NDIA Accountability Project

Submission 25 — Brightwater Care Group — Supported Independent Living

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Joint Standing Committee on the National Disability Insurance Scheme

Senate Inquiry: Supported Independent Living

Date: 6 September, 2019

Sent by email to: ndis.sen@aph.gov.au seniorclerk.committees.sen@aph.gov.au

Submitted by: Brightwater Care Group

Level 3, 355 Scarborough Beach Road

Osborne Park 6017 Western Australia

Introduction

Brightwater Care Group is a non-profit organisation that supports people to live a better quality of life, with the mission of ‘pursuing the dignity of independence’. Our services are extensive, from short and long-term residential accommodation and rehabilitation services to capacity building and assistance in the home, and include specialist skills in supporting people living with Dementia, Acquired Brain Injury and Huntington’s Disease. Our expertise is providing high quality care in a strong and flexible framework that embraces changes in funding models and paradigm shifts in consumer-directed care, and values investment in dynamic relationships across multiple care sectors including health, primary care, mental health, and disability. The Supported Independent Living (SIL) service maintains a focus on helping people to remain active and engaged within their home and community. Navigating transition to the NDIS has presented this cohort with opportunities to broaden perspectives on service delivery models and integration with providers including health, mental health, housing, and community services.

In regard to the committee’s inquiry into the implementation, performance and governance of the National Disability Insurance Scheme (NDIS) in regard to Supported Independent Living (SIL), we submit to you our experience and recommendations as a large SIL provider in Western Australia.

a) the approval process for access to SIL;

  1. Challenge: The time required to develop and process a SIL quote is lengthy.

  • The process of SIL quoting requires that the roster of care for all participants is included for each NDIS plan developed. The roster of care specifies staff to participant ratios for every hour of the day.

  • We recognize in the future, SIL shared accommodation will consist of houses with no more than 5 participants, however, existing SIL sites represent a range of models including accommodation and distribution of staff resources for 6 to 12 participants across multiple houses on a site. In larger sites with more participants, the process to develop and update rosters of care for quoting is particularly arduous.

  • The NDIA process relies on emails as the only form of correspondence to address SIL related enquiries. The NDIA call centre is unable to discuss the SIL quote or provide an update about the progress of the quote. Communicating with NDIA around the complexity of delivering services to this cohort results in significant delays for plan approval. This unsustainable strategy of communication creates inefficient delays and does not place the participant and their needs at the centre of the quoting process.

    Example: Our SIL shared accommodation service includes a variety of housing

configurations. Site configurations range from 2 houses with 6 participants per house, to 3 houses with 4 participants per house, to a cluster of 6 units with a total of 9 participants. A common feature across all our sites is that there is one support worker scheduled for the night shift which may be an active or sleep shift. In over 25 years of delivering high quality care, we have evidence that this level of support is safe and effective to support up to 12 residents per site. The roster of care and SIL Quoting Tool do not facilitate this scenario and it requires discussion with NDIA every time we submit a quote for every current or prospective client across 8 residential sites.

Opportunity: The process of approvals for SIL should be attentive and flexible to the range

of  existing  SIL  configurations supporting  participants  in shared accommodation, and

efficient, effective communication between NDIA and Service Providers in the SIL quoting process is of utmost importance to meet the needs of participants and providers.

  • The SIL Quoting Tool should facilitate rosters of care for legacy sites where staff to participant ratios are less than 1:5.

  • The SIL quoting process should include access to knowledgeable NDIA staff for SIL related enquiries to talk through rosters of care and quote development to reduce delays and increase clarity of communication.

    1. Challenge: Individuals living in supported accommodation for people with disabilities

represent a cohort of defined participants who are eligible for NDIS and should be most easily identified, however, many are not being identified or contacted by NDIA planners in a timely or effective manner.

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• Our experience is that gaps in information about this cohort have resulted in

significant delays in clients accessing the NDIS due to lack of consistent of awareness of the individuals and absence of contact from NDIA planners. On multiple occasions our organisation has initiated contact and provided to NDIA lists identifying the individuals waiting to be contacted.

  • Participants in our organisation are waiting more than 14 months for a planning meeting from the time they became eligible for NDIS services.

  • Participants in our care have been contacted by NDIA planners who organize meetings that are cancelled at short notice because a non-SIL NDIA planner has been assigned. The meetings are not rescheduled and no follow up is provided to ensure appropriate SIL planning is progressed.

  • Participants in our care have been contacted and requested to attend meetings at a great distance from their home location, or asked to complete the planning over the phone. This is not appropriate given their impairments.

  • NDIS plans may be approved without the SIL funding component (subject to the quote) which means that providers are unable to claim for services until a SIL quote has been approved, resulting in delayed payments for services provided. The Provider Payments process is exceedingly lengthy and not responsive (delays of over 12 months) which leaves providers in debt.

Opportunity: The cohort of defined individuals living in supported accommodation in Western Australia is distinct and known to NDIA. These individuals have confirmed eligibility and are supported by service providers who can contribute to the planning process in a way that meets the individualised needs of the participant and his/her decision makers.

  • It is essential that the NDIA addresses, as a top priority, the backlog of participants in SIL waiting for initial NDIS plans.

  • SIL quoting requires concurrent prioritisation with NDIS planning. b) the vacancy management process, including its management and costs; Challenge: Delays in approval for access to SIL significantly impact opportunities for eligible individuals to access appropriate housing in a timely manner.

  • Participants with highly engaged advocacy support to influence escalation and expediting of NDIS plan approvals are disproportionately advantaged for securing SIL vacancies.

  • Complex participants who are under public guardianship are a highly vulnerable group within the population of NDIS participants. They are dependent on the effectiveness of collaboration between service providers and with the NDIS to achieve access to appropriate housing.

  • Businesses carry a financial risk to hold vacancies for eligible clients waiting for plan approval and creating pressure to fill vacancies with preference for plan approval timing rather than suitability of matching with the house or consideration of greatest participant need and choice.

Case Example: Participant H has an acquired brain injury and lives in a remote part of the state. Participant H has a public guardian and trustee, and the few family members he has are estranged and live interstate. Participant H lived on his own until his health deteriorated and he required hospitalization. After a very positive recovery in hospital, he was unable to be discharged as he could not yet return to living on his own and there were no SIL providers

in the remote location. The hospital had started the process of the NDIS application during his hospitalization and reached out to a metropolitan SIL provider that had a suitable vacancy for him. The process of achieving approval of the plan required escalation and took over 6 months before the individual could transition to the SIL accommodation. In this example there is interagency collaboration and resource identification to meet the need of a highly vulnerable participant. It was also fortunate for the participant that the provider was willing to hold an unfunded vacancy for a number of months and did not actively pursue alternative clients, withstanding the opportunity cost of close to $3000 per week. The cumulative cost to the health system, including basic bed day costs, 24/7 security, and individualized support for the individual in a public hospital is significantly higher and is not an appropriate use of resources for an individual who required no ongoing medical attention.

Opportunities: Where there is interagency collaboration for complex and highly vulnerable participants, priority should be given to match and progress SIL accommodation approval. This places the wellbeing and dignity of the participant at the center of the process to transition to suitable housing and supports.

c) The funding of SIL We welcome the 28 June 2019 announcement, by the Council of Australian Governments (COAG) Disability Reform Council (the Council) of the agreement that the NDIS will fund a range of disability-related health supports where they are part of the participant’s daily life and result directly from the participant’s disability and that this agreement is due to commence on 1 October 2019.

Challenge: Brightwater supports complex clients with acquired brain injury and Huntington’s Disease in SIL. This cohort of participants has high health and self-care support needs directly related to their disabilities and are statistically more prone to chronic disease than the general population. Disease prevention through proactive health management is not currently well provided for within the existing NDIS price guide.

•  Poor  health has  the  potential  of  reducing  the  individual’s  capacity  to  live

independently and increasing their lifetime cost of care.

Opportunity: The health related supports fact sheet states, “A NDIS participant’s disability may prevent them from being able to self-manage certain health conditions that a person without disability would be expected to do themselves. In these circumstances, the NDIS will fund self-care supports. The NDIS will also fund self-care supports where it is necessary for the support to be delivered by a clinician.”

  • Clarification and support is urgently needed to enable clients to develop appropriate plans inclusive of supports that are currently neither covered by the public health departments or NDIS, including preventive health measures.

d) any related issues:

  1. Challenge: There is a heavy reliance on Service Providers to facilitate the NDIS process, especially for people who do not have independent decision making capacity and/or family support. This includes access, pre-planning, plan meetings and service links. Community

clients (non-SIL) have access to the NDIS Partners in the Community i.e. Mission Australia and APM services for additional support and service links. This resource is not currently available to participants in SIL, placing unfunded strain on SIL providers and creating disadvantage for SIL participants.

Opportunity: SIL participants, particularly those who do not have independent decision making capacity and/or family support, require equitable access to resources such as NDIS Partners in the Community to provide independent support and service links.

2.  Challenge: The  level  of  responsibility  for the  SIL provider,  in supporting  participant

outcomes, is impacted by the lack of ability to influence those outcomes when recreation, employment and therapy providers are not necessarily taking a consistent approach to supporting participant goals.

  • Current plan structures are single item funding oriented and do not intuitively facilitate multiple providers working with and around the client. Plans may articulate “providers work together within the home and community settings in order to meet the plan goals and objectives”, however, this is reliant on the participant or guardian being able to lead and facilitate this process, or consistent (not time limited) support coordination to support where the participant is not able to lead this facilitation.

  • The impact of this issue is particularly significant for complex clients living in SIL. Many clients in SIL have appointed decision makers for different aspects of daily living, with widely variable levels of engagement with the client, family and service providers.

  • For clients who are their own decision makers and/or who have highly engaged family or guardians, coordination of interagency communication can be a very challenging.

Opportunity: It is of great importance to ensure that within a client’s plan there is dedicated opportunity for collaboration between the client and all of their providers.

  • We recommend that plans for complex clients include funding for interagency multi- disciplinary time to work jointly on goals and empower more collaborative

interactions such as therapy providers training the SIL and recreation staff to carry over goal oriented activities introduced in therapy.

•   Support Coordination and access to resources such as NDIS Partners  in the

Community should be included in all plans for SIL participants, and recognized as an continuous requirement for dynamic management of complex support.

Case example: Participant P lives in SIL and has community access in his NDIS plan which includes goals of outdoor activities and reconnecting with people and memories from his past. One of the special locations he likes to visit is over 30 minute drive from where he lives. Participant P goes on his community outings with provider X. After a few months, provider X approached the SIL provider to discuss strategies for Participant P to access more transportation funding. It came to light that the community access provider was taking the participant on to the special location far from the house at almost every outing, and as such used the entirety of his travel funding for the year. There was a lack of communication between the community access provider and the SIL provider around goals and outcomes, and differences in approach to engaging the client in the planning and budgeting process to ensure that he could continue access the community in a way that he chose and in within the funding resources available to him.