Submission 22
SUBMISSION: SUPPORTED INDEPENDENT LIVING INQUIRY
Inquiry by the Joint Standing Committee on the National Disability Insurance Scheme
About Identitywa
Identitywa is one of Western Australia’s leading agencies supporting people with disability and their families. We provide support to children and adults throughout the Perth metropolitan area. We are an outreach of the Catholic Archdiocese of Perth and while our services are proudly based on Catholic values, our Vision encompasses people of all faiths and backgrounds.
Our Vision is to build a community in which “All people live with a sense of purpose, a sense of belonging and a sense of wellbeing”.
Our Mission: Identitywa works in partnership with individuals and families to build a community where people with disability enjoy a fulfilled life. We support individuals to achieve their goals, whatever they may be. We offer families the support they need.
Our Values: Above all else, we make a commitment to act. We look for opportunities rather than seeing the barriers. Our approach is objective, transparent and fair. We’re honest and open, and no matter how challenging, we will see it through to the end.
For each individual and family this means we begin our relationship by asking, ‘What does a good life look like for you?’ We then work together to find the mix of right supports to help make this a reality. To achieve this, we are continually finding new ways of adapting our support to suit people’s needs, goals and dreams as they change over time.
Response to the Terms of Reference
a. The Approval Process for Access to SIL
- Wait time for Housing reports and confirmation of SIL For new participants seeking Supported Independent Living (SIL) the process is lengthy, and at a minimum it is taking up to six (6) months for the first stage, a Housing Exploration / Housing Report to be conducted and submitted. From this point the Participant is required to wait a further period of time before SIL is approved. For many Participants and their families who are seeking SIL this wait time has exacerbated their situation. One example Identitywa can share and comment on has been in process since November 2018. Mr KC is a 34-year-old man living in the northern suburbs of WA with his parents. He has an intellectual disability and is supported during the week to access his community.
KC first entered planning with the NDIA in October 2018. The primary goal was to secure SIL as the family were at breaking point and his mother was also caring for KC’s father who was terminally ill. A short-term plan was approved from 26/11/2018 to 27/05/2019
for the family to explore housing options and undertake occupational therapy
assessments to determine his needs.All reports were complete and submitted including a SIL quote (submitted on multiple occasions due to NDIA misplacing them). At this time KC and his family still have no final plan, no SIL funding or guarantee that KC can move into his own home.
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The email chain below is indicative of the numerous attempts to secure SIL funding for KC. Unfortunately for the family and after the below email chain, the Carer of KC received a phone call notifying her of a scheduled planning meeting…. ‘The NDIA have set a time for September 19, 2019’. After 10 months of work and planning the NDIA clearly have an internal communication issue. How can a SIL quote be submitted and the planning process be nearing end stage while at the same time the family are being asked to enter planning? Identitywa and the family acknowledge that this is a mistake by NDIA however this is just one example of the incompetence and immaturity of their systems and processes. It is guaranteed that this will further delay a positive outcome for KC and his family. The impact on KC and his family has been that the poor process of the NDIS has added to their distress over a prolonged period.
Example of the frustration with the NDIS process and planning, the quote referred to was first submitted on 28 May 2019
Date: 28 August 2019 at 9:28:08 am AWST Subject: RE: SIL Quote [SEC=OFFICIAL] Good morning Thank you for the resubmitted quote for KC. SIL quote model of care looks reasonable, however, the NDIS is unable to accept the weekly quoted amount you have requested. A weekly amount of $4850 inclusive of any indexation would be accepted. Please reply to this email to confirm acceptance of this weekly price.
Thanks, NDIA WASIL
—————————————————————————————————– Reply from Identitywa to WASIL Hi
When developing our quotes, Identitywa use the NDIA prices to determine the total figure. This is how we arrived at $5,016.90/wk plus indexation.
However, we have picked up a flaw in the pricing template developed by NDIA that overstates the quote amount. After allowing for this, we come to a quote amount of $4,898.50/wk plus indexation. This would be acceptable to Identitywa as it directly reflects NDIA’s own pricing guide and is reflective of reasonable and necessary supports.
If you would like to discuss the quote, or the flaw in the pricing template please feel free to contact me.
Thanks,
Identitywa
From: On Behalf Of WASIL
Sent: Wednesday, 28 August 2019 3:25 PM
To: Identitywa
Subject: FW: SIL Quote [SEC=OFFICIAL]
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Hi
Thank you for your email, Please note this negotiation is not an acceptance that SIL has been approved for KC. I will be progressing this quote through for consideration by the NDIA.
Kind regards,
WASIL
Second Example
Another case in point, which also indicates the negative impact of the Planning process, was a young gentleman who had housing exploration put into his plan in 2017. Identitywa provided a Housing Exploration report to the Support Coordinator in June 2018. A review of his plan took place in December 2018. The review included the participant wanting to find employment and accommodation. His new Plan contained the accommodation component but omitted the Finding and Keeping a Job line (the other primary reason for review.). This omission lead to another review of his plan, which was planned for February 2019. Identitywa were asked on 3 occasions to submit and re-submit the SIL Roster of Care and Profile. On 1st May 2019 NDIS informed us and the family that the Support Coordinator had not submitted the full Housing Report. All parties re-submitted all documents. On the same day NDIS apologised as they did have all the information already (this is a common occurrence). The SIL quote was finally accepted on 20 June
- The gentleman moved into his house on 28th June 2019. The stress for the family during this time was significant. The mother has a chronic health condition, hence the need for alternative accommodation. This process was onerous, confusing, error-filled and took its toll on all involved.
- Service Providers deliver reports on time and prior to planning meetings The NDIA are failing in their responsiveness to set and keep appropriate timelines for planning meetings and the planning process. Identitywa has on numerous occasions supported participants and families to seek and set planning meeting dates and times in lieu of no response from the Agency. On several occasions, the meetings are set with little or no notice and in some instances Identitywa have delivered / uploaded reports required well in advance of the required 6 weeks.
It has been Identitywa’s recent experience on 3 separate occasions that NDIS planners have contacted us with less than a week before the expiry of individuals plans (including SIL) to organise meetings with the participant, family and stakeholders. On one occasion it was with less than 15 hours’ notice and could not be attended by any parties. This led to plan extensions for 3 individuals in a house. On each of these occasions it has been impossible to organize with NDIS suitable times prior to the end of plan dates, hence, plans have been extended for 3 months, causing additional administrative burden for both NDIS and organisations and families, due to having to create Service Agreement addendums, and new service bookings for short periods of time, knowing that it will occur again in another 3 months.
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In some instances, plan extensions have been applied or the plan ends, and the participant is left without access to funding and services. In these cases, Identitywa is forced to deploy resources into finding a resolution on behalf of the Participant or cease services. Even when Identitywa continue to deliver supports there is no guarantee that we will have access to funding to cover the delay caused by NDIA.
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Time available to SIL Planners to pre-read all documentation for new and existing SIL individuals. Availability of all documentation to SIL planners in one place. It has been Identitywa’s recent experience that some Planners appear to only read certain parts of an individuals Allied Health reports – which is critical to the funded support. One example of this in the past few months, was a Planner stated that an individual could ‘cook his own meals’ and was therefore independent in this regard. This was interpreted from a 1 hour OT assessment where the individual was observed (with prompting) to get a frozen meal out of the freezer, prompted to open the packet, assisted to set the time for cooking on the microwave, assisted to check it for heat, assisted to get it out of the microwave with prompting to use oven mits, and assisted to put the food on his plate. What wasn’t overtly stated in the OT report was that, without verbal
prompting and support, this person would not be able to undertake this task
independently. If Identitywa staff had not queried this, the individual would not have the level of support that he requires to live in a SIL supported accommodation.
b. The Vacancy Management Process, including its Management and Costs
- Vacancy management has been challenging due to the slow and lengthy time it is taking the NDIA to approve SIL in a participant plan. On one occasion Identitywa was forced to fill a vacancy without delay or face a funding cut to one of our existing clients. This participant was six months into his twelve-month plan and had earlier moved from a five person shared living home into a single option due to his extreme behaviors of concern and damage to property. For his safety and for the safety of others Identitywa placed him in a new option. It was always a goal and the intent that this participant would live with others, and therapy reports identified that he should live with no more than 3 others. When NDIA called an early plan review and demanded we fill the vacancy they stated that it was a restrictive practice for the participant to live alone, and that the participant would see a reduction in SIL funding if this was not rectified before the plan end date.
Where a participant dies, and they live in a shared option it would be beneficial and respectful to all involved if funding was extended for a period an extension of eight weeks would allow participants time to grieve and for the roster of care to be adjusted without detriment to all involved.
c. The Funding of SIL
- SIL quotes When developing our quotes, Identitywa use the NDIA prices to determine the total figure. Regularly we are asked to adjust our quote to consider a lessor amount as recommended by the SIL team. Recently we alerted the NDIA WA SIL team that we picked up a flaw in the pricing template developed by NDIA that overstates the quote amount.
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Submission 22
On the quote for the Participant when the discrepancy was identified, and after allowing for this the quote amount remained slightly higher that what was being offered by the WA SIL team Planner. Our response was that our revised quote would be acceptable as it directly reflected the NDIA’s own pricing guide (unlike that which was being offered).
We offered to further discuss the quote, or the flaw in the pricing template. Identitywa would like for all quotes as per the quoting tool to be funded and for the final amount of SIL funding to accurately reflect the Pricing Guidelines of the day.
d. Any related issues
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Delay in payment Identitywa is regularly waiting for payment via the portal process or via the Manual payment method. The largest amount owed to us by NDIA has been $250,000.00 and as at August 30, 2019 it was $90,000.00. In our experience for existing plans that meet their end date it is unlikely that the NDIA are on time or meet deadlines.
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Reasonable and Necessary The interpretation of reasonable and necessary is not consistent from year to year, Identitywa have clients in receipt of items for three years and for one individual when they received their fourth plan some items e.g. nursing care were omitted and denied. The care and support required is attributable directly to their disability type. The participant has been in dispute with the NDIA and has been awaiting an outcome from his request for a review for nearly five months. If items that are essential (requirements of daily living due to disability) and have been previously funded, these items should continue to be funded and the Participant not disadvantaged.
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Delay in the setup of Service Bookings for SIL There are frequent delays in NDIA setting up service bookings in the portal for SIL. On numerous occasions we have had to follow up and or request for the service bookings to be finalised. We currently have two outstanding service bookings, one since April
- We suggest that there be automatic service bookings for SIL participants – one booking until participant exits scheme. An Alternate solution is two-year service
bookings regardless of plan start / end date.
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Plan errors including typos, incorrect information Where plan errors exist and are identified immediately or on receipt of the draft plan the
NDIA must rectify and ensure accuracy immediately and without delay to avoid
disadvantage to the participant or Service Provider.
- 3-month SIL service bookings Identitywa are confused as to why some SIL-funded participants in our shared living accommodation are provided with 3-month SIL bookings, whilst others living in the same house have full year bookings. When we raised the question with the SIL Planner, there is often not a clear response. This adds undue additional administrative burden to the SIL provider, through additional paperwork, and having to explain to families and individuals that there will be another plan in 3 mons without a reasonable answer.
Identitywa’s Contact Details
Phone: (08) 9474 3303 Fax: (08) 9474 3315 Email: admin@identitywa.com.au
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