Tasmanian
Government
Submission
JOINT STANDING COMMITTEE ON THE NATIONAL
DISABILITY INSURANCE SCHEME (NDIS)
September 2019
19/97119
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Table of Contents
- Introduction ………………………………………………………………. 2
- Response to Areas of Inquiry ……………………………………….. 2 2.1 ………………………………………………………………………………………………………….. T he approval process for access to
SIL………………………………………………..2
2.2 ………………………………………………………………………………………………………….. T he vacancy management process, including its management and costs………………3
2.3 ………………………………………………………………………………………………………….. T he funding of SIL …………………………………………………………………….. 4
2.4 ………………………………………………………………………………………………………….. A ny related issues …………………………………………………………………….. 5
- Conclusion ………………………………………………………………. 6
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1 INTRODUCTION
The Tasmanian Government welcomes the opportunity to provide a submission to the
Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Inquiry
into Supported Independent Living (SIL).
The NDIS is one of the most complex and important reforms that Australia has seen in recent years and its potential to transform the lives of Tasmanians living with disability cannot be overestimated. Tasmania moved to full scheme NDIS on 1 July 2019 and is now operating under the Bilateral Agreement between the Commonwealth of Australia and the State of Tasmania on the National Disability Insurance Scheme. This Agreement reflects the shared NDIS responsibilities of both Governments and locks in arrangements for on-going funding contributions to the Scheme.
Successfully transitioning to the NDIS has been a key focus for the Tasmanian Government. From 2013 to 2016, Tasmania was an NDIS trial site for young people in the 15-24 age group. During that time over 1,000 young Tasmanians transitioned into the Scheme. In July 2016, Tasmania commenced its three year transition to full scheme with eligible people entering the scheme by age cohort. It was estimated that 10,587 Tasmanians would be supported by the NDIS by 30 June 2019, the end of the transition period. As at 30 June 2019, 6,831 Tasmanians were receiving NDIS support. This represents 65 per cent of the Tasmanian Bilateral estimate met for the period 1 July 2013 to 30 June 2019 compared to a national average of 72 per cent.
Supported Independent Living (SIL) in the context of the NDIS means help with and/or supervision of daily tasks to develop participants’ skills to live as independently as possible in the housing option of their choice.
The Tasmanian Government is pleased to note recent improvements in relation to the funding of SIL, however there is still more to be done to improve the capacity of participants to live as independently as possible, as quickly as possible. This is particularly the case for those participants experiencing discharge delays from Tasmanian hospitals, acute facilities and those in custodial settings.
This submission highlights areas of particular relevance to the Tasmanian Government as they relate to the experience of SIL supports in Tasmania.
2 RESPONSE TO AREAS OF INQUIRY
2.1 The approval process for access to SIL
The SIL approval process can be lengthy, particularly for participants who are seeking discharge from hospitals or custodial settings. At times, multiple requests for clinical
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recommendations are made by the National Disability Insurance Agency (NDIA), which can be time consuming and may result in extended in-patient stays, delays in being released from custody or the need to provide interim accommodation support while waiting for final approval of a SIL quote.
The SIL approval process in general could be further improved through better coordination and working protocols with Tasmanian Government agencies based on the NDIS Applied Principles and Tables of Support (APTOS).
The Tasmanian Government acknowledges progress of the National Hospital Discharge Action Plan (currently being piloted in South Australia) which, when implemented in Tasmania, may resolve some of these issues. Local protocols are also being finalised between the Tasmanian Department of Justice and the NDIA to improve the access, planning and support processes for participants leaving custodial settings.
Currently there is no provision for a participant to access SIL when they are staying in interim accommodation. For example, a person who requires short term accommodation as a transition home from a clinical setting or a person that needs to move to a temporary respite situation as a result of behavioral issues can experience difficulties accessing SIL. The Tasmanian Government suggests improved pathways for emergency management together with a crisis response. These modifications, along with increased flexibility in participant plans, would allow better use of SIL supports when providing short term interim accommodation support.
It is noted that the SIL approval process is not consistent and can depend on the skills and knowledge of the planner processing the quote. Consequently there may be delays in communicating with participants, families and service providers in relation to outcomes. This can be particularly challenging where the participant is living in shared accommodation and other residents may be affected by the delay. Further, the provider may be financially disadvantaged as they are unable to claim through the NDIS portal without an approved quote.
The approval process for people with complex support needs can be time consuming as additional information may be required as evidence of complexity. To date there has been a lack of skilled and experienced planners to facilitate effective approvals for this cohort.
2.2 The vacancy management process, including its management and costs
Vacancy management remains the responsibility of service providers or providers of Specialist Disability Accommodation (SDA).
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Prior to implementing the NDIS, the Tasmanian Government was responsible for vacancy management via contracted arrangements with non-government providing an access and service coordination point for specialist disability services. These organisations maintained a needs register, a list of accommodation vacancies and individual client profiles. The Tasmanian NDIS partner organisations providing Local Area Coordination would be well placed to continue such an arrangement as part of the NDIS system.
While a pathway has now been established by which providers can alert the NDIA to vacancies, a seamless process still does not exist to ensure planners, Local Area Coordinators (LACs) and support coordinators are aware of existing vacancies when working with participants and their families through the planning process. As a result, accommodation providers are experiencing financial impacts as vacancies are left unfilled for extended periods of time. This is affecting the viability of some accommodation arrangements, leading to a reduction in the number of places available in an accommodation setting, and disruption for participants who may need to find alternative accommodation.
There are potential benefits to participants and providers in sharing fixed costs, however prolonged vacancies are having a negative impact on this option. For example, providers are balancing shared fixed costs to manage the property and workforce (including rosters), and experiencing reductions in both rental income and access to shared transport. As mentioned previously, this issue can affect the other residents and has on occasion led to the provider downsizing a property, resulting in disruption to residents.
The original intent of SDA was for the market to develop and self-manage a process for filling vacancies, acknowledging that the NDIA has held the position it will not undertake this role. However, the market has not significantly or sufficiently matured thus far to self-manage this process. This has resulted in ongoing gaps, leaving participants and providers unable to readily advertise and/or identify vacancies.
Support Coordinators have no effective processes to find suitable vacancies and are often turning to the private rental market, which in Tasmania is already under significant pressure with a shortage of affordable accommodation in general and even fewer options for people with disability.
2.3 The funding of SIL
Providers report that the level of funding for SIL is inconsistent and inadequate to meet the needs of participants and to maintain support in a SIL environment.
The quoting process has been time consuming for providers, with little guidance on information required by the NDIA to undertake the assessment process and approve
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the quote. Providers have also found the process difficult in that they are required to commit unfunded resources to complete the quotes.
In Tasmania, all existing group homes transitioned into the NDIS over a set time frame. During this period, providers reported inconsistencies with the receipt of SIL funding, resulting in challenges around adequately managing the household, workforce (including rosters) and participant needs. This inconsistency has created an increased workload over a period of time, which has led Tasmanian providers both large and small being disadvantaged.
Recent amendments to the NDIS Pricing Guide are welcomed but providers have advised the increases are still not covering the cost of delivering services. Larger providers have indicated they are absorbing some of the cost of service delivery, particularly in rural and remote areas. Providers are considering how this unsustainable situation will affect their capacity to deliver future services.
Providers are also expressing concern about providing future SIL support to participants who have complex support needs. Depending on an individual’s circumstances, delivering complex support can be costly, difficult to manage, and require additional reporting as a result of the introduction of the Quality and Safeguarding Framework.
The requirements of the SIL framework can at times present challenges for providers to respond to emergency situations; namely, it can be difficult to mobilise a workforce at short notice outside of current rosters to meet emergency or crisis needs.
The Tasmanian Government acknowledges the review and iterations of SIL requirements and funding, along with the revision of templates and guidelines to make the quoting process less complex for providers. Most providers have now developed internal processes associated with the preparation and submission of quotes.
2.4 Any related issues
2.4.1 Changes in circumstances
Changes in individual participant circumstances can occur at short notice or as a result of a crisis or emergency situation, which may then trigger the need for a plan review. These sorts of circumstances can adversely affect providers.
For example, a change in circumstance may mean that the participant needs to leave their SIL accommodation for a period of time with the intention to return when able
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and appropriate. Where a participant needs to move to a respite environment as a result of behavioural issues but receives support from the same provider, then the provider can no longer claim for the SIL support component of the participant’s care whilst they are in alternative accommodation. A plan review may be called for, but these take time – often up to several months – to be finalised. Meanwhile, the provider is financially disadvantaged until the plan is reviewed or until the person moves back to the SIL environment, often requiring a revised SIL quote.
This process can be disruptive and stressful for the participant and their family and administratively burdensome for the provider.
2.4.2 Accommodation - separation of property/tenancy management and support in
SDA
In Tasmania, approximately 350 participants live in SDA and receive SIL to assist them to live as independently as possible. Approximately 80 per cent of SDA in Tasmania is owned by the Tasmanian Government’s Director of Housing (DoH) and leased to disability support providers through a Community Tenancy (CT) lease. CT lease arrangements comprise a head lease between the DoH and the disability support provider who then enters into separate rental arrangements with participants. Effectively this means that the disability support provider is providing both tenancy management and SIL.
Introduction of the NDIS has enabled participants to exercise choice and control over their supports, including who provides it. In the context of current SDA arrangements in Tasmania, when participants choose to change their SIL support provider this presents challenges for both the participant and the SIL provider. The participant would potentially either need to negotiate with providers to split the tenancy/support function or in some circumstances (for example, shared living arrangements) need to leave their home. From the provider’s perspective, the current SDA model is based on providing accommodation and support and it is often not financially viable to provide just one of these functions.
The Tasmanian Government is currently considering its long term management of SDA and following an audit, will release an SDA portfolio plan and a review of forecasted demand and supply.
2.4.2 Transport
Historically, service providers have provided transport for people residing in group homes or large residential services through a vehicle funded by block grant funding. SIL funding within the NDIS does not include transport costs, making it challenging for providers to maintain vehicles and meet residents’ ongoing transport needs.
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3 CONCLUSION
The Tasmanian Government acknowledges the complexity of NDIS reform nationally and welcomes recent SIL process changes that have improved the experience of Tasmanian participants and providers respectively in accessing and providing SIL supports.
As an overview of the Tasmanian experience of SIL to date, below is a summary of key points raised in this submission:
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The Tasmanian Government continues to participate in work currently progressing at a national level through the COAG Disability Reform Council Senior Officials Working Group and welcomes development of national policy and ongoing improvements to the NDIS.
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It is vital that there continues to be an improvement in the consistency of the SIL approval process such that it meets participants’ needs and results in positive accommodation support outcomes.
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There is a clear need for improved vacancy management processes to assist participants in securing appropriate accommodation and to enable growth in the developing market.
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The Tasmanian Government welcomes implementation of the National Hospital Discharge Action Plan (currently being piloted in South Australia) in Tasmania as soon as possible.
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There is still work to do to improve the timeliness of the SIL approval process, particularly in the case of people with complex needs.
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Improved pathways for emergency management and crisis response situations, including increased flexibility in participant plans, would enable better use of SIL supports when providing short term interim accommodation support.
The Tasmanian Government looks forward to the release of the outcomes of this Supported Independent Living Inquiry.
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