—_—The-prevision-of services under the NDIS for sith psychosocial disabiliti people with psychosocial disabilities related t iti Sn aeeenres o a mental health condition
Queensland Health
Queensland Health Submission to the Joint Standing Committee:
Provision of Psychosocial Services under the NDIS for people with psychosocial disabilities related to a mental health condition.
February 2017
Government
Terms of Reference “a. and b. and d”
Queensland Health’s understanding of the NDIS eligibility criteria for psychosocial disability is that many people with mild to moderate psychosocial disability will not be eligible for individual funding packages under the NDIS.
At the same time, Queensland Health is aware that the Commonwealth Government has “cashed out” to the NDIS, some portion of their community-based, recovery oriented services of Personal Helpers and Mentors (PHaMs) and Partners in Recovery (PIR) which have been able to be accessed previously by individuals with mild to moderate psychosocial disability.
Queensland Health is concerned that due to this “cash out” decision there may be insufficient funding left to provide services to Queenslanders with mild to moderate psychosocial disability who may not be NDIS eligible. Queensland Health’s concern arises from a number of areas:
e some lack of clarity around what activities the “Information Linkages and Capacity Building” (ILC) function will fund and its interaction with any PHaMS and PIR “continuity of supports”;
e some lack of clarity around how the NDIA will fund “continuity of supports” around any individuals who were previously clients of PHaMS and PIR and are ineligible for individual funding packages under the NDIS; and
e apotential rise in the number of people with mild to moderate psychosocial needs seeking support (unknown unmet need).
Further in relation to the issue of NDIS eligibility, Queensland Health is uncertain as to how eligibility of people with dual or multiple disabilities will be determined, for example, a person may have a mild or moderate intellectual disability and a mild or moderate psychosocial disability, the sum of which will be greater than the parts.
Dual disability can affect both adults and adolescents. For this cohort, Queensland Health wishes to emphasize the importance of the National Disability Insurance Agency (NDIA), regional planners and Local Area Coordinators (LAC) being aware that even though individual disabilities, when viewed in isolation, may not lead to significant functional impairment, the combination of two or more mild to moderate disabilities can result in significant functional impairment consistent with NDIS eligibility. As such, any eligibility determination needs to be made on the basis of the person’s combined disability and the totality of the reduced functional capacity.
Queensland Health also notes that whilst children are not diagnosed as having a psychosocial disability, many children with behavioural issues will be NDIS eligible. Early and seamless coordination of supports between health and the NDIS will assist these individuals to achieve better long term outcomes.
Lack of sufficient disability support for all people with a psychosocial disability will have a detrimental impact upon their mental health and functioning.
Queensland Health is concerned that a lack of support for people living with a psychosocial disability is likely to result in an increase in demand for inpatient and community mental health services. If sufficient community supports are not available to people with psychosocial disability, some individuals in inpatient facilities may not be able to be discharged in a timely manner, again creating access issues for mental health services.
Queensland Health recommends the following actions in response:
Fhe-provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition
e mapping of the supports under PHaMs and PIR with ILC to understand what ILC will replace and what gaps may be left;
e some information of what proportion of PHaMS and PIR funding, if any will be available post-NDIS for the support of people with mild to moderate psychosocial disability;
e some clarity around who will be eligible for any PHaMS and PIR funding not “cashed out”;
e how the Commonwealth “continuity of supports” will work for these programs and individuals;
e clarity from the NDIA around its understanding of the needs of the people with dual or multiple disability and how their support needs will be determined; and
e clarity from the NDIA about what supports children with behavioural issues will be provided, including provision of NDIS support coordination, to ensure seamless coordination with mainstream services.
ey
Term of Reference “e
The Bilateral Agreement between the Commonwealth and Queensland: Transition to a National Disability Insurance Scheme sets targets for the number of people to transition to the NDIS throughout 2016-17.
Queensland Health is aware that the NDIA has had difficulty in meeting these targets to date in Queensland but acknowledges that the NDIS Recovery Strategy has improved
this issue.
Compounding delays in transition are issues with the upload of some data, meaning that, despite Queensland Health providing the necessary mandatory data fields, for example for the Housing and Support Program (HASP), and acceptance by the NDIA in October 2016 of HASP as a “defined” program, HASP clients have not been accorded streamlined entry to the NDIS. In fact in some cases they have not been accepted as meeting NDIS disability requirements at all.
This is resulting in distress for individuals and carers and unanticipated increase in workloads for Department of Health funded Non-Government Organisations and Hospital and Health Services’ staff. Queensland Health acknowledges that there has been a local work around put in place in relation to data upload issues for HASP clients
in the Townsville region.
Whilst faster access and planning is helpful, it must be balanced by impacts upon individuals. Reliance by NDIA LACs and planners on phone conversations with individuals experiencing psychosocial disability does not necessarily take account of the nature of their disability and can severely disadvantage representation of their support needs. As such, Queensland Health is aware that, in particular, the streamlined planning measures in place to process clients more quickly are resulting in considerable anxiety for mental health clients who in general require time to process information and do not necessarily respond well to interactions via telephone.
Most people with psychosocial disability, often due to issues of disorganisation and sometimes compounded by issues of itinerancy and homelessness, also require support from an informed and trusted person (e.g. family member/carer, clinician, Non Government Organisation, advocate) in their planning meeting. This is necessary to ensure development of an NDIS plan that enables them to achieve their life goals and well supported, sustainable and safe community living.
The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition —
Consumers with very severe, complex and fluctuating mental health issues may be additionally disadvantaged by a lack of insight into their disability and/or denial of their mental illness and its resulting impact. Without appropriate supports, particularly in the planning process, these people may be disadvantaged in terms of their support plan outcomes.
Queensland Health also notes the financial impact of the provision of inadequate NDIS packages, as has occurred in North Queensland, where Queensland Health has had to continue to provide ongoing funding support to clients while reviews are conducted.
Suggested actions are as follows:
e improved data upload and faster resolution of issues;
e planners with knowledge of mental health issues to undertake face to face planning and review for those people with psychosocial disability and that this be put in place in all roll out areas as a matter of course;
e that NDIA planners ensure that people with psychosocial disability have appropriate support in the planning process;
e that NDIA provides dedicated experienced planners for patients in health facilities or specialist health services across all areas of disability including mental health; and
e that the NDIA clarify how they will manage funding of supports for people with fluctuating conditions.
Term of Reference “h”
The management of Forensic Order (FO) disability clients in Queensland can occur in two ways: e via an authorised mental health service under the Mental Health Act 2076 to commence March 2017; or e inthe Department of Communities Child Safety and Disability Services (DCCSDS) Forensic Disability Service facility under the Forensic Disability Act’ 2071.
As the DCCSDS facility has limited beds, the majority of FO disability clients in Queensland are cared for by authorized mental health services.
Forensic Order disability clients require supports from a number of stakeholders or service systems both in the community and to transition from the inpatient setting to the community.
Whilst Queensland Health is responsible for the mental health needs of these individuals on a Forensic Order (disability) and also for individuals on a Forensic Order (mental health), it is unsure what the NDIS will fund both for these individuals in the community and/or supporting their transition to the community.
A lack of disability supports, including psychosocial disability supports is almost certain to result in the client being unable to gain the skills required to live successfully in the community and to ensure community safety.
In addition, if sufficient community supports are not in place to address the disability support needs, including adequate support coordination for these individuals and to assist in managing the risk to community safety, individuals are required to be admitted to Queensland Health mental health facilities, again causing access issues for mental health services.
——the-provisior-of services under the NDIS for people with psychosocial disabilities related to a mental health condition
Queensland Health makes the following recommendations in relation to this issue:
e that the NDIA clarifies the supports that it will fund and provide in relation to forensic disability and forensic mental health clients access to and use of community supports.
Wd
Term of Reference “I
The NDIA Principles to determine the responsibilities of the NDIA and other service systems suggest that there is a shared responsibility for complex care clients during transition from inpatient services to the community. However there is lack of clarity (and uncertainty) from the NDIA about how shared responsibility will be operationalised e.g. long term mental health patients who are stable and have a provisional discharge date, will require disability supports during transition, for example, for weekend or part week leave in order to effect a successful and sustainable discharge.
A gradual phased transition to community living for people with psychosocial disability, particularly if they have been long stay inpatients, often requires the provision of mental health and NDIS supports concurrently to ensure integrated service delivery that meets the person’s complex transitioning needs.
Queensland Health considers that terms currently in use by the NDIA such as clients “reaching a point of stability” or “ceasing treatment “are unhelpful when applied in the context of acquiring skills to live in the community.
The NDIA Principles to determine the responsibilities of the NDIA and other service systems also state that “the interactions of people with disability with the NDIS and other service systems” should be as seamless as possible, where integrated planning and coordinated supports, referrals and transitions are promoted, supported by ano wrong door approach”.
Planning and implementing inpatient discharge from either adolescent or adult mental health facilities to community living requires intensive liaison and collaboration between mental health clinicians, funded providers and, where relevant, the NDIA.
Queensland Health is also cognizant of the fact that safe and sustainable discharge for all of its patients with disability requires the existence of a strong, diverse and competent community disability service sector. If NDIS funding does not facilitate the existence of such a sector then Queensland Health is concerned about the impacts that this will have not only on individuals, families and carers but also on the public health system.
The NDIA provides participants with an NDIA unique identifier. Sharing of this number between NDIA, health and perhaps other systems would greatly enhance the ability for an integrated seamless and timely response for mutual clients.
In addition, access to individual’s NDIS plans will greatly enhance coordination between systems. Whilst in the majority of cases health will be able to access, with patient consent, these from the individuals or their families/carers or guardians, there will be some situations, due to illness or circumstances such as homelessness, where the individuals will not be able to provide the information themselves.
It is understood that the NDIS legislation may allow provision of the identifier and information about an individual but this needs to be available in a timely manner to the relevant staff.
The provision of services under the NDIS for people with psychosocial disabilities related to a mental health conaition
Queensland Health makes the following recommendations in relation to these issues:
that the NDIS should clarify what supports it will provide for an individual transitioning out of inpatient care to acquire community living skills (in mental health and other settings);
that there is clarity that a decision as to when a person is ready to commence transitioning (and therefore requires commencement of disability supports during the transition) will be based on expert clinical opinion from the health system;
that the NDIA can demonstrate that the funding for NDIS service providers is sufficient to create and maintain a viable and competent community disability sector;
that the NDIA unique identifier for all Queensland participants is made available to Queensland agencies via a periodic data exchange; and
that there is a mechanism for health providers to obtain a copy of an individual’s NDIS plan in a timely manner should the individual not be able to provide their plan.