However, since the introduction of the ECEI Approach there have been several challenges that both families and service providers have encountered. In particular, the funding provided to implement the ECEI Approach does not allow service providers to properly deliver many of the fundamental early childhood intervention supports. These funding constraints, combined with sector-wide workforce shortages, has meant that it has been difficult to effectively build the strength and capacity of many families and their children that are referred to ECEI.
It is in this context that SDN supports the need for an examination of the implementation, rather than the design, of ECEI services under the NDIS.
- About SDN SDN Children‘s Services is a not-for-profit organisation established in 1905, and is one of Australia‘s most experienced and trusted leaders in mainstream early education and child care; early childhood intervention, disability services for children, and family support.
Our mission is to:
- provide high-quality, inclusive early childhood education and care
- strengthen families and communities
- address inequalities faced by children Through our Strategic Plan we seek to enhance the wellbeing of children and to make sure that children facing challenges have a place in the services we operate, support and advocate for.
1 of 9
We operate an integrated model of service delivery using our Pathways Approach that brings together our expertise in mainstream and specialised service delivery. In all, around 5,000 children, families and other service providers benefit from SDN’s work each year.
Our family-centred, strengths based early intervention and inclusion services are well regarded across the sector, and we are a provider of several state and federal government funded early intervention programs. In particular:
-
In 2015 we were selected by the NDIA to trial the ECEI Approach in the Nepean Blue Mountains in NSW and continue to provide these services as an NDIS Partner in the Community.
-
In 2016 we began to provide NDIS ECEI Transition Provider services across NSW.
-
In 2017 we were engaged by the NDIA to provide ECEI Transition Advisor services
-
We were selected to partner with the NDIA to be an NDIS Registered Provider for children in the ACT from 2014, and have been providing registered supports in the Nepean Blue Mountains in NSW since July 2015, and the rest of NSW as transition occurs.
SDN’s submission focuses on our experience working with children and their families through our early childhood education and care services, and State and Federal government early intervention programs. We also draw on our recent experience providing services to children and their families under the NDIS, as both a NSW ECEI Provider and a Registered Provider of supports in NSW and the ACT.
- SDN’s response a. the eligibility criteria for determining access to the ECEI pathway ECEI Partners currently receive referrals from a range of sources to support children aged 0 6 with a developmental delay or disability. This may include, but is not limited to: the NDIA; early childhood education and care services; health professionals and self-referrals. SDN does not support placing any restrictions on referral pathways or on the ability of families to contact ECEI Partners directly for support.
SDN believes that in most cases the appropriate level of support can only be determined once an in-depth understanding of the family and child is taken into account. Experienced ECEI practitioners remain best placed to undertake this assessment, and to determine whether access to the ECEI pathway is appropriate for the child.
The early years of life is when developmental trajectories are varied and flexible. Families should not be dependent on slow or non-existent assessment services or require a diagnostic label to access the ECEI pathway.
2 of 9
b. the service needs of NDIS participants receiving support under the ECEI pathway
NDIS Participants have a more intensive service need than those children who only require short-term interventions under the ECEI Approach. In our experience, ECEI Partners do not have the funded workforce to provide intensive early childhood intervention supports to an NDIS participant while they progress through the planning process to receive funded supports.
In NSW, a large proportion of ECEI resourcing is currently dedicated to the NDIS planning process due to the sheer volume of plans required to be developed. As there is limited funding available under the ECEI Approach, and the planning process for participants can be quite drawn out, it is not possible to dedicate meaningful time to deliver intensive supports to NDIS participants while they wait for a plan.
Through the previous state-based funding model, families and children that required intensive early intervention support would have received the support they needed as soon as a service provider accepted the referral. Under the ECEI Approach, these families do not get the support they need until both an access request (for non-defined participants), and an appropriate reasonable and necessary support plan has been prepared by the ECEI Partner, and approved by an NDIA delegate. This significantly delays families’ access to support.
The NDIA would need to provide additional funding to allow ECEI providers to deliver continuity of support from the point of referral, to the point that the NDIS plan is handed over to a registered provider. This funding would enable ECEI providers to engage additional resources to deliver more intensive early childhood intervention supports to NDIS participants.
c. the timeframe in receiving services under the ECEI pathway SDN believes that timely access to early intervention services are of critical importance to families, children and the long-term sustainability of the NDIA.
The ECEI Approach was designed with this in mind. The NDIA Statement of Requirements acknowledges there is evidence that “timely access to best-practice early intervention can improve the functional capacity and well-being for a child with a developmental delay or disability and their family”1. Timely access to early intervention services also means that families and children are less likely to require longer-term formal supports from the NDIA and/or reduces exclusion from other mainstream or community supports2.
Unfortunately, the ability of service providers to provide timely supports under the ECEI Approach has been hindered by several factors during its implementation. These include:
1 NDIA Annex E to the Statement of Requirements Early Childhood Early Intervention Services 1.2.2 2 NDIA Annex E to the Statement of Requirements Early Childhood Early Intervention Services 1.2
3 of 9
-
The level of funding provided to deliver the services does not allow service providers to engage sufficient staff to respond to changes in demand for support
-
The well documented disability sector staff shortages3 has made recruiting suitable early intervention staff a lengthy and difficult process
-
The long lead-in time it takes to build adequate NDIS planning expertise in existing or new early intervention staff
-
The demand for support has created long waiting lists for non-defined children (new children) that present through a referral channel. Due to capacity constraints, priority is given to children that need a NDIS plan, meaning that some families are waiting too long to receive short term intervention supports under the ECEI
Approach
- The current Access Request and NDIS Plan delegate approval process is lengthy, meaning that some families can wait months to receive a funded NDIS plan.
While SDN fully supports the methodology and evidence behind the design of the ECEI Approach, the above implementation issues have resulted in poor outcomes for families and children waiting for appropriate support.
d. the adequacy of funding for services under the ECEI pathway The funding to provide ECEI services must be commensurate with the functions and skillset required to deliver best-practice services. Currently ECEI service providers are being asked to deliver too much given the current allocated funding.
There is a significant disparity between the funding previously provided by the NSW Government to deliver early intervention services and the current ECEI Approach. Unfortunately, this lack of funding is impacting services – resulting in the ECEI Approach not being delivered in line with its best-practice design.
If requested, SDN would support working with the NDIA to develop a more realistic financial model that enables providers to deliver the ECEI Approach as intended.
e. the costs associated with ECEI services, including costs in relation to initial diagnosis and testing for potential ECEI participants
ThecostsofECEIservices
The bulk of costs associated with delivering best-practice ECEI services are dedicated to engaging suitably experienced early intervention workers. SDN recommends that the NDIA conduct a proper analysis of the cost of providers engaging experienced early intervention staff to deliver the functions of the ECEI Approach. If needed, SDN would be happy to assist the NDIA with any inputs it may need to conduct this analysis.
4 of 9
Evidence of best practice tells us that work with young children requires a professional, qualified transdisciplinary team. In NSW, state-based early childhood intervention programs had previously been adequately funded to engage highly qualified transdisciplinary teams. This included, but was not limited to: early childhood teachers, occupational therapists, social workers, speech therapists and physiotherapists.
An ECEI workforce not only requires specialist disciplinary skills. It also requires a commitment to working using a transdisciplinary approach, skills in working with and through families, and commitment to working collaboratively with other early years’ professionals and agencies. These professionals expect remuneration and conditions commensurate with skills and experience, and in-service training and professional supervision.
With the limited funding available under the Approach, it has been challenging to retain and recruit suitably experienced staff from these disciplines. We are aware that this is a sector-wide issue affecting a large proportion of early intervention providers. As a result, providers currently have no option than to employ fewer staff from these disciplines, or rely on a workforce with lower qualifications or experience. This compromise has a detrimental impact on the quality and quantity of ECEI services that are delivered.
Another consequence of the lack of adequate funding is that some experienced early intervention Allied Health Professionals are choosing to transition into private practice, or work for a registered provider of supports where the remuneration is greater.
Initialdiagnosisorassessment
SDN would not support requiring children to have a diagnosis or be tested prior to being referred to an ECEI provider. As previously mentioned, ECEI practitioners remain best placed to undertake the initial assessment of a child to determine whether access to the ECEI pathway is appropriate.
Currently the NDIA requires ECEI providers to collect information about a child’s development delay or disability by using the PEDICAT tool. These results are used by the NDIA to validate any reasonable and necessary supports requested during the planning process, as well as to measure any improvements in the child’s development once they exit the ECEI Pathway.
PEDICAT is an inappropriate and inadequate developmental assessment tool for children. SDN recommends that PEDICAT be replaced by a more relevant and useful tool for children aged 0-6 (for example, Ages and Stages Questionnaires).
f. the evidence of the effectiveness of the ECEI Approach The ECEI Approach is still relatively new with the model undergoing several iterations since being trialled in the Nepean Blue Mountains region in 2015. SDN is encouraged that the current design of the ECEI Approach has been developed using evidence-based best
5 of 9
practice, however, there are some early signs that the implementation of the Approach may not be delivering the desired outcomes to families and their children.
While it is too early to determine with any certainty the effectiveness of the Approach, NSW ECEI providers are dealing with a number of issues. Some of these issues have been discussed in section C and include: growing waiting lists for assessment, sector-wide workforce constraints, funding pressures and having to use resources to prioritise NDIS planning over short-term interventions. These issues all impact the effectiveness of ECEI services – particularly for those children on waiting lists that are not receiving any early intervention support.
If these implementation issues are not adequately addressed by the NDIA, there is a real risk that a cohort of children on waiting lists may not receive the necessary support they need in a timeframe that will ensure an effective early intervention. This will result in a poor outcome for families and children, who may develop potential longer-term developmental issues that could have otherwise been prevented.
g. the robustness of the data required to identify and deliver services to participants under the ECEI
As previously discussed, SDN believes that in most cases the appropriate level of support or services can only be determined once an in-depth understanding of the family and child is completed. Experienced and suitably qualified ECEI practitioners remain best placed to undertake this assessment, and to determine what ECEI services are appropriate for the child.
The nature of early childhood developmental delays and disabilities means that using data or assessment tools in isolation can be detrimental to effective service delivery. It critical that ECEI providers are properly funded to engage suitably qualified practitioners that can assess a child’s developmental delay or disability, and identify appropriate services.
SDN does not believe that PEDICAT is the preferred or an appropriate developmental assessment tool for children. SDN recommends that the NDIA replaces PEDICAT with a more relevant and useful tool for children aged 0-6, for example, the Ages and Stages Questionnaires.
h. the adequacy of information for potential ECEI participants and other stakeholders
SDN believes that the provision of ECEI information is currently delivered in a fragmented way and can improve. SDN recommends that all current ECEI communications be consolidated and future information be developed by the NDIA in collaboration with ECEI providers.
ECEI providers should be treated as partners in implementing the Approach and communicating with participants and stakeholders. This should include designing and trialling improvements, in bringing issues forward and solving service delivery problems.
6 of 9
SDN is encouraged that the NDIA has begun to investigate the use of an NDIS Partners Community of Practice for this purpose. We would also recommend that the NDIA look into the partnership model that was used through the NSW Inclusion and Professional Support Programme Alliance and the National Support Agency Alliance that was part of the (now ended) Department of Education and Training funded Inclusion and Professional Support Programme.
SDN would also recommend that the NDIA work with states and territories to facilitate the development of formal communication and referral protocols between ECEI and critical services such as health, education, child protection, and child care to support integration of ECEI into the early years’ system.
The NDIA should consider funding a separate ECEI referral and support service to assist those families and children that may need a referral to an appropriate mainstream services or community support. Similar successful referral services have been funded by state governments to assist families and children to access mainstream or community services in other sectors. This includes the NSW Family Referral Service4 for those children that do not meet the statutory child protection threshold, as well as the WA Health Navigator5 to help people manage their chronic health condition by assisting them to navigate the health system.
i. the accessibility of the ECEI Approach, including in rural and remote areas SDN is not able to comment as we do not provide services in remote or rural areas.
j. the principle of choice of ECEI providers The NDIS Partners in the Community Program Guidelines states that no more than one Early Childhood Early Intervention Partner will be appointed in each Service Area6. This policy means that there is currently no choice for families to select their preferred ECEI provider.
SDN would support the NDIA engaging more than one ECEI Partner in service areas where there is a high demand for support. This would allow families more choice over ECEI providers, encourage competition and therefore increase the quality of service provided to families. To maintain a level of control over the services delivered, the NDIA could consider imposing a limit on the number of ECEI providers in each service area (for example, two or three).
The current conflict of interest clause in the ECEI Approach also removes an element of choice and control from families as ECEI providers are precluded from also being Registered Providers of support. In SDN’s experience, some of the most experienced and high
4 http://www.familyreferralservice.com.au/index.html 5 http://healthywa.wa.gov.au/healthnavigator 6 NDIS Partners in the Community Program Guidelines, Page 1
7 of 9
performing early intervention providers have registered to provide NDIS supports, which has reduced the pool of suitable organisations to deliver ECEI services.
Our experience in this sector has also taught us that in many cases the best outcome for the family is to have continuity of support throughout their child’s developmental journey. While SDN agrees that the NDIA needs to manage any potential conflict of interest within the ECEI Approach, the current separation of ECEI provider and the NDIS provider of supports may not be delivering the best outcomes for families and their children.
k. the application of current research and innovation in the identification of conditions covered by the ECEI Approach, and in the delivery of ECEI services
SDN maintains that ECEI practitioners are best placed to identify conditions covered by the ECEI Approach. ECEI practitioners have expertise in understanding typical and atypical child development; in family systems and ecology; and in understanding the complex context of mainstream and specialist early years’ systems in which ECEI will operate and the enablers of and barriers to inclusion.
High quality early childhood education programs, led by university qualified teachers, are also critical to a sustainable early childhood intervention system, including identifying conditions covered by the Approach. Advice from specialists to mainstream providers has frequently been a component of block funded Early Childhood Intervention service delivery, and should be maintained.
The early education and child care system could be leveraged further to meet the needs of potential ECEI participants and to reduce long-term scheme costs. This would require ensuring that early education and child care services have equitable access to transdisciplinary advisory teams that could be attached to the ECEI provider.
- Conclusion Overall, SDN commends the NDIA’s best-practice design of the ECEI programme. Early childhood intervention is a critical as we know that fundamental cognitive and non cognitive skills are produced in the early years of childhood (Heckman and Masterov, 2007). For many children, a development delay that they may experience in these early years can be mitigated with quality early childhood intervention, but only if caught early. Because of this, SDN was encouraged that the ECEI Approach was eventually included in the Scheme rollout.
However, it is critical that the Commonwealth and the NDIA recognise that effective early childhood intervention will require a realistic financial investment to ensure its success. For the investment in children to be worthwhile, funding to provide ECEI services must be commensurate with the functions required to deliver best practice services.
8 of 9
The NDIA must also address several implementation concerns raised in this response if the ECEI Approach is to succeed. These include that:
-
the disability sector’s staff shortages are having a real impact on ECEI support
-
the demand for ECEI support has been underestimated, which has increased waiting lists for non-defined children (new children)
-
using data or assessment tools in isolation can be detrimental to effective service delivery unless supported by experienced ECEI practitioners
-
the current Access Request and NDIS Plan delegate approval process should be streamlined
-
referral and information pathways between ECEI and critical services such as health, education, child protection, and child care needs to improve, and
-
the NDIA should engage more than one ECEI Partner in each service delivery area and revisit its conflict of interest clause.
The return on investment of adequately funding ECEI services will mean fewer children entering NDIS or require long-term supports. This will also mitigate the risk of secondary disabilities, family breakdowns and mental illnesses associated with caring for someone that requires long-term support. Put simply, the opportunity cost of not investing adequately in early intervention services is that children may end up requiring formal funded supports from the scheme for much longer than if the early intervention was successful.
9 of 9