Submission 62 — Occupational Therapy Australia — Provision of services under the NDIS Early Childhood Early Intervention Approach | External submission

PARLIAMENT OF AUSTRALIA

JOINT STANDING COMMITTEE ON THE

NATIONAL DISABILITY INSURANCE SCHEME

PROVISION OF SERVICES UNDER THE NDIS

EARLY CHILDHOOD EARLY INTERVENTION

APPROACH

OCCUPATIONAL THERAPY AUSTRALIA (OTA)

SUBMISSION

AUGUST 2017

Occupational Therapy Australia Limited ABN 27 025 075 008   | ACN 127 396 945

6 / 340 Gore St. Fitzroy VIC 3065

Ph +61 3 9415 2900   | Fax +61 3 9416 1421   |  Email policy@otaus.com.au   |  Website www.otaus.com.au

Introduction

Occupational Therapy Australia (OTA) welcomes this opportunity to make a submission to the Joint Standing Committee on the National Disability Insurance Scheme’s inquiry into the provision of services under the NDIS Early Childhood Early Intervention Approach.

Occupational Therapy Australia is the professional association and peak representative body for occupational therapists in Australia. As of March 2017 there were around 19,000 nationally registered occupational therapists working across the government, non-government, private and community sectors in Australia. Occupational therapists are allied health professionals whose role is to enable their clients to participate in meaningful and productive activities.

Occupational therapists provide services such as physical and mental health therapy, vocational rehabilitation, chronic disease management, assessments for assistive technology and home modifications, and key disability supports and services.

As such, they are key providers of services to many NDIS participants, including children.

OTA is a strong supporter of the NDIS and its focus on providing individualised support for participants with informed choice and control over their plans. Occupational therapists worked across all NDIS launch sites and contributed to the design and implementation of the scheme during its trial period. They are continuing to support participants as the scheme transitions to full rollout.

Those occupational therapists working in the area of Early Childhood Early Intervention (ECEI) have raised concerns about several aspects of the National Disability Insurance Agency’s (NDIA) management of this crucially important part of the NDIS.

Summary of recommendations

 The National Disability Insurance Agency should conduct a wide-ranging review of its communication processes to identify examples of poor practice and develop solutions to the problem of untimely responses to queries from participants and providers.  NDIS participants and providers should be able to make direct contact with Planners rather than be required to ring their local NDIS office or use a generic email address.  The training provided to NDIS Planners should be revised to provide for more comprehensive participant plans and reduce the frequency of plan reviews. NDIS providers, including occupational therapists, should be consulted throughout the process of developing or refining training material.  Appropriate safeguards should be implemented to prevent Early Childhood Partners from having excessive influence over what supports are included in a child’s plan, particularly when the EC Partner is also a registered NDIS service provider.  Generic templates intended to guide the development of plans for children should be used at a minimum in order to ensure that each child receives individualised supports that are tailored to their particular needs.

 Factors contributing to long waiting times to access early childhood supports should be identified and addressed as a matter of urgency by the NDIA.  The NDIS Price Guide should be modified to reflect the costs of providing peer therapy to children with developmental disabilities who are transitioning from individual to group therapy.  The support needs of siblings of children with disability should be prioritised in the treatment plans of children with disability. The NDIS should fund sibling support groups that have proven to be an effective means of assisting siblings in these situations to manage their emotions.  Occupational therapists should be appropriately compensated for the time it takes to prepare reports for clients who are seeking funding through the NDIS. Additionally, greater clarity should be provided by the NDIA around when such reports may be required.  In exceptional cases, children who have not yet received a formal diagnosis should be able to access supports through the NDIS. However, this should only occur on the recommendation of a suitably qualified health care professional who can produce evidence in support of the child’s need for funding.  The NDIS website should be enhanced to make it easier for providers and participants to navigate. Email alerts should be sent when new documents/guidelines are added to the website and a notification should be added to the homepage.  Steps should be taken to improve the accessibility of the ECEI Approach in rural and remote areas, including greater use of videoconferencing to communicate with clients and families.  The NDIA should clarify whether the $1000 annual travel limit means that each participant has a maximum of $1000 per annum to offset the travel costs of a team of different providers, or if each service provider receives a maximum subsidy of $1000 for each participant they work with.  The NDIA should prioritise the implementation of appropriate safeguards to prevent EC Partners that are also registered NDIS service providers from automatically referring families to their own services. Any cases of partner organisations repeatedly encouraging families to access services provided by their own organisation should be thoroughly investigated.  The situation in New South Wales, whereby organisations that were previously block funded by Ageing, Disability and Home Care (ADHC) have been selected as EC Partners, should be closely monitored to assess the impact of this arrangement on private practices.  NDIS participants should be made aware of all appropriately qualified service providers within a designated distance of their residence. Any list of local providers that is given to families should include providers that are not NDIS-registered but can provide services if the family chooses to self-manage their funding.  Consideration should be given to broadening the types of interventions that are promoted as best practice for people with autism, as research suggests that a relational, developmental approach to autism treatment is more beneficial.

Communication

Irrespective of what aspect of the NDIS rollout is being considered, the issue most commonly raised by our members and their clients is that of poor communication. The entire scheme is being

compromised by the inadequate channels of communication between its key players. Participants and their carers should be able to reach the National Disability Insurance Agency (NDIA) within a reasonable period of time, and the Agency’s undertakings to return telephone calls should be honoured. Emails should, at the very least, be acknowledged.

One therapist noted that it can take weeks or even months to receive a reply from the NDIA. Therapists are told to leave a message and someone will return their call, however this is seriously impractical for private practitioners who are running clinics and are unable to answer phone calls during the day while with clients. Additionally, changes to NDIS processes seem to occur on a daily basis, and these are often not communicated to service providers or families.

This therapist also observed that staff who are supposed to know the answers very often do not, while the information provided is not consistent across NDIA employees. OTA is often advised by NDIS providers that they never speak to the same person and are constantly having to provide the same information.

If a Planner contacts a family about a plan review or other query, the family cannot get back in touch with them unless they email their local NDIS office or phone the NDIS and leave a message.

The NDIA’s apparent inability to engage meaningfully with service providers, and the difficulties involved in navigating the NDIA website, act as disincentives to registration as an NDIS provider. At a time when there are doubts about whether the disability workforce will be sufficient to meet NDIS driven demand, the NDIA should not be allowing such disincentives to undermine recruitment.

OTA members have also called for more formalised communication channels between Early Childhood (EC) Partners and service providers.

Our members report that vulnerable families have trouble navigating the bureaucracy involved with the NDIS, its service partners and different providers. Whereas once they dealt with a not-for-profit service focussed squarely on the wellbeing of the child, they must now make unanswered telephone calls, wait to speak to an inexperienced Planner, navigate a difficult website and often contend with the marketing pitch of profit driven service providers.

Recommendation 1: The National Disability Insurance Agency should conduct a wide-ranging review of its communication processes to identify examples of poor practice and develop solutions to the problem of untimely responses to queries from participants and providers. One such solution should be the development of a specific set of key performance indicators to monitor and evaluate the performance of Agency staff with respect to replying to emails and returning phone calls in a timely manner.

Recommendation 2: NDIS participants and providers should be able to make direct contact with Planners rather than be required to ring their local NDIS office or use a generic email address.

TOR A: The eligibility criteria for determining access to the ECEI pathway

One occupational therapist in New South Wales noted that there has so far been little contact with clients who are new to the system; in particular those who do not have diagnoses/disabilities which have been ‘traditionally’ funded through programs such as Helping Children with Autism (HCWA) and Better Start for Children with Disability (Better Start).

TOR B: The service needs of NDIS participants receiving support under the ECEI pathway

OTA is concerned that the identified service needs of participants seem to depend less on actual need than on the knowledge and experience of the Planner they are allocated, whether the participants’ families know what to ask for, and whether they can predict what will be needed in the future. This gives rise to inconsistent and often quite inappropriate plans.

It is our understanding that while EC Partners develop and propose client plans, it is a delegate of the NDIA CEO who actually approves plans. Further, it is our understanding that these delegates are usually NDIS Planners.

Due to the fact that Planners are recruited from a variety of backgrounds, their understanding of appropriate options to support participants to achieve their goals, and the role of occupational therapists in this process, is often poor. This problem is particularly pronounced in the field of paediatric disability, where the nature and extent of disability can be difficult to determine, and distressed parents are in need of advice and support of the highest quality. An occupational therapist in South Australia reported that families are increasingly requesting a case coordinator to accompany them to planning meetings and advocate on their behalf, as they do not feel confident that the Planner will understand their needs.

Case study: Client has been accessing Occupational Therapy service since May 2016. Client required NDIS review and OT and SP wrote supporting documents and recommendations to be taken to meeting. OT and SP recommended NDIS provide funding for the client to access psychology sessions. Client requires significant support due to Autism Spectrum Disorder, to manage behaviour to engage in school and activities of daily living. Client’s parent was told by planner to ask GP for Mental Health Care Plan to access psychology services. This only provides rebate for 10 sessions. Client has significant difficulties with anxiety and interacting socially, psychology is almost always recommended after diagnosis of ASD due to the significant challenges with anxiety and behaviour frequently experienced.

Funding for respite services was also reduced by half from previous plan. A comment was made to the parent that the child, aged 6 years, should not be accessing overnight respite. The client in fact does not access overnight respite. The planner also referred to the day activities respite option she attends as “excursions” and cut the amount previously allocated

by more than half. The planner did not contact therapists to clarify and did not seem to understand the importance of respite for child and family.

Providers in New South Wales have reported that EC Partners appear to have a great deal of influence over the goals that are identified during planning meetings. Those tasked with developing plans often mean well but are overshadowed by their organisation’s guidelines and their own understanding and bias.

It is clear that NDIS Planners frequently underestimate the hours of therapy required for a participant to achieve their goals, which subsequently affects the quality of their plan. There have also been reports of the wrong funding streams being allocated to clients. An occupational therapist in South Australia provided an example of clients without a physical disability being funded for hoist provision when this was not requested. The Planner was subsequently contacted about this and changed the plan accordingly, however the hoist funding remained. Additionally, no funding was allocated in the client’s plan for their regular skills development program, despite this having been specifically requested.

A number of other issues have been raised by OTA members in regards to NDIS Planners, including the fact that some Planners defer meetings because of their workload. When the client’s funding date expires, families are told that their old plan will be extended or their new plan will be backdated, however this tends not to occur. Therapists have continued to provide services as they have been led to believe that the client’s funding will be extended, however in many cases it has not.

There have also been reports of Planners not reading reports before planning meetings. An OTA member in South Australia provided the following example of the implications of this:

I have a family with very high needs who did not receive funding for mobility, continence and other aids because their needs were dismissed by the planner. I believe it is a matter of time before the carer will have an injury as a result of not having the supports she needs. Not only did they not read reports, dismiss needs, not provide what the client needed, underfund the client but then the planner told the client’s family that the mobility aid is a restrictive practice and won’t be funded unless a case is put forward – they receive no additional funding for the restrictive practices assessment or report (instead [the Planner] told the client’s family that they would have to decide whether … the little therapy money they receive would be spent on trying to put a stronger case together or on therapy. As a therapist I am having trouble charging for my time to do the Restrictive Practices report to justify a piece of equipment I had already put an assessment report in for and from what I was told by the family was not read by the planner prior to going into their planning meeting. The amount of time, and resources mismanaged is ludicrous, not to mention I have a single parent who is feeling very overwhelmed emotionally, physically and financially having to keep “fighting” a system that is supposedly put in place to help make her and her son’s life better.

OTA acknowledges that some Planners do have an allied health background and have developed plans that adequately reflect the complexities of a participant’s needs.

OTA believes that occupational therapists should play a key role in working alongside NDIS Planners to assess and understand the functional needs of NDIS participants. Occupational therapists should also be consulted throughout the process of developing or refining training material for Planners.

As noted above, the amount of funding a client receives can also depend on whether their family knows what to ask for. An OTA member in South Australia reported that they have two clients who have undergone phone reviews that have not taken into account the parents’ capacity to answer questions. One child received no funding for occupational therapy because their parent advised the Planner that the child was able to manage. In reality, the child (who is eight years old but functioning at the level of a five year old) cannot even write their own name.

Concerns have also been raised about the decision to no longer fund interpreters, and how this will affect service providers who are unable to afford the fees for an interpreter to communicate with parents from culturally and linguistically diverse (CALD) backgrounds.

OTA is concerned that transitional arrangements in New South Wales are failing some children in need of ECEI services. One NSW member writes:

There are inconsistencies with the identified list of children with disabilities. This list is provided to the ECEI provider from ADHC/ADHC funded services, however in other areas across NSW this list is incomplete and individuals who were expected to be on the list were not. This means that a child who should be receiving a plan now has to wait until after June

Children that have previously received services under the Helping Children with Autism Scheme and the Better Start Initiative were expected to be on these lists however this is not always the case as some of these children have only used their funding to access private providers and never accessed ADHC or ADHC funded services. There are a lot of individuals using their funding in the hope of receiving an NDIS plan in a timely manner, however it is more than likely these children will be left without funding and on a waitlist. Their therapy and progress will be at a standstill unless they are able to financially cover the gap.

Concerns have also been raised about the decision to create a separate NDIS pathway for children aged 0-6, while the same arrangements are in place for children aged seven and above and adults who are eligible for the scheme. These children have access to the same staff who work with adults, and their understanding of the key issues facing children and families can be quite limited. The use of templates indicates that plans are not being adapted to meet the needs of particular children.

Recommendation 3: The training provided to NDIS Planners should be revised to provide for more comprehensive participant plans and reduce the frequency of plan reviews. NDIS providers, including occupational therapists, should be consulted throughout the process of developing or refining training material.

Recommendation 4: Appropriate safeguards should be implemented to prevent Early Childhood Partners from having excessive influence over what supports are included in a child’s plan, particularly when the EC Partner is also a registered NDIS service provider.

Recommendation 5: Generic templates intended to guide the development of plans for children should be used at a minimum in order to ensure that each child receives individualised supports that are tailored to their particular needs.

TOR C: The timeframe in receiving services under the ECEI pathway

By its very definition, ECEI is a service that needs to be provided in a timely fashion if it is to be effective. It is therefore of great concern that OTA members in Queensland report waits of six months for ECEI approval for clients, with the average wait reportedly three to four months even when the evidence of developmental delay is overwhelming. This is simply too long.

Similar reports have been received from occupational therapists working in the Northern Territory, with the NDIA being criticised for being too slow to assess and implement ECEI plans.

In New South Wales, occupational therapists report that families take three to four months to find and secure appropriate services after getting a plan approved. This leaves just eight or nine months to actually use the services and expend allocated funds before the plan is reviewed. Children then experience significant breaks in service delivery, with predictably detrimental effects on their progress.

Children under six with a new diagnosis in New South Wales do not have access to NDIS funding until at least July 2018 and receive very basic and general services from an Early Childhood Partner (a large NGO). This is a crucial time for families to be receiving support, and time lost can lead to added costs in the long term. OTA understands that this arrangement is a result of inadequate funding being allocated to support unidentified new clients who would access the scheme.

Arrangements in New South Wales appear to be in stark contrast with the scheme’s focus on ‘investing in people with disability early to improve their outcomes later in life’.

Recommendation 6: Factors contributing to long waiting times to access early childhood supports should be identified and addressed as a matter of urgency by the NDIA.

TOR D: The adequacy of funding for services under the ECEI pathway

While the NDIS is promoted as a scheme tailored to the needs of the individual, funding packages seem to be largely dependent on the knowledge and expertise of that individual’s NDIS Planner. This gives rise to considerable and inequitable variations in funding. One OTA member reports by way of example a seven year old child with Down syndrome and moderate developmental disabilities who requires occupational therapy, speech pathology and physiotherapy receiving a $3,000 funding package while a five year old child with high functioning Autism Spectrum Disorder is receiving $21,000.

Concerns have also been raised about situations whereby the families of children who receive a large amount of funding feel pressured to book multiple appointments with a therapist in order to

expend all the funds they have received. This is because they believe that their child will not be allocated the same amount when their plan is reviewed at the end of the year. There appears to be a misconception among families that if a child is allocated less funding, they will not be eligible for an increase in future if their needs change. This goes against the principles of choice and control that underpin the NDIS, and participants need to be informed that they will receive an appropriate level of funding depending on their current needs.

As per Submission 5 to the Committee’s inquiry (name withheld), the NDIS is currently not providing funding options for young children to attend small social group therapy. Currently, group therapy is funded at a rate that is not viable for clinics to implement, with rigid therapist to child ratios that do not take into account the needs of the child.

The submission states the following:

Children who have high needs in terms of behaviour management, explosive reactions and their ability to process their own and other’s emotions and reactions require continual attention and adaptation by a therapist during therapy. Many ECEI clients would not be able to participate in larger “traditional” group therapy until they have reached a certain level in their ability to cope with controlled peer therapy. This type of therapy relies on a ratio of 1 therapist to 2 children then 2:3 and progressing to 2:4 and the current NDIS pricing structure does not support this type of progression.

OTA agrees that changes to the NDIS Price Guide are needed to reflect the costs of providing peer therapy to children with developmental disabilities who are transitioning from individual to group therapy.

Submission 5 also highlights the need for funding to support siblings of children with disabilities; recognising that the challenges associated with raising a child with special needs can have a significant impact on the health and wellbeing of other children in the family. Sibling support groups facilitated by trained therapists have proven to be an effective means of assisting siblings in these situations to manage their emotions. OTA supports the call for siblings to be included in the integral treatment plan of a child diagnosed with special needs, or a non-diagnosed child who is showing delays and disruptions in his/her development, in order to reduce their likelihood of requiring mental health support in the future.

Recommendation 7: The NDIS Price Guide should be modified to reflect the costs of providing peer therapy to children with developmental disabilities who are transitioning from individual to group therapy.

Recommendation 8: The support needs of siblings of children with disability should be prioritised in the treatment plans of children with disability. The NDIS should fund sibling support groups that have proven to be an effective means of assisting siblings in these situations to manage their emotions.

TOR E: The costs associated with ECEI services, including costs in relation to initial diagnosis and testing for potential ECEI participants

Occupational therapists, by virtue of their skills in the field of functional assessment, are often called upon to write reports for clients seeking NDIS support. This work is fundamental to the determination of eligibility for the scheme yet it is not remunerated by government. Accordingly the occupational therapist must produce this assessment without payment or the potential NDIS participant must pay an out-of-pocket cost. This anomaly should be addressed by the NDIA.

OTA was recently advised that there is a great deal of inconsistency in terms of when reports are requested, despite the fact that it is generally acknowledged that reports prepared by occupational therapists form an integral part of the review and funding process.

The assessment process to determine eligibility for ECEI services is expensive for many families and is placing those who cannot afford assessments at a significant disadvantage. Some have suggested that a concrete diagnosis not be the key determinant of a child’s eligibility for funding. It is not uncommon for paediatricians and psychologists to adopt a ‘wait and see’ approach if they are unsure about a diagnosis but can clearly see that the child is in need of support. However, this is only appropriate if the child is assessed as needing support by a trained health care professional, rather than a Planner who does not have a health background.

Recommendation 9: Occupational therapists should be appropriately compensated for the time it takes to prepare reports for clients who are seeking funding through the NDIS. Additionally, greater clarity should be provided by the NDIA around when such reports may be required.

Recommendation 10: In exceptional cases, children who have not yet received a formal diagnosis should be able to access supports through the NDIS. However, this should only occur on the recommendation of a suitably qualified health care professional who can produce evidence in support of the child’s need for funding.

TOR H: The adequacy of information for potential ECEI participants and other stakeholders

There is an apparent lack of information for potential ECEI participants, providers and other stakeholders about the ECEI process. Members also report that information received is often inconsistent which means, of course, that some of it is incorrect.

It is difficult to find information on the NDIS website about:

 timeframes for the determination of a child’s eligibility for the NDIS;  the process of planning by EC Partners (and how long this might take);  how priority for planning is determined (there are cases of unsupported clients being of a lower priority than clients who have existing funding through the HCWA/Better Start programs);

 how conflicts of interest are supposed to be avoided or managed by those EC Partners who are also early intervention service providers);  participants’ choice and control with regard to the way their funding is held (e.g. agency managed, plan managed, self-managed, or a combination of these); and  participants’ choice around who to engage as an early intervention service provider once a plan has been developed (e.g. early intervention partner/service, private provider, not for profit organisation).

It would be beneficial for providers to be grouped by the age groups they service (0-6, 6-12, teenagers, adults) and the therapy services they offer (occupational therapy, speech pathology etc.). It has also been suggested that participants and their families be able to search for providers by suburb and Local Government Area. OTA notes that the NDIS website currently lists service providers by name and registration group (eg. Early Childhood Supports, Therapeutic Supports). The downloadable lists can be difficult to navigate given the large number of registered providers, particularly in larger states.

Our members have also reported that the provider section of the NDIS website can be difficult to navigate, as providers are required to sort through an abundance of information to find what they need (such as a particular set of guidelines). There is also a lack of user friendly information for prospective providers who are interested in learning more about the scheme. OTA believes that the NDIA should adopt a co-design approach to developing operational guidelines. Providers often have no input into these or any opportunity to submit feedback on whether what has been proposed will work in practice.

Some occupational therapists have reported that the registration process can be quite lengthy, which may deter some people from signing up as providers. As noted above, another issue is the fact that providers quite often receive no response to phone calls and emails from NDIA staff. This could present a barrier to entry for new providers who may wish to speak to someone or ask questions about the scheme.

Another issue is the lack of information given to therapy providers in areas where the NDIS has not yet rolled out. One occupational therapist who works at an early intervention centre in rural New South Wales expressed concern that they have been given no indication of the possible demand on their service. This therapist noted that they anticipate that demand for their service will grow rather suddenly as government-funded services are dismantled, however it may not be financially viable to provide services to clients with complex needs due to the amount of travel involved.

Recommendation 11: The NDIS website should be enhanced to make it easier for providers and participants to navigate. Email alerts should be sent when new documents/guidelines are added to the website and a notification should be added to the homepage.

TOR I: The accessibility of the ECEI Approach, including in rural and remote areas

However well-intentioned the NDIS, and however sincere its commitment to consumer choice, the fact remains that Australians living in rural and remote areas will continue to have limited access to healthcare and disability services. This, of course, is the product of our highly urbanised population and the attendant unevenness of the geographical distribution of our health and disability workforce.

OTA notes that, over time, this may be less of a consideration for occupational therapists as a growing number of regionally based universities are offering degrees in occupational therapy; evidence suggests that health professionals who study in a regional location are more likely to settle and work in there.

At the moment, however, members in rural and remote areas report that those children found to be eligible for services under the ECEI pathway are unlikely to have services to access. This is particularly true of the child with complex disabilities requiring the regular and integrated services of multiple health professionals. Some OTA members travel great distances to provide therapy to clients in rural centres but can only do so a few times a year, thereby providing an irregular service to children who should be seen much more often.

OTA members working in regional areas note that it is often difficult for families living in remote areas to travel into a regional centre to access clinical services. But these services report that it is often not financially viable for them to travel to these families. The NDIA must ensure that clients’ packages allow for service providers’ travel costs to be reimbursed. This is particularly so for occupational therapists, who should ideally work with clients in the environment in which they seek to function. In the case of children this is the home, and in the case of school aged children, the classroom and playground.

Indeed, in its National Guidelines to Best Practice in Early Childhood Intervention, Early Childhood

Intervention Australia (ECIA) identifies eight key best practices (page 7). The fourth best practice is Engaging the Child in Natural Environments and ECIA states that this:

promotes children’s inclusion through participation in daily routines, at home, in the community, and in early childhood settings. These natural learning environments contain many opportunities for all children to engage, participate, learn and practise skills, thus strengthening their sense of belonging.

OTA endorses this observation absolutely, and contends that this is the reason why occupational therapists must see their young clients in their natural environments. It is also why there must be greater clarity around, and more generous subsidies for, provider travel.

OTA understands that providers can claim travel time at an hourly rate for the relevant support item for travel in excess of 10km, up to a maximum annual limit of $1000 per participant (per annum).

Does this mean a participant has a maximum of $1000 per annum to offset the travel costs of a team of different providers or $1000 per annum per service provider? If the former, it is conceivable that one provider who sees the client multiple times within a short period may fully expend the funds available, leaving nothing for another provider who may need to consult with the client at a later date.

In discussions with ECIA, OTA has been advised that the travel allowance rises to $3,000 per annum as part of something known as the transdisciplinary key worker model. If this is indeed the case, it should be much more widely publicised given the centrality of travel costs to the delivery of effective clinical services to children living in rural and remote parts of Australia.

As indicated above, it is paramount, and also best practice, for functional assessments to be conducted in the participant’s environment. The potential for an occupational therapist, in particular, to have restricted access to a participant’s environment will restrict service provision and potentially compromise clinical outcomes.

It is deeply regrettable that the cost of travel is such that NDIS work is becoming unviable for some of our members, particularly those working in rural and remote areas.

It may be possible for ECEI service providers in rural and remote areas to use videoconferencing to communicate with clients and families, however this is contingent on improving Internet access in these areas.

Recommendation 12: Steps should be taken to improve the accessibility of the ECEI Approach in rural and remote areas, including greater use of videoconferencing to communicate with clients and families.

Recommendation 13: The NDIA should clarify whether the $1000 annual travel limit means that each participant has a maximum of $1000 per annum to offset the travel costs of a team of different providers, or if each service provider receives a maximum subsidy of $1000 per annum for each participant they work with.

TOR J: The principle of choice of ECEI providers

The NDIS ECEI Approach needs to demonstrate a genuine commitment to the principle of choice because so few Australian families can afford to exercise choice without financial support. Medicare offers only partial reimbursement for clinical services, while private health insurance funds also reimburse only a portion of costs incurred and have an annual limit on consultations that is exceeded in a few sessions.

Given this reality, families requiring ECEI services are at the mercy of government. And at the moment, government’s effectiveness at delivering choice to vulnerable families varies widely from jurisdiction to jurisdiction.

It has become apparent to some OTA members that many of the NDIA’s EC Partners are established services with long established relationships with therapy providers. These particular providers have retained a de facto “preferred provider” status under the new arrangements and accordingly receive the bulk of referrals from these EC partner organisations. This runs counter to the principle of consumer choice that supposedly underpins the NDIS.

Reports from OTA members suggest that this problem exists, to a greater or lesser extent, across several jurisdictions. The potential for this problem exists across all jurisdictions.

Of even greater concern is the situation where a partner organisation also provides therapy services or employs therapy providers, and directs clients to these services. This amounts to a clear conflict of interest and should not be allowed. This problem is most pronounced in New South Wales and is the product of the bilateral agreements around the NDIS arrived at by the Commonwealth and New South Wales governments. There have been reports of families feeling pressured to use the services of EC Partners who are also service providers. This could pose problems for clients who are already receiving a service that they are satisfied with, but may be pressured to change to the service provided by the partner organisation. One client apparently had to make it very clear that they wished to continue receiving services from their current provider.

An OTA member working in New South Wales notes the potential for EC Partners to maintain a monopoly of early intervention services, to the detriment of participant choice. This may have significant implications, with a reduction in broader early intervention services because other providers are unable to compete with the EC Partner. Expanding, or at the very least maintaining, choice for participants is crucial in regional and rural areas, where there are already limited options due to a shortage of therapists.

It appears that these existing services, which previously received block funding under the state’s Ageing, Disability and Home Care (ADHC) program, were chosen by the NSW Government as part of the bilateral agreements with the Commonwealth Government, without a tender process having occurred. There is an inherent – and entirely foreseeable – conflict of interest when a service provider is also conducting the planning process with families. They are the first point of contact for vulnerable families and at no point in the subsequent process is there a mechanism to address an obvious conflict of interest.

One occupational therapist in New South Wales writes:

The NSW government has implemented the ECEI Approach across NSW in line with the NDIS rollout. Whilst our local ECEI provider is yet to be announced there are limited options as to who the provider will be. As the provider must have previously been receiving ADHC block funding to provide early intervention services. Our business is already starting to feel the impact of the ECEI Approach. After speaking with other small private providers across the state the concerns are similar.

This same provider notes that it is at the discretion of EC Partners who receives an NDIS plan and who will receive ‘soft therapy’. ‘Soft therapy’ is typically provided to those with mild disability and it

is provided by the ECEI provider, who will continue to receive block government funding. These children will have no choice of provider and the type of intervention provided.

Of particular concern is the subtlety with which some conflicted EC Partners endeavour to circumvent the perception of conflict. OTA has seen emails in which EC Partners propose a detailed package involving services they offer and then add a line at the end of the email noting the client is free to choose other NDIA registered therapists. The effect of such careful packaging is to imply the EC Partner is the default provider and only if the package is unacceptable should they seek alternative providers. Some families report that at no time were they provided with a list of NDIS registered providers or even alerted to the fact that other providers existed. These families seemed unaware of their right to request a plan manager, financial intermediary or to self-manage.

One OTA member writes:

We have had families come back to our service after planning meetings informing us that the ECEI provider had told the family that they will manage and provide all of the therapy services… This is a significant concern as there are a number of families that are not aware of their choice and as a result have left our services because they have been told they have to and do not want to upset the ECEI provider as they are the ones that organise the NDIS plans which in turn has a significant impact on their child’s life.

It appears that even those parents who are aware of their rights are often reluctant to take issue with the EC Partner as they don’t wish to alienate the people responsible for their child’s wellbeing.

Such self-interested conduct on the part of some EC Partners is unworthy of a disability scheme that is supposed to represent a bold new venture in client directed care and informed choice. That children with disability aged under six should be the object of such conduct is reprehensible and a matter that should be urgently addressed by the Commonwealth and NSW governments.

Concerns about a possible conflict of interest have also been raised by therapists in South Australia. One member noted that they had a client whose three year old child was eligible for the NDIS, however a Planner was unable to meet with them for several months. The family was subsequently offered early intervention services by an EC Partner with no fee charged (evidently because the Partner was pre-paid). This particular family wished to continue accessing services through their current provider, however they felt forced to take up the EC Partner’s offer because the services were more affordable. The EC Partner later confirmed that early intervention services were being provided to a number of clients because NDIS funding for new plans had been fully expended.

The member who provided this example noted that NDIS Planners do not refer families to particular providers. Rather, it is up to families to choose their child’s provider/s, with the exception of EC Partners. NDIS Planners can and do refer families to EC Partners, even when this means withdrawing the child from their current therapy services.

OTA believes participants should be made aware of all appropriately qualified service providers within a designated distance of their residence (and clearly this distance would vary between

metropolitan, regional and rural locations). Above all, they should be thoroughly acquainted with their right to choose the manner in which their child’s package is managed and the service providers who deliver care and therapy as part of that package.

OTA believes that any list of local providers that is given to families should include providers that are not NDIS-registered but can provide services if the family chooses to self-manage their funding. The list needs to be specific to the child’s needs rather than detailing every type of service in the area, and should also include a summary of what each service is able to provide.

Additionally, families should be encouraged to explore their options and request quotes from a number of service providers. They should also be advised that a quote is not only about cost but also the suitability of the service provided. It has been suggested that the NDIA keep records of all participants who developed their plan with an EC Partner and monitor what services they have accessed. In cases where participants do not branch out to other organisations, they Agency should investigate whether this is because of a lack of awareness of alternative options. It may be viable to provide families with questionnaires in order to elicit feedback about their experience with the EC Partner and their knowledge of other service providers (small private practices).

Of particular concern is the sidelining of sole providers in the new arrangements, particularly in New South Wales. Even providers with immense experience in the delivery of care to children and who meet NDIS ECEI Approach guidelines are currently excluded from the scheme. There are cases of services that once qualified for HCWA funding that are yet to be recognised as a provider by the NDIA. This limits clients’ choice and threatens the viability of services through no fault of their own.

One occupational therapist with 25 years’ experience working in early intervention, and who studied RDI (Relationship Development Intervention) overseas to enhance their capacity to work with children with autism, writes:

To have the flexibility to do the training and use it, I needed to start my own private practice. My practice tends to attract families who have a child with autism and they have funding, which I am grateful for. I would not have established a private practice if only wealthy families could access my service. I am passionate about providing guidance to parents that can make a significant difference to the whole family’s quality of life and that gives parents the opportunity to make their day to day engagements in ordinary activities meaningful and therapeutic for their child…

… My service is cost effective because I aim to train the parents to use the time they have with their children to best advantage and I pass on my knowledge so that they don’t need to continue working with a consultant…

… The approach that NDIA has set up for Early Childhood Early Intervention affects my service drastically. My caseload and income has suddenly halved. That is drastic for a small business and came by stealth… The way NDIS is approaching ECEI at present is a waste of the expertise of private therapists and means families don’t have the choice they were promised…

… Some of the families I have been working with who had FaHCSIA funding have run out of funding or their child has turned 7. They are stalled, waiting in line for NDIS to provide funding. There are no more families with a child with a new diagnosis contacting me because they have to go through the large Early Childhood Partner NGOs.

And once they start with a service, even if NDIS includes private practitioners as service providers in the future, most families will stay with what they know.

This last comment is significant. While arrangements in New South Wales are transitional, with the NDIA to run a competitive sourcing process for longer term ECEI arrangements that are to take effect from 1 July 2018, many clinical relationships will have been established by that date and these will most likely continue. Providers currently excluded from ECEI work will therefore remain at a disadvantage beyond July 2018, assuming their practices survive until then.

Moreover, can the NDIA guarantee that a system of “de facto” preferred providers mentioned above will not be the outcome of the sourcing process? Will the process source partners and providers, or just partners? And if the latter, will these partners be allowed to provide clinical services? If not, will they still be free to nominate preferred providers?

These are fundamental questions which will test the NDIA’s commitment to the principle of consumer choice.

It will be a tragedy if the NDIS ECEI Approach is remembered for having broken up longstanding and highly effective relationships between providers and clients. Nor will this sit well with the supposedly overriding principle of client choice.

Concerns have also been raised about the lack of choice for families in the ACT, given that there is only one Early Childhood Partner (EACH). An OTA member working in the ACT expressed concern about the process for clients to be referred to their service. They were advised by EACH that there is an initial triage of need and the child may receive assessments by a speech pathologist, physiotherapist or psychologist as required. The therapist was advised that occupational therapists would be called in to conduct assessments if needed. It is therefore assumed that the same applies to other allied health professionals (such as orthoptists), however this has not been confirmed. At this point children may be referred to other services, however there is no information on what these services will be as this will depend on the child’s individual needs.

It is unclear if this assessment process is the same across other EC Partners. This therapist also noted that there is a lack of clarity around the referral process; specifically the timeframe for referrals by the EC Partner to other services. They received conflicting messages around the length of time that children will receive initial therapy support provided by each – the therapist was initially told that this would be for 6-12 weeks, however were subsequently advised that this could be longer depending on the child’s needs.

The fact that screening services by occupational therapists will occur on an as-needs basis is particularly concerning, as it highlights the fact that each EC Partner can only screen/review/provide services in line with their skillset, staffing, scope and strengths. This will inevitably lead to inconsistencies in the quality of early childhood services across the country.

Recommendation 14: The NDIA should prioritise the implementation of appropriate safeguards to prevent EC Partners that are also registered NDIS service providers from automatically referring families to their own services. Any cases of partner organisations repeatedly encouraging families to access services provided by their own organisation should be thoroughly investigated.

Recommendation 15: The situation in New South Wales, whereby organisations that were previously block funded by Ageing, Disability and Home Care (ADHC) have been selected as EC Partners, should be closely monitored to assess the impact of this arrangement on private practices. If a decision is made for private practitioners to continue to be excluded from providing ECEI services until at least July 2018, a fair and transparent competitive sourcing process should be initiated to prevent current ECEI providers from automatically being selected as preferred providers from 1 July 2018 onwards.

Recommendation 16: NDIS participants should be made aware of all appropriately qualified service providers within a designated distance of their residence. Any list of local providers that is given to families should include providers that are not NDIS-registered but can provide services if the family chooses to self-manage their funding. Above all, families should be informed of their right to exercise choice and control over their child’s funding package, and should be encouraged to explore their options and request quotes from a number of service providers.

TOR 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

OTA is concerned that although the NDIS is intended to promote best practice interventions in line with current research and innovation in the disability sector, many services do not reflect this philosophy. This is particularly evident in regards to services for people with autism.

Currently, there is a heavy bias towards Applied Behaviour Analysis (ABA) in the provision of autism services. However, this behavioural approach is not supported by current research. Large organisations that advocate for and market ABA exert a great deal of influence over what is offered and what paediatricians, hospitals, schools and families are aware of.

Research instead suggests that a relational, developmental approach to autism treatment, which places parents at the centre, is more beneficial. It has also been suggested that providers need to shift from a skills-based, static style of service provision, to a dynamic, guiding, relationship-based approach that requires appropriate training to implement.

Recommendation 17: Consideration should be given to broadening the types of interventions that are promoted as best practice for people with autism, as research suggests that a relational, developmental approach to autism treatment is more beneficial.

Other related matters

Referrals

Provision needs to be made for the appropriate training of EC Partners (and NDIA Planners) to ensure their awareness, and greater understanding, of the types of services offered by allied health professionals. OTA is well placed to contribute to the development and delivery of such training.

Also of concern is the fact that many general practitioners and most schoolteachers are unaware of what ECEI is and the services it can provide. This is why some OTA members report that the bulk of their clients come from families who have heard about paediatric occupational therapy from other families and have approached service providers privately, rather than using NDIA referral channels. This is an additional burden for families already at risk and suggests many children that could be assisted by ECEI are missing out.

Dismantling existing services OTA members have noted with concern that while funding has been withdrawn from existing services to fund the NDIS, the NDIS may not replace those services because its eligibility requirements are much tighter.

The NDIS will not be providing “health” and “educational” services, but these are very grey areas where children with developmental delay and unclear diagnoses are concerned. Many of these children may not be eligible for the NDIS after they turn six years of age but, with the funding for alternative services virtually gone, they will be left without any supports. There is no clear pathway yet for these children.

While the ECEI part of the NDIS is in theory very good, with clear and commendable expectations of providers, in many cases it is replacing systems of proven excellence employing the services of a range of outstanding individual providers.

In Tasmania, for example, an excellent Early Childhood Intervention Service has been provided for children 0 – school age, with help for schools and families in transition to school. Our members report that this is an exemplary service, with one saying it is the best she has worked in. It brings together teachers, occupational therapists, physiotherapists and speech pathologists in a comprehensive developmental program which addresses a given student’s language and communication needs, movement needs, self-care need, sensory need and cognitive developmental needs. This is all provided in a play based setting, either in a group, individual session or through home visits, whichever best meets the needs of the parents. However, because the provider has been the Tasmanian Education Department, this service will be ineligible for support under the NDIS. Individual providers cannot hope to meet the comprehensive nature of this service and, given the

NDIS’ preoccupation with individualised packages, it is unlikely that this successful model will ever be replicated again. This is a tragedy for the children concerned and their families.

One Tasmanian OTA member also perceives a potential conflict of interest as a result of the dismantling of a service:

As a result [of reforms] St Giles children’s services here in Tasmania claim to have lost much of their public funding and have virtually morphed into a private practice, leaving little ability to refer children for services, such as OT Physio and Speech Therapy. Waiting lists are enormous, and many children are offered private services using their funding, such as Better Start and HWCA rather than the public service. There is an obvious conflict of interest when the main publicly funded service is also a private provider.

Another occupational therapist in Tasmania raised the following concerns with regards to direct referrals to St Giles from the NDIS:

This practice provides an unfair/unequal financial advantage to a single private provider.
St Giles is based in Launceston which is 100km from Devonport and 150km from Burnie. This means that children will have to either travel or be charged by St Giles to complete home visits. There are now two private paediatric OT clinics on the north west coast that could reduce this travel time significantly.
That by direct referral to St Giles families are denied the opportunity to choice-a core value underpinning NDIS philosophy (as I understand it to be).
That children who have established relationships with small local providers will be negatively impacted and therapeutic process severely interrupted if they are forced to change providers.

An occupational therapist working in a year 2 site in New South Wales is concerned that while HCWA/Better Start funding has ceased abruptly, children that have been newly diagnosed are unlikely to have access to NDIS funding until 2018, which is a significant gap in support during a crucial period for early intervention.

This provider writes:

It was recently announced that due to the collateral agreement between the NDIA and the NSW Government, they had not allocated enough funding to accommodate the unidentified new clients that would be accessing the scheme and, as a result, children aged between 0-6 that have not been previously been identified as having a disability by ADHC or an ADHC funded service provider will not be able to receive a plan until the collateral agreement ends in July 2018. This is a significant amount of time that children will be waiting to receive the services they deserve. Whilst they will be able to receive some ‘soft therapy’ from the ECEI provider they are unlikely to receive the level of support they need. Research shows that early intervention to this population is extremely important in decreasing the long term impacts of delay or disability on a person’s function.

This was a recurring theme in submissions OTA received from its members. Occupational therapists working with children are deeply concerned about the dismantling of existing services, or the gaping grey areas between existing services and NDIS services that are yet to be rolled out, because this population cohort is so vulnerable. The families involved are new to the world of disability and the associated therapeutic supports. Evidence based research demonstrates that best practice is early intervention to decrease the long term functional impacts of disability. While this is supposedly a foundational principle of the NDIS and its ECEI Approach, there is a disconnect between theory and reality which must adversely impact these children and their families. This gap is also having a negative impact on the viability of local private practices that have to date provided therapeutic services of a consistently high quality to young children under the auspices of programs run by the Department of Social Services (DSS) or state and territory government agencies.

Unqualified workers Members in Tasmania have expressed concern that the NDIS has partnered with Baptcare and Mission Australia in the delivery of ECEI services in that state and that these organisations are employing childcare workers, with no qualifications or experience in disability, to undertake assessments.

These unqualified workers will be responsible for working with parents to prescribe the required treatment, rehabilitation, and therapy services for young children with a broad range of developmental delays. This is far from best practice, and therefore an extremely disappointing model.

At a time when families are coming to grips with a life-changing diagnosis, or are facing the uncertainty of a child exhibiting developmental delays but with no clear diagnosis, they need very sensitive support from highly experienced professionals. Many families will be in a state of denial, making engagement with the NDIS even more problematic. Childcare workers with no expertise in disability are simply unable to offer the necessary support and guidance.

Allied health assistants An occupational therapist in the ACT reported that they are observing a trend whereby allied health assistants (AHAs) are being employed to conduct therapy sessions at a cheaper rate in order to extend clients’ plans. OTA acknowledges the important role of AHAs but notes the need for appropriate supervision, clear lines of delegation, core training, and identification of key tasks that AHAs can appropriately conduct. Our position statement on the role of AHAs in supporting occupational therapy practice is available from http://www.otaus.com.au/sitebuilder/advocacy/knowledge/asset/files/21/positionpaper-theroleofahasinsupportingoccupationaltherapypractice%5Boctober2015%5D.pdf.

Assistive technology OTA members are frustrated by their inability to prescribe low risk equipment for participants as part of the ECEI service. This is a significant problem for families requiring fine motor, gross motor, adaptive and social (play) equipment and sensory supports.

Members from across the country have also expressed concern about the uncertainty surrounding the delivery of assistive technology as part of NDIS packages. Before the introduction of the NDIS some jurisdictions allowed one AT provider to have a monopoly on the provision of goods to people with disability who were receiving government support. Under new arrangements it appears that in some jurisdictions these same providers will have, if not a monopoly, a preferred provider status.

It is imperative that, consistent with the overriding principle of client choice, NDIS Planners, EC Partners and, above all, participants be thoroughly acquainted with the breadth of AT providers available to deliver goods in a genuinely free and fair marketplace. This awareness, and the competitiveness it breeds, will ensure lower AT prices and, it follows, NDIS packages that make the participant’s dollar go further.

Indigenous children Occupational therapists in the Northern Territory report that the Ages and Stages Questionnaire (ASQ) has been used in remote Indigenous communities to determine a child’s eligibility for ECEI services. The ASQ, however, is a screening instrument and not a diagnostic tool, and the NDIA Planners using it do not have the clinical reasoning skills to interpret results.

Our members report that this problem gives rise to inconsistency around eligibility criteria and frustrating difficulties accessing feedback from Planners when these inconsistencies are questioned.

Non-attendance

Service providers are financially disadvantaged by clients who fail to keep appointments. While there have been recent adjustments to arrangements which partially compensate providers for non attendance, this remains a significant problem, particularly for those providers working in private practice in low income areas or poorly resourced areas where limited transport options, poor housing and poor health are additional complicating factors. If providers are unable to make a reliable income they will leave the sector, further reducing services for already vulnerable families. Anecdotal evidence suggests this uncertainty is already deterring some younger occupational therapists from practising in the disability sector generally, and in lower socio-economic status areas specifically.

Once again, this is a problem with more acute implications for those families in regional, rural and remote areas of the country.

Summary of recommendations

including occupational therapists, should be consulted throughout the process of developing or refining training material.  Appropriate safeguards should be implemented to prevent Early Childhood Partners from having excessive influence over what supports are included in a child’s plan, particularly when the EC Partner is also a registered NDIS service provider.  Generic templates intended to guide the development of plans for children should be used at a minimum in order to ensure that each child receives individualised supports that are tailored to their particular needs.  Factors contributing to long waiting times to access early childhood supports should be identified and addressed as a matter of urgency by the NDIA.  The NDIS Price Guide should be modified to reflect the costs of providing peer therapy to children with developmental disabilities who are transitioning from individual to group therapy.  The support needs of siblings of children with disability should be prioritised in the treatment plans of children with disability. The NDIS should fund sibling support groups that have proven to be an effective means of assisting siblings in these situations to manage their emotions.  Occupational therapists should be appropriately compensated for the time it takes to prepare reports for clients who are seeking funding through the NDIS. Additionally, greater clarity should be provided by the NDIA around when such reports may be required.  In exceptional cases, children who have not yet received a formal diagnosis should be able to access supports through the NDIS. However, this should only occur on the recommendation of a suitably qualified health care professional who can produce evidence in support of the child’s need for funding.  The NDIS website should be enhanced to make it easier for providers and participants to navigate. Email alerts should be sent when new documents/guidelines are added to the website and a notification should be added to the homepage.  Steps should be taken to improve the accessibility of the ECEI Approach in rural and remote areas, including greater use of videoconferencing to communicate with clients and families.  The NDIA should clarify whether the $1000 annual travel limit means that each participant has a maximum of $1000 per annum to offset the travel costs of a team of different providers, or if each service provider receives a maximum subsidy of $1000 for each participant they work with.  The NDIA should prioritise the implementation of appropriate safeguards to prevent EC Partners that are also registered NDIS service providers from automatically referring families to their own services. Any cases of partner organisations repeatedly encouraging families to access services provided by their own organisation should be thoroughly investigated.  The situation in New South Wales, whereby organisations that were previously block funded by Ageing, Disability and Home Care (ADHC) have been selected as EC Partners, should be closely monitored to assess the impact of this arrangement on private practices.  NDIS participants should be made aware of all appropriately qualified service providers within a designated distance of their residence. Any list of local providers that is given to families should include providers that are not NDIS-registered but can provide services if the family chooses to self-manage their funding.

 Consideration should be given to broadening the types of interventions that are promoted as best practice for people with autism, as research suggests that a relational, developmental approach to autism treatment is more beneficial.

Conclusion

Whilst the NDIS Early Childhood Early Intervention Approach is supposed to deliver greater choice and peace of mind to the families of children with a disability, flaws in the scheme’s design and operational shortcomings are having quite the opposite effect.

The constant failure of NDIA personnel to return telephone calls or even acknowledge emails renders the scheme all but unworkable for many participants and providers. This failure of communication is compromising the very purpose of the ECEI Approach – to identify and help vulnerable children at the earliest possible moment. Until this problem is addressed, discussion of the scheme’s other problems is rather academic.

The NDIS website needs to be much more user-friendly, for both participants and providers.

Flying in the face of the principle of greater choice is governments’ decision to allow EC Partners to also be service providers. In too many cases, ECEI packages are being prepared by a partner organisation in which clinical services are to be delivered by that very same organisation or its preferred providers. These are being presented to families as a fait accompli at a time when families are still coming to terms with the reality of a disability diagnosis and are understandably reluctant to take issue with the organisation responsible for their child’s wellbeing. Such conflict of interest has no place in a disability scheme predicated on the principle of client choice. Moreover, such protectionism is having an immediate and detrimental impact on practitioners who have done great work in the disability sector for many years. As these services struggle to remain viable, the flow-on effect will be borne by disabled children and their families.

In order to help long established practitioners remain viable, the NDIS ECEI Approach should ensure that no qualified provider is excluded from delivering services. This should be an immediate priority, not an undertaking to take effect after a transitional period. Too many providers face immediate financial difficulties.

OTA observes with great concern the haste with which longstanding services of proven effectiveness are being dismantled by state and territory governments which seem to hope that disability services are no longer their responsibility. This is not the case and leaves many people without the support they once had and unsure of their eligibility for NDIS services which may or may not have been rolled out. Further, many practitioners who once delivered services under the auspices of state and territory government programs, or as part of the HCWA and Better Start programs, now find themselves excluded from NDIS packages and facing financial ruin. At a time when doubts exist as to the adequacy of the disability workforce, how can the NDIA countenance arrangements that threaten the viability of experienced service providers? The NDIS, and in particular its ECEI

Approach, should aim to match the right providers to the right client. It should not be a money making vehicle for corporate, and often conflicted, practices.

Paediatric occupational therapists are trained to assess and then enhance the functionality of children. This core skill is fundamental to the success of any early intervention service. Given that occupational therapists work in a variety of capacities – as sole providers, in multi-disciplinary private practices, as part of NGOs – it is imperative that the NDIS ECEI Approach recognise and accommodate all such providers. To do otherwise is to exclude highly trained professionals at the very time there are doubts about the adequacy of workforce numbers. The ECEI Approach should also ensure the viability of these providers, by recognising the costs of delivering services and ensuring these are offset by appropriate remuneration.

Occupational Therapy Australia thanks the Joint Standing Committee on the National Disability

Insurance Scheme for the opportunity to make this submission and would be happy to elaborate on the concerns we have raised.