Submission 66 — ACT Government — Provision of services under the NDIS Early Childhood Early Intervention Approach

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JOINT STANDING

COMMITTEE ON THE

NDIS

PROVISION OF SERVICES UNDER THE NDIS EARLY

CHILDHOOD

EARLY INTERVENTION APPROACH

COMMUNITY SERVICES

DIRECTORATE

AUGUST 2017

Directorate, Office for Disability. 1

CONTENT

INTRODUCTION …………………………………………………………….. 3

REPONSES TO TERMS OF REFERENCE ………………………………. 3

A) THE ELIGIBILITY CRITERIA FOR DETERMINING ACCESS TO THE ECEI PATHWAY ……… 5 B) THE SERVICE NEEDS OF NDIS PARTICIPANTS RECEIVING SUPPORT UNDER THE ECEI PATHWAY ……………………………………………………………………………………………………… 7

C) THE TIMEFRAME IN RECEIVING SERVICES UNDER THE ECEI PATHWAY ………………… 7 D) THE ADEQUACY OF FUNDING FOR SERVICES UNDER THE ECEI PATHWAY …………….. 9 E) THE COSTS ASSOCIATED WITH ECEI SERVICES, INCLUDING COSTS IN RELATION TO

INITIAL DIAGNOSIS AND TESTING FOR POTENTIAL ECEI PARTICIPANTS ………………. 10

F) THE EVIDENCE OF THE EFFECTIVENESS OF THE ECEI APPROACH ……………………….. 11 G) THE ROBUSTNESS OF THE DATA REQUIRED TO IDENTIFY AND DELIVER SERVICES TO PARTICIPANTS UNDER THE ECEI …………………………………………………………………….. 12

H) THE ADEQUACY OF INFORMATION FOR POTENTIAL ECEI PARTICIPANTS AND OTHER STAKEHOLDERS ……………………………………………………………………………………………. 12

I) THE ACCESSIBILITY OF THE ECEI APPROACH, INCLUDING IN RURAL AND REMOTE AREAS …………………………………………………………………………………………………………. 13

J) THE PRINCIPLE OF CHOICE OF ECEI PROVIDERS ……………………………………………….. 14 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 ………………………………………………………………………….. 15

L) ANY OTHER RELATED MATTERS …………………………………………………………………….. 15 Directorate, Office for Disability. 2

INTRODUCTION

The ACT commenced preparation for implementation of the NDIS in October 2012. In the

last three years the ACT landscape for the provision of Early Childhood Early Intervention

services has changed significantly. In April 2014 the ACT Chief Minister announced the

phased withdrawal of ACT Government from provision of disability services including

therapy and early intervention (EI) services. During 2015, therapy and EI services

transitioned to the non-government sector. At the same time the ACT Government

established the ACT Child Development Service (CDS) as a mainstream service to ensure

continuity of support for children who may not be eligible to participate in the NDIS. The ACT

Government retains a focus on supporting NDIS participants through all stages of the

transition.

CDS became operational in January 2016, utilising co-located medical and allied health staff

to provide a seamless service for young children and their families. These services include

assessment and referral for children aged 0-6 years, as well as autism assessment for

children up to 12 years of age. CDS promotes appropriate referral pathways, and prior to the

commencement of the ECEI Partner in the ACT, has played an important role in referring to

the NDIS and other mainstream services. CDS has continued to maintain a focus on

assessment and referral, including providing information and advice to families of children

aged 0-6 at risk of developmental delay.

The National Disability Insurance Agency (NDIA) launched its Early Childhood Early

Intervention (ECEI) approach in February 2016, with the contracted ECEI partner for the ACT,

Victorian NGO EACH, announced in March 2017. In early May 2017 the ECEI partner EACH

commenced the stand up of its service in the ACT, co-located with the CDS in Holder. EACH

recently commenced working with families.

The ECEI partner is the first point of contact for a family with a child who has a

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developmental delay. The ECEI partner will work with the family to determine if the child’s

developmental delays meet thresholds for eligibility to the Scheme. A recommendation to

the NDIA for eligibility to the Scheme will be made by the ECEI partner where there is

sufficient evidence that the child’s delay is having a significant functional impact in a number

of areas and the young person would benefit from funded supports. The ECEI partner will

refer and link families to mainstream services and may also provide short term intervention

and support for children who don’t meet the NDIA EI eligibility criteria but who would still

benefit from short term supports outside of access to the Scheme. The ECEI partner will also

provide interim supports for children who are waiting for access to the Scheme.

The ACT retains its commitment to the important role early assessment has in effective early

intervention strategies. The Community Services Directorate will continue to monitor any

potential overlap of services between CDS and the ECEI provider as it matures its operations,

acknowledging the agreed role of the Commonwealth in this area of provision.

The co-location of the ECEI partner with the CDS creates a rich opportunity to enhance the

support to children and their families, though this is yet to be fully utilised mainly due to

early operational and logistical matters currently being addressed. Streamlined pathways

recently commenced with the provision of ‘warm referrals’ for vulnerable families. CDS

continues to provide support to families during transition, and advice in relation to EI

referral pathways.

The ACT has raised concerns with the NDIA over several months regarding the high number

of children in the NDIS, as well as poorly communicated changes to ECEI eligibility through

the NDIA’s operational guidelines on access and early intervention requirements. Even with

the regular raising of matters with the NDIA, the systemic challenges the ACT Government,

participants and providers experience remain current and of significant concern.

The ACT Government welcomes the opportunity to input into the Committee’s inquiry with

the view to strengthen the early childhood early intervention services for young children and

their families.

Directorate, Office for Disability. 4

REPONSES TO TERMS OF REFERENCE

A) THE ELIGIBILITY CRITERIA FOR DETERMINING ACCESS TO THE ECEI PATHWAY EI services funded and provided by the ACT were based on a clear delineation of

responsibility as set out in the NDIA’s Operational Guidelines. The Guidelines state that

children with delays in one or more developmental areas are eligible for an EI package.

Children with delays of more than twelve months in one area of development (for example,

significantly delayed communication) are eligible for a package of targeted therapy.

Many children previously provided with services through Therapy ACT received packages for

one area of significant delay when the NDIS commenced. However, in late 2016 the NDIA

changed the operational guidelines relating to eligibility to the Scheme for developmental

delay: specifically, the ’need for a combination and sequence of special interdisciplinary or

generic care, treatment or other services that are of extended duration and are individually

planned and coordinated’. This change is being interpreted to mean children with only one

area of delayed development are not eligible. As a result, the NDIA access team deems

children with one area of delay not eligible for the Scheme because they do not require

interdisciplinary care and these children are no longer receiving (or renewing) packages or

early intervention supports. In the absence of an ECEI partner until May this year, this has

pushed the cost back on the ACT funded services to provide further evidence of need or to

provide therapy supports.

CDS has found that providing evidence of functional impact in two areas of delay is more

likely to support eligibility to the Scheme. Examples of children not deemed eligible for the

NDIS since the new guidelines were implemented and prior to the commencement of the

ECEI approach are detailed below.

Case Study One: Three year old girl with family history of Autism

A three year old girl has a strong family history of Autism Spectrum Disorder and learning

difficulties. The child has severely delayed expressive and receptive language, but due to

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being so young formal assessments do not capture this very well. For example, the Clinical

Evaluation of Language Fundamentals Preschool showed only a moderate delay when her

scores were scaled, even though she could not complete any of the tests. As she did not

have concerns in other areas of development, she was not deemed eligible for the Scheme

or for early intervention supports.

Case Study Two: Two and a half year old boys with delayed language skills

Two boys aged two to two and a half years are attending a CDS language group. After five

sessions of language stimulation they have made no progress. They continue to have zero

words and poor play skills. These children require Augmentative & Alternative

Communications (AAC)/visual supports before learning language. To implement this they

require longer term intervention. However as they have only one area of concern they are

not currently eligible for the NDIS.

Overall, responses to eligibility for EI and developmental delay from the national access

team have been variable, with some clients referred by CDS being told that they are not

eligible for the NDIS and either sent back to CDS or referred to the NDIA portal to find the

new ECEI partner, which at that stage was not established in the ACT. Families are reliant on

the skills and knowledge of assessors to assist them in understanding the assessments, and

the functional impact of developmental delays and disability on their children. Families also

report they find completing the necessary initial documentation difficult.

In the early years of life, development is rapid and delayed access to appropriate

interventions has a far greater impact on the child’s long term trajectory than may be the

case in later years. Access to appropriate assessments and interventions needs to be

smooth.

Children coming to the end of their package at age 7 are often in difficulty because they are

not NDIS-eligible but have ongoing functional difficulties and need continuing support. These

children potentially ‘fall through the gaps’ as most cannot afford private providers.

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There is an acknowledged gap in the area of paediatric rehabilitation for children whose

condition is still stabilising. NDIS will only fund services when there is ‘permanent and

ongoing disability’ that is stable. This restriction in eligibility means for children who may, for

example, be post accident or post surgery and who will not have an ongoing disability

cannot access services through NDIS. This gap is currently being met in the ACT on an

individually brokered response, funded by ACT Health.

B) THE SERVICE NEEDS OF NDIS PARTICIPANTS RECEIVING SUPPORT UNDER THE ECEI

PATHWAY

It is difficult to comment on scope of service needs being given with the limited clarity on

what NDIA have asked the ECEI partner to provide. It is unclear what evidence base is

utilised by the NDIA in determining, for example, how many sessions a child diagnosed with

ASD level 1 receives, or the extra family supports put in place. There is potential risk for

families not receiving the level of specialised support needed early after diagnosis when it is

not only needed, but can have the most impact. The NDIA has not given assurances to the

ACT on the level and targeted specialised support that will be provided to families with a

child diagnosed with ASD level 1.

Also unclear are what measures the NDIA will use to determine effectiveness of the sessions

delivered, not only for the child but in capacity building for families and the interface with

Information, Linkages and Capacity building (ILC) in the ACT.

A strong evidence base exists for the benefits of early identification and intervention for

children with disability and developmental delay. We know that the earlier a child is

identified as having a developmental delay or disability, the increased likelihood they will

benefit from targeted strategies to meet their needs. It is important to recognise that not

only does successful early intervention assist families through the provision of support for

their child, it decreases the longer term costs to schools and communities as children move

through to their schooling years.

Directorate, Office for Disability. 7

Following ACT Government withdrawal from school readiness early intervention services at

the end of 2014, anecdotal feedback suggests there are young children requiring early

intervention that are not getting the right supports or not connecting with providers.

Providers have indicated the challenges and barriers faced in accessing inclusion support

funding which impacts on their ability to provide the required number of staffing support to

care for families enrolling children with additional needs. To assure safety and quality of care

for enrolled children, this can result in services turning families away or delaying access to a

program. In some instances where children who require one-on-one support for the entirety

of a School Age Care (SAC) session, services have covered the cost of the additional educator

required, demonstrating that the NDIS funding may have little impact on funding for children

to attend SAC programs.

The development of the service sector is in some cases not keeping up with demand. This

inability to meet some demands results in delays in accessing services for an age group

where timing of intervention is critical in order to prevent lifelong disadvantage.

Additionally, parents report finding it difficult to navigate access to the ECEI pathway; they

are given a package but need guidance on how to use the package and the services which

would be best for their children.

The providers who take a “key worker” approach may, in some cases, not be serving the

family appropriately. The Community Paediatric and Child Health Service has experience of

children with severe language delay having an Occupational Therapist visit under the “key

worker” model to provide speech development exercises to the parent – not direct speech

therapy to the child.

The ACT Government welcomes the opportunity to work with the NDIA and the ECEI partner

to ensure that children aged 0-6 years requiring early intervention are effectively identified

and supported, and have maximised their opportunity for development prior to starting

school. This includes ensuring effective connections are established between the ECEI

partners and mainstream service providers such as schools, but in particular ensuring

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stronger and more effective connections are established with early childhood education and

care providers.

At a broader level, there is also a lack of clarity to reconcile instances where children may be

diagnosed, or a diagnosis may be attempted to obtain funding for an Inclusion Support

Package under Family Assistance Law, which is administered by the Commonwealth

Department of Education and Training, but may not align with the status under an NDIS

process. It may also be in the best interests of children with disabilities, or under diagnosis

for disability, to align any Inclusion Support for a child with needs identified under the NDIS

process.

C) THE TIMEFRAME IN RECEIVING SERVICES UNDER THE ECEI PATHWAY A delay in the NDIA ECEI service partner tender process and set up of the service has

resulted in families not receiving services as soon as the ACT expected. This delay has also

increased exposure of the ACT Government in continuing support and service provision until

such time as the NDIA had the partner in place. The NDIA’s communication to families and

stakeholders was also delayed, resulting in some confusion regarding early intervention

supports for children with developmental delays in the ACT.

Timeframes for access have also been impacted by the need to triage clients, and as the

partner has only recently commenced ECEI services, it is unclear what the EI partner’s

capacity is to be responsive to the needs of children and families at risk is. This may be

crucial, for example, when a child with aspiration risks requires the family to receive timely

support to meet the feeding and positioning needs of the child, rather than being assigned

to a wait list.

Parents report delays in accessing services, both in accessing the Planning Meeting and there

are then further delays until services actually commence. It is not uncommon for delays of

greater than 6 months to be experienced to the point of commencing therapy. Again, this is

a significant delay at what is normally a time of rapid development and these delays can

have negative lifelong impact.

Directorate, Office for Disability. 9

D) THE ADEQUACY OF FUNDING FOR SERVICES UNDER THE ECEI PATHWAY The NDIA has not included the ACT in discussions on resourcing associated with the ECEI

partner. There is no transparency in the scope and funding of service provision the NDIA is

expecting from the partner.

The ACT has experienced cost pressure associated with the shift of what’s ‘in scope’ as

outlined in the response to part (a) above. Of particular interest to the ACT is the ECEI

partner’s delivery of early intervention services (therapeutic interventions) for children. In

the context of the ECEI partner’s broad service delivery remit, the delivery of these direct

early intervention services fills a critical service gap for the ACT.

Feedback from  families  indicates  that  they  are  experiencing  difficulty  in  accessing

psychology services. This is because, in participant plans, these services are either not

provided for at all, or are not funded sufficiently. Psychology services previously funded

through mainstream health services before the NDIS are no longer available. Some families

therefore have to self-fund psychological supports which results in out of pocket expenses

for vulnerable families.

E) THE COSTS ASSOCIATED WITH ECEI SERVICES, INCLUDING COSTS IN RELATION TO

INITIAL DIAGNOSIS AND TESTING FOR POTENTIAL ECEI PARTICIPANTS

For several months the NDIA has been focused on the review of plans for children aged 0-17

years who entered the NDIS as participants under the eligibility criteria for developmental

delay or disability. The aim of the plan reviews was is to test the participant’s eligibility for

ongoing services under the NDIS. In order to address the high numbers of children in the

Scheme and to implement the ECEI model in the ACT, the NDIA has commenced conducting

scheduled and unscheduled plan reviews for this cohort in the ACT aged 0–17 years. A total

of 2,974 plans are required to be reviewed. As part of the review process, an assessment of

participants’ ongoing eligibility to access the Scheme is being undertaken. EACH will also be

undertaking these plan reviews for children 0-6 years in partnership with the NDIA and will

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be providing a referral and linkage service for families to the mainstream service system

where ongoing access requirements have not been met.

F) THE EVIDENCE OF THE EFFECTIVENESS OF THE ECEI APPROACH The NDIA is yet to communicate the evaluation framework to assess efficiency and

effectiveness of the implementation of the ECEI Approach. The ECEI Approach cites key

research used to inform its development, and the evaluation will ideally utilise the research

findings to inform its scope. The KPMG report1 discussed the analysis of effectiveness of

intervention while highlighting the complexity of determining efficiency in this area. The

Victorian literature review2 also referred to in the Approach concludes “evidence based best

practice pedagogies are possibly the most  effective and economically  efficient  early

intervention strategy to support  positive developmental outcomes and improved  life

chances for all children.”3 The paper further suggests these best practice approaches must

experience renewal on a regular basis and that there is provision of ongoing ‘trans

professional learning opportunities’ in provision of information to families.

The NDIA has provided no information on how it will ensure ECEI services provided to

children and their families reflect not only recent research and evidence based approaches,

but also regular connections with other services and clinicians. Additionally, there is no

information from the NDIA on how the effectiveness of ECEI approaches will be measured.

Of particular interest will be stakeholders identified for consultation in any evaluation

undertaken, including the mechanism used to discuss process and EI outcomes with families,

especially families experiencing vulnerabilities. The ACT expects to be included in work

regarding the evaluation and scope of any evaluation measures.

The ACT Government has noted that for many ACT participants undergoing plan reviews, the

control, choice and quality life experiences and outcomes for participants is of concern. In

1 KPMG (2011), Reviewing the evidence on the effectiveness of early childhood intervention, Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA) 2 Department of Education and Early Childhood Development (DEECD), Victorian Government (2009), Early Childhood Intervention Reform

Project: Literature review

3 ibid 1 p57

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recent months plans appeared to be increasingly based on an off-the-shelf reference

package rather than a serious consideration of the participant’s own aspirations and goals.

G) THE ROBUSTNESS OF THE DATA REQUIRED TO IDENTIFY AND DELIVER SERVICES TO

PARTICIPANTS UNDER THE ECEI

The NDIA has not shared with the ACT the data and evidence base used to determine the

size and scope of the EI partner services. Over several months the ACT has held bilateral and

trilateral discussions with the NDIA regarding the high number of children in the Scheme and

the estimated number of people eligible for the NDIS in the ACT.

The higher than anticipated numbers of children entering the Scheme in the ACT may result

from the NDIA’s delayed implementation of EI. The ECEI approach was not adopted during

the trial and only commenced in May 2017. Additionally, the ACT was the only jurisdiction

during the trial not to have Local Area Coordinators (LAC) implemented. This is likely to have

led to the underutilisation of plans. Families didn’t have access to a LAC to support their

connection to service providers.

The ACT welcomes the introduction of the ACT ECEI approach which is an opportunity to link

families to appropriate supports and providers, but  is concerned there  is inconsistent

understanding and implementation of the Early Intervention Rule. The ACT has also raised

concerns about the inexperience of planners in this area and the resulting higher than

expected number of children in the Scheme and apparent lack of understanding of the

expected outcomes of intervention approaches. The ACT remains concerned there appears

to be a lack of expertise in the Assistive Technologies and Environmental Modifications.

H) THE ADEQUACY OF INFORMATION FOR POTENTIAL ECEI PARTICIPANTS AND OTHER

STAKEHOLDERS

The ACT endorsed the much delayed NDIA Communication Strategy for the children 0-17

Plan Review Process prior to letters being sent to parents of participants. These letters

outlined  requests  for  information and  explained the review  process. However, the

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effectiveness of the communications has been uneven. Families and stakeholders are still

approaching CDS seeking clarity of EI pathways and process. Anecdotal evidence indicates

families remain unclear on who to approach and how they can escalate concerns regarding

delays in receiving services. Families from culturally and linguistically diverse backgrounds,

with limited English proficiency, require additional supports in this process.

Although in early stages of implementation,  it will be critical to ensure there  is clear

communication of processes and pathways for all providers, including mainstream providers.

I) THE ACCESSIBILITY OF THE ECEI APPROACH, INCLUDING IN RURAL AND REMOTE

AREAS

The NDIS environment is complex involving multiple agencies. The child may often receive

services under NDIS packages and from community support agencies (as well as Health and

Education).

While communication is not always as effective as it needs to be or the pathways as clear as

they could be, accessibility for families using the ECEI Approach is enhanced by the user

friendly language  in the  publication, and the  relative absence of too much  clinical

terminology. The commitment to localise access to the Scheme is evident in the ACT with

the co-location of the ECEI partner with the ACT Child Development Service.

Families of children with disabilities have expressed concern to Healthcare Access At Schools

staff regarding their interaction with NDIS. Comments regarding access have included:

difficulty with using the portal; lack of communication from NDIS; lack of consideration for

access – for example asking carers to attend evening information sessions even though they

are full time carers; lost paperwork requiring repeat applications; early intervention not

occurring due to time delays or not meeting eligibility criteria; and significant time delays to

access services. One parent stated that “In the past when my child needed a service we

were referred and able to access without cost. Now, we are waiting for months for services

to deliver care, and we have the added burden of paperwork. NDIS has meant I can choose

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the service, but it has made it more complicated and harder for me as a carer to access the

supports for my child.”

At this stage, there is no evidence of culturally sensitive communication materials for the

ECEI Approach for Aboriginal and Torres Strait Islander families. CDS provides a range of

outreach services for this community in the ACT and through the NDIS trial it has been

evident that these communities have not fully engaged with the Scheme.

To maximise the opportunity for all potentially NDIS eligible Aboriginal and Torres Strait

Islander students to engage with the NDIS, the Education Directorate, in cooperation with

schools, referred a significant proportion of these students and their families to the Gugan

Gulwan NDIS Outreach Support program.

J) THE PRINCIPLE OF CHOICE OF ECEI PROVIDERS The ACT’s single ECEI partner was selected by the NDIA through a tender process. This

follows an  earlier NDIA  process  in  the ACT  to  support market development and

establishment of non-government service provision.

Further growth in the therapy sector may need to occur to better meet the principle of

choice  for  families. The demand  for speech  pathology and  the  limited uptake  of

psychologists as providers in the ACT impacts on this principle. A single ECEI partner could be

cost effective in the long term if the evidence base informing the practice is strong and the

provider is actively engaging with relevant groups to build inclusive connections; these

connections will enable long term support for families within their community. The NDIA has

not provided evidence that it has communicated an expectation for the ECEI partner to take

an inclusive approach with community to build long term, strong connections with relevant

groups such as playgroups or new parent groups.

In addition to the limited number of providers, parents often do not have the necessary

information to assist them in making a decision as to who would be the best provider. This

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lack of information may be an additional challenge from parents from culturally and

linguistically diverse background, particularly if they have limited English proficiency.

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

The NDIS ECEI Approach makes reference to key research pieces used to underpin practices

and services for children with developmental delay or disability. In particular, the KPMG

report4 provides an exploration of early intervention effectiveness, and finds that use of

functional assessment (determining needs and strengths) is appropriate for targeting of

services to individual children and family circumstances5. Given the ACT was not involved in

establishing the scope of the services provision or any intended evaluation process, it is not

clear how the NDIA applied this research in determining the delivery of EI services.

Actual scope of the ECEI Approach does not outline how eligibility for short term EI services

by the EI partner outside of the Scheme’s  eligibility criteria  will be determined. The

sensitivity of functional assessment tools to identify developmental needs of children is still

to be demonstrated in the application of this Approach.

L) ANY OTHER RELATED MATTERS Aboriginal and Torres Strait Islander community connection and diversity

It is important that consideration be given to how the ECEI partner will engage with the

Aboriginal and Torres Strait Islander community given a number of families experiencing

vulnerabilities in the ACT are Aboriginal or Torres Strait Islander, or from culturally and

linguistically diverse backgrounds. The ACT is interested to know the number of Aboriginal

and Torres Strait Islander staff employed by the NDIA and the ECEI provider to ensure ECEI

communication  is effective and process  is culturally sensitive. The NDIS Aboriginal and

4 KPMG (2011)

5 Ibid p92

Directorate, Office for Disability. 15

Torres Strait Islander Strategy 20176 acknowledges that ACT Aboriginal and Torres Strait

Islander “community members have expressed concern and frustration about the lack of

culturally sensitive support services to choose from”7. At time of writing, the Strategy’s

section on the ACT makes no reference to ECEI strategies to enable strong connections with

the local ACT Aboriginal and Torres Strait Islander community or to build links to existing

services and supports. This is of particular concern given the Strategy admits lack of

culturally sensitive supports has “resulted in some people with high needs not accessing any

formal supports or services related to their disability”8. Additionally, it will be important that

cultural and linguistically appropriate materials are provided to other stakeholders to ensure

inclusion and accessibility.

Additionally, it would be of interest to know how appropriate materials are to be delivered

to people from culturally and linguistically diverse backgrounds, particularly those with

limited English proficiency so as to ensure inclusion and accessibility.

Opportunities

Co-location of the newly established EI partner with CDS provides the opportunity for

stronger partnering and access to local knowledge and stakeholders; it is anticipated this

stronger partnering and sharing of information could streamline access to services for

families.

Local connections with Aboriginal & Torres Strait Islander communities are an opportunity

still to be fully utilised with the co-location of CDS and the EI partner. However recent

operational changes negotiated through the NDIA at the request of the ACT may address

this.

Risks

Evidence from families interacting with the Community Services Directorate indicates that

6 NDIS (2017), Aboriginal and Torres Strait Islander Engagement Strategy

https://www.ndis.gov.au/medias/documents/hcb/h31/8800389759006/Aboriginal-and-Torres-Strait-Islander-Strategy-3MB-PDF-.pdf

7 Ibid p32 8 Ibid p32

Directorate, Office for Disability. 16

mainstream services are increasingly being utilised as families seek to deal with lack of

clarity on service pathways and timely access to EI Services. Access to mainstream services in

the private sector will also be dependent on family income.

The ongoing provision of in kind services by the ACT Government through the Children and

Young People’s Equipment Loan Service (CAYPELS) currently ensures continuity of care for

families of young children with equipment/assistive technology needs. However, in kind

provision cannot extend beyond transition and there are budget pressures impacting on the

long term provision of CAYPELS. Private providers in the sector access this service for clinical

trials and loan equipment for children with NDIS support packages. This additional cost

pressure is unaccounted for with no interim arrangements in place with the NDIA.

Directorate, Office for Disability. 17

Community Services Directorate

August 2017

Directorate, Office for Disability. 18