Provision of services under the
NDIS Early Childhood Early
Intervention Approach
Joint Standing Committee on the National Disability Insurance Scheme Inquiry
August 2017
Submission by KU Children’s Services
Abbi, 5 years
About KU Children’s Services
As Australia’s most experienced not for profit provider of quality early education and care, KU Children’s Services (KU) is committed to the inclusion of children with disability and developmental delay in high quality educational programs. KU’s vision is that ‘Every child has a right to feel safe, nurtured, valued and heard’.
KU operates almost 140 early education services across NSW, ACT, VIC and QLD. These services include long day care, preschool/kindergarten, out of school hours care, vacation care, occasional care, family programs, early intervention programs and other early childhood education and care services.
KU’s Education Support team supports over 750 children per year to actively participate in KU’s early education and care programs.
KU also provides a range of Early Intervention services in the Sydney and Nepean Blue Mountains area including:
Family Supported Playgroups
Early Intervention Preschool
Therapy services e.g. speech therapy, occupational therapy
Autism specific services
Individualised support such as transition to school support
Community outreach
In addition, KU, together with our partners, provides inclusion support to over 12,000 early childhood education services across NSW, ACT, QLD and VIC under the Australian Government funded Inclusion Support Programs (refer separate submission).
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KU’s experience of the ECEI approach
KU has been part of the transition to NDIS as an early intervention provider in the Nepean Blue Mountains early roll out site, a Year 1 transitioning provider in the South Western Sydney region and a Year 2 transitioning provider in other Sydney regions.
KU is pleased that the unique nature of providing early childhood intervention supports to children birth to 6 years old has been recognised and a different approach put in place by the NDIA to help families access NDIS planning services.
We support the concept of the Early Childhood Early Intervention (ECEI) approach, however it has been implemented differently in NSW to other states and territories and there have been significant challenges experienced by families and providers leading to high levels of anxiety for families.
There is also a risk that due to the conflict of interest inherent in the NSW ECEI approach disrupting the ability for a fair marketplace to operate for NDIS early intervention services, there will be less choice of supports available for families as some organisations may have to close programs and services that are no longer viable.
We wish to make comment on the following aspects of our experience with the ECEI approach in NSW to date:
Selection of ECEI providers
In all other states and territories, the selection of a single provider for each region to deliver the ECEI approach was undertaken through an open, selective tender process. In NSW the Department of Family and Community Services approached specific early childhood intervention providers in October 2016 to engage them to provide ECEI supports as a transitional arrangement to June 2018. The selection process appeared to be arbitrary and offered no transparency to other early childhood intervention providers or families and there was no open tender process undertaken.
Conflict of interest
In another departure from the national approach to ECEI where ECEI providers are not allowed to also provide NDIS supports to prevent any conflict of interest, NSW has engaged several early childhood intervention providers in each region to deliver the ECEI who also provide NDIS supports in the same regions.
The ECEI provider supports the family to develop an NDIS plan for the child and then should provide the family with information to help them choose the provider they wish to use to deliver the NDIS supports. Due to the relationship developed with the family during the planning process it is quite likely that the family will choose to stay with the ECEI provider organisation to deliver their supports as this avoids them needing to describe the child’s needs in detail to another provider. This disadvantages other early childhood providers that were not selected as ECEI providers in an arbitrary selection process.
A number of families that attend KU early intervention services have also related the following experiences which demonstrate that conflict of interest can drive situations where the NDIS Guidelines are not being followed and has a detrimental impact on the supports accessible to families:
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When a family told the ECEI provider that after the planning meeting they were going to purchase supports from KU not the ECEI provider, the ECEI staff member told them that meant that their planning meeting would be delayed and they couldn’t provide them with a planning meeting in the near future.
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An ECEI provider told a family that they must purchase therapy from the ECEI provider as part of their NDIS plan. (This situation has been replicated in other areas as described by attendees at NDIS regional information meetings in Sydney attended by KU staff)
The setup of ECEI in NSW has resulted in a situation where the providers who are engaged to deliver ECEI (and are themselves NDIS providers) are effectively in control of the referral pathways to other early intervention providers. As a non-ECEI provider, KU has experienced a decrease in referrals for support since the introduction of the ECEI approach as paediatricians and other referral organisations must refer families first to the ECEI provider and it appears that families are not being referred onto other organisations.
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Timeframes
In the Year 1 roll out, the ECEI providers were advised of their selection only a couple of weeks prior to the beginning of the ECEI approach on 1 November 2016. The timeframes that the ECEI providers were given to deliver planning meetings and develop plans for eligible children were extremely tight and as at August 4th 2017, only 25% of children accessing early intervention support provided by KU in the Year 1 rollout area had an NDIS plan in place.
The NSW Department of Family Services had advised all providers that funding would be stepped down and cease as at 30 June 2017, however this has had to be extended temporarily as the planning process has not been completed for families.
Families who already accessed supports from ECEI providers were prioritised in the NDIS planning process. This means that families who access early intervention from non-ECEI providers have been disadvantaged as they are waiting longer to access their plans than other families. Many families who were meant to have plans completed by 30 June 2017 have yet to be invited to a planning meeting.
Feedback from families
Families who attend KU early childhood intervention services have provided feedback around their experiences of the ECEI approach. In general this has not appeared to have been a positive experience for most families. Issues raised have included:
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High levels of anxiety about the whole process experienced by all families, particularly those who don’t feel as confident to advocate well for their child and vulnerable families.
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Families feel that they have been “pushed” into having telephone planning meetings when they would prefer to meet face to face, ideally in the home environment as they have identified that planners’ attitudes to the amount of support their child needs have softened once they meet the child.
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Some families who are registered as not being able to be contacted by NDIA have not received a phone call/letter inviting them to a meeting.
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Families are worried that if they don’t get the planning process “right the first time” there won’t be an opportunity for change.
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Confusion around which ECEI provider will contact the family as there are several providers in the area and no communication in terms of which families have been allocated to which provider.
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Confusion around which ECEI provider to contact when a family is trying to access early intervention supports for the first time as the family has a choice between several and each have a different waiting list time.
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Lack of communication around the ECEI approach for families.
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Families being told that they are not on a list provided to them by the NDIA and as such they could not access any planning support.
‘Soft entry’ program
The NDIS set up of individual plans and focus on individual supports has led to the situation where group support programs are not adequately funded and are no longer viable to operate. The ECEI providers have a role to offer supports but it is very unclear at this stage how this is going to be implemented. In some areas there are already established programs provided by other organisations which have been operating for many years which may not be able to continue.
KU Starting Points Macarthur for example, relies heavily on NSW ADHC funding to provide support to over 90 families with children with disability or developmental delay and is an integral part of the referral pathways in the Campbelltown, NSW, area from Paediatricians, Community Nurses, education settings and the CATS Assessment team. KU Starting Points Macarthur operates in a purpose built building and provides group early intervention for children to support them to achieve their goals including the development of social and emotional skills and at the same time provides a psychologist supported group for the families, many of whom are vulnerable, to share their successes and challenges.
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The program has operated for over 24 years and has enabled families to form strong peer support networks which help them navigate the often very stressful journey of supporting their child and family, with these relationships often lasting many years.
It is critical that vulnerable families with children with high support needs are able to access community supports to support their own mental health needs but this seems to be a significant gap in the overall NDIS provision. Unless this is able to be funded under the ILC, communities such as the Campbelltown area will lose access to long established programs, resulting in less choice and control for families, contradicting the fundamental tenet of the NDIS.
Recommendations
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The NSW ECEI approach to be changed to replicate the approach implemented in other states and territories to remove the inherent conflict of interest and incorporate any lessons learned from other jurisdictions. This should include an open selective tender to select the most appropriate provider for each region.
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Implement an audit/compliance process in relation to referral pathways to identify where ECEI providers have not operated within their contractual obligations with regards to managing conflicts of interest.
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NDIA and ECEI providers to provide more communication around the ECEI approach to families and mainstream providers.
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Timeframes for the roll out of NDIS planning to be realistic and be reflected in the step-down payments to block funded providers on an actual implementation basis not an estimated basis.
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The provision of soft entry supports to be reviewed and take into account the existence of already established programs which will not be funded adequately under the NDIS as it currently stands.
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Clear communication regarding supports and timeframes from the ECEI providers for “new” children in the Year 1 rollout area.
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Clear communication from ECEI providers regarding the soft entry supports that they are providing so that mainstream services have clear and consistent referral pathways.
Availability for further comment
KU values the opportunity to provide comment on the ECEI approach and NDIS transition. We are happy to provide further information to the Committee if required.
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