27 February 2017
Committee Secretary
Joint Standing Committee on the NDIS - Mental Health
Department of the Senate
PO Box 6100
Parliament House
CANBERRA ACT 2600
AUSTRALIA
Via email:
Re: Inquiry into the provision of services under the NDIS for people with psychosocial
disabilities related to a mental health condition
Merri Health welcomes the opportunity to provide comment into the above mentioned inquiry commissioned by the Joint Standing Commission of the National Disability Insurance Scheme.
Merri Health creates healthy, connected communities through local health services for people at every age and stage of life. Our approach is holistic, addressing the medical, social, environmental and economic aspects that affect health, with services spanning across children and young people, carer support, chronic disease management, mental health, disability support, dental services, population health and aged care. We’ve been the trusted health service of local communities for over 40 years.
General Comments in response to selected elements of Terms of Reference for the Standing Committee which have relevance to Merri Health are detailed below:
Terms of Reference
That the joint committee inquire into and report on the provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition, with particular reference to:
a. the eligibility criteria for the NDIS for people with a psychosocial disability; Comment: Merri Health has concerns that the eligibility criteria for the NDIS for people with a psychosocial disability will exclude a number of the consumers currently receiving services. The need for a statement confirming permanency of psychosocial disability will exclude people who don’t have a formal diagnosis or who don’t currently access a regular health professional that would be willing to make a formal statement around the ongoing state of their mental health. It is important to note that many of our current consumers move between health professionals thus attaining such medical confirmation/assertion can prove difficult.
The eligibility for the NDIS is much higher than for many existing community mental health programs and this in itself will create gaps in service provision, result in poorer consumer outcomes and increase the burden on other health services that may need to respond in the absence of care, i.e. acute sector.
Additionally, the eligibility criteria’s reliance on permanency as well as the definition of mental
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illness as a formal disability does not reflect a recovery-based approach to mental health services and applies a stigma that may increase barriers to access. Many consumers will choose to not access the NDIS as they will not wish to confirm that their condition is a permanent disability.
Accessibility for consumers also needs consideration as current access processes may be quite confronting and difficult to navigate. There is an assumption that individuals with mental health ill health are aware of the service system and have the capacity to proactively engage with appropriate service providers. Furthermore, in order for accessibility to be maximised and enhanced NDIS agents responsible for consumer assessment and planning need to be appropriately qualified and experienced in terms of understanding the complexity of mental health and the cyclic nature of support needs.
b. the transition to the NDIS of all current long and short term mental health Commonwealth Government funded services, including the Personal Helpers and Mentors services (PHaMs) and Partners in Recovery (PIR) programs, and in particular;
Comment: The transition to NDIS in Victoria for mental health consumers has just commenced and whilst we have little direct experience of this on the ground, we have been very active in the transitioning of Early Childhood services and also in the delivery of Support Coordination under the NDIS. Clear observations we have made to date that raise concern for us as a service provider include: a significant percentage of our consumers will not be eligible under current NDIA guidelines and will therefore experience significant impacts on their daily life; those who are deemed eligible may not receive adequate packages to provide the current level of support they receive; the NDIS model doesn’t allow for the flexibility and responsiveness currently possible within PHaMs. For example, having time to develop trust and rapport before commencing work on goals or the ability for staff to visit the consumer in their home or other places which are comfortable to them.
i. whether these services will continue to be provided for people deemed ineligible for the NDIS; Comment: It is pleasing to see the Commonwealth Department of Social Services has publicly stated that current clients will receive continuity of care if found to be ineligible. It is unclear however what the level and length of this care may be. It is our understanding that the amount of funding we are likely to receive for continuity of care will be very small and unlikely to cover the current needs of consumers. Ongoing services for people who are ineligible is a significant concern across the sector and a foreseeable gap that urgently needs to be addressed.
c. the transition to the NDIS of all current long and short term mental health state and territory government funded services;
Comment: Given the large scope of programs identified for transition to the NDIS, the higher eligibility criteria under this scheme and a range of services/consumer cohorts that will not be funded, i.e. carer services, it is concerning that some current consumers of services will fall through the gaps. The NDIS needs to consider a review of the parameters of the scheme to ensure continuity of client care and/or state and Commonwealth governments need to consider alternative funding to ensure these
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cohorts across our community are provided with the services they require.
d. the scope and level of funding for mental health services under the Information, Linkages and Capacity building framework;
Comment: The NDIA has released the Information, Linkages and Capacity Building framework. The focus of this funding is to support the sector and individuals who do not have plans to build their capacity to respond to needs and link with services. This funding will not fund NDIS support items or mainstream services to deliver such supports from identified activities in scope as once had been assumed. It is our understanding that funding is only available for short-term targeted work. Whilst we acknowledge the importance of this work and funding, it is important to note that this service element will not alleviate gaps in service provision across mental health services resulting from ineligible consumers for the NDIS.
e. the planning process for people with a psychosocial disability, and the role of primary health networks in that process;
Comment: The current reform environment across a number of health and community sectors does not assist with a smooth planning transition process. We have to date witnessed inadequate plan approvals across a number of support provisions and inconsistent planning processes and experiences for consumers. One such example is the lack of interpreter use for people clearly in need of this service during the planning process. This can only lead to misunderstanding for consumers and generally an inability to advocate for and explain their personal circumstances and future goals.
To date it is unclear what the primary health network will be funding in terms of mental health and whilst work with the primary health network may provide new opportunities for different forms of support around mental health, it is our understanding that they will not be funding psychosocial rehabilitation-type services; this is the role of the NDIS. The primary health network will seek to provide services for identified gaps in response to local community need and not replicate NDIS service provision and supports. Therefore it is unlikely the total support needs of people who are not eligible for the NDIS in terms of disability support can be met through the primary health network.
Further to this, it is important to note the primary health networks have vast regions to cover and it is questionable whether the resources they have at their disposal are adequate to meet community need.
f. the role and extent of outreach services to identify potential NDIS participants with a psychosocial disability; and
Comment: We are unaware of any NDIS outreach practice currently taking place in identifying potential NDIS participants; however we would strongly advocate for and support this type of service. Accessibility and health literacy for this consumer group is a key consideration, and in order to ensure that the most vulnerable and in need of NDIS support are accessing the service, it is important that a variety of means are used to support access. To date, it appears and is concerning that a lot of the initial NDIS care plans have been undertaken over the phone, we would be suggesting that all mental
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health plans be conducted in person, and preferably in the participants environment of choice. This will assist participants to fully participate at their optimum level in the process.
General Comments: We would like to advocate for two key issues for the NDIS to consider:
1/. In order for the NDIS to more thoroughly meet the needs of people living with mental health illness there needs to be ‘tweaks’ to some of the current processes. For example, more flexible and supportive processes around assessment and planning, and engaging in more extensive assessments around an individual’s experience of their mental illness to allow for the development of more comprehensive and accurate plans. More thorough risk assessments would also be beneficial so that service providers are able to provide the most appropriate service delivery and care;
2/. While the NDIS provides a service delivery model for the most severe and complex people experiencing mental health issues, there is a large cohort of people who will not be eligible and therefore left without vital support. We feel it is so important for both the State and Commonwealth governments to continue to fund a community mental health system that runs alongside the NDIS to ensure that the needs of the community continue to be met and people can access this vital support at an early presentation stage as required to ensure they don’t spiral towards the most severe and complex end.
Merri Health appreciates the opportunity to comment on the Joint Standing Committee on NDIS – Mental Health Terms of Reference and is committed to improving outcomes for clients in our community. Merri Health would welcome the opportunity to further share our thoughts and experience on the challenges and opportunities present with the introduction of the NDIS, in particular clients experiencing long term mental health condition that may or may not be eligible to transition and the implications this will potentially have on these vulnerable members of our community.
This feedback is provided by:
Nigel Fidgeon
Chief Executive Officer
Merri Health
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