Submission to Standing Committee on the Submission to the Joint Standing Committee of the NDIS
The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition
Chris Redmond
27 February 2017
PO Box 35 Woden ACT 2606
www.wcs.org.au Ph: 02 6282 2644
6282 2644 .| ABN 80 527 241 761
Introduction
Woden Community Service (WCS) is a well-established and regarded not-for-profit community organisation that has provided a wide range of services to the broader Canberra community for over 45 years. WCS’s services are flexible, responsive, innovative and person-focused. The services are funded by the ACT and Australian
Governments, the National Disability Insurance Agency (NDIA), Primary Health
Network and fee-for-service.
WCS has been true to its mission and purpose since it was established in 1969. Our values of hope, community, integrity and responsiveness continue to form the cornerstone of every service we provide – from child care to working with seniors. We have a strong, respectful service intent that offers flexibility and choice to people across the ACT and we work with stakeholders to build a vibrant and connected community.
WCS is considered a leader in its field for a range of disciplines. All areas of our organisation have been expanding rapidly over the past five years as we are recognised for the way we work individually and in partnership with government and other community partners.
The diverse suite of services WCS delivers reflects the breadth of the community we work with. WCS has three main service areas, Children Youth and Family Services, Social Inclusion Services including ability services, and Mental Health and Housing Services. It has a vibrant volunteer program to support the work of the organisation and is developing a strong peer workforce in some areas. WCS is also a provider of National Disability Insurance Scheme (NDIS) services. Services are: Children, Youth and Family Services - case management, youth engagement
and Network Coordination
o OneLink – ACT Government’s Human Service access gateway
o Children’s Services - Early Childhood Education and Care, Outside
School Hours Care, Family Day Care, Paint and Play, Multicultural Paint
and Play
o Community Development
Social Inclusion
o Ability Programs - support and NDIS services, NDIS Plan Coordination
o Commonwealth Home Support, Community Transport, Assistance with
Care and Housing for the Aged, Social Groups
o Settlement Grants, Volunteers, The Big Issue
Mental Health Programs - Transition to Recovery, Personal Helpers and Mentors
(PHaMs), Partners in Recovery, Beyond Blue’s The Way Back Service, NDIS
Recovery Services
Supportive Tenancy Service, Tenancy Options, Canberra Living Conditions
Network - including work in Squalor and Hoarding
WCS has worked to integrate our services as we acknowledge the interface of issues within people’s lives that create complexity and vulnerability. WCS believes that it is the responsibility of the provider to manage the complexity of the service system to provide greater ease of access and improved outcomes for people accessing those services.
Collaborative service partnerships have underpinned WCS’s service delivery over the past 10 years, acknowledging that when organisations work together better outcomes can be achieved by leveraging the diverse capabilities of each organisation. WCS enjoys service partnerships with Belconnen Community Service (BCS), the YWCA of Canberra and Anglicare in the delivery of child, youth and family and tenancy support services. WCS also has a partnership with the ACT Health Directorate’s Mental Health Justice and Alcohol and Drug Service for the delivery of mental health services.
WCS mental health programs provide a well-regarded, quality mental health service delivering a stepped continuum of care including the Improved Access to Psychological Therapies (IAPT) coaching program for people with mild to moderate mental illness (PHN funded), a step up step down outreach service, Partners In Recovery, Personal Helpers and Mentors, NDIS Recovery services and more recently beyondblue’s Way Back service working with people who have attempted suicide.
WCS’s mental health services are accredited against the National Mental Health Standards by the Quality Improvement Council.
WCS and the NDIS experience WCS has been actively involved in the whole of jurisdiction transition to the National Disability Insurance Scheme for our Ability Services and for those with Psychosocial Disability (PSD). To date the ACT is the only whole jurisdiction to have transitioned. The ACT was a trial site and, as such, experienced all the permutations of service trials that could be imagined – of what we were allowed to do and not allowed to do; and then allowed to do what we weren’t previously allowed to do!
Our experience has been that PSD was very much an afterthought for the NDIS and while advocates argued strongly for its inclusion, it is still very apparent that the scheme is focused on physical and intellectual disability.
Overall WCS considers the NDIS to be cloaked in deficit oriented language which reinforces the negative aspects of disability and encourages people to present themselves as disabled to receive support despite their own efforts at creating fulfilled and enriched lives.
The NDIS trial process in the ACT had lent itself to many changes during transition which has led to significant inconsistency across every facet of the scheme – engagement with the NDIA, responses from the NDIA, interpretations of advice and, most importantly, inconsistency of plans. This plan inconsistency has left some people with generous and effective support budgets, while others with similar disabilities have received very poor plans without any rationale for these outcomes.
As an organisation using a recovery focused approach to mental illness and service delivery WCS has sought to continue and develop this approach through the NDIS framework and have invested significant human and financial resources to make it work. This has included accepting 14 clients from a service (funded through HASI/HARI) that was ceasing six months early as they changed their service model due to NDIS and needed another agency to take up their clients (of many years).
WCS was also very mindful of the cessation of Commonwealth funded programs, such as Personal Helpers and Mentors and Partners in Recovery, which closely works with people through care coordination, peer support and therapeutic interventions. Through the NDIS Recovery model WCS assisted people from these programs with NDIS access and planning and now provision of support coordination and plan delivery.
The service and financial risk has been left squarely at the feet of the service provider, particularly given the inconsistency of plans. The service risk is presented through lack of communication from the planner and through the client. WCS believes the introduction of the scheme has shifted the financial burden to service delivery agencies.
In the PSD stream NDIS is not structured to support the notion or practical reality of “recovery” which underpins the essential work undertaken by community managed mental health services in assisting people towards greater levels of self-reliance and social and economic participation. The NDIS has fragmented people’s illness to scheduled items and “core supports” which encourages dependency rather than independence and has delegated itself as arbiter of people’s level of support needs over time. WCS’s view is that the NDIS shouldn’t be the only pathway for people who have good prospects of leading participative lives.
Responding to the Terms of Reference
a) Eligibility Eligibility has a number of applications in NDIS – eligibility for the scheme, eligibility for appropriate scheduled items, eligibility for capacity building activities (once eligibility for the scheme has been established).
WCS’s mental health recovery services all work from a strengths based approach with a strong focus on recovery. WCS is concerned about the NDIS focus on the notion of permanence, especially for people with psychosocial disabilities. This is due to the fact that while most of these conditions, particularly schizophrenia and bipolar disorders, are permanent conditions, if they are well managed clinically and the appropriate personal supports are in place people are able to lead contributing and meaningful lives.
in testing eligibility for NDIS people must describe their deficits and the debilitating effects that the condition has on their lives. This in itself is a demeaning introduction to the scheme which doesn’t encourage a description of what people have done to overcome their conditions. Moreover, people feel that if they present too positively, they won’t receive the supports that they need. So they must dwell on and go into great detail about the limitations that mental illness imposes on them, rather than focusing on what they can do with support. This access model is totally at odds with best practice recovery approaches.
Not only are the Access Request Forms (ARF’s) deficit focused, the time delays in decision making regarding eligibility causes much anxiety for potential NDIS applicants. This is exacerbated when people who have been living with a mental
illness and have been receiving services from community managed and clinical services are rejected for the scheme!
From a mental health perspective NDIS is incompatible with “recovery” which is a key practice principle of most mental health and clinical services. A recovery approach maintains that people living with a mental illness can manage their condition to live a fulfilled and meaningful life with the appropriate clinical management and community supports. It also means that people can live independent lives, not dependent upon services that absolve them from responsibilities of daily life, such as caring for themselves.
Case Study-PHaMs Participant
Process of determining eligibility In 2016,a WCS Personal Helpers and Mentor (PHaMs) staff member worked with a PHaMs participant, John (not his real name), to assist him in transitioning to the NDIS. We submitted his completed Access Request Form in person to an NDIA office on April 05, 2016. According to the NDIS website “The NDIS Act requires the National Disability Insurance Agency (NDIA) to make a decision or request information within 21 days of receiving a complete access request”. We did not receive confirmation that John had been granted eligibility until October 10, 2016. My participant waited over six months with no clear explanation as to the delay.
During this waiting period we made numerous attempts to find out what was happening with his application. John personally made phone contact with the NDIA on several occasions and was told that his application was still being processed. The WCS staff member contacted the NDIA at least five times by phone and two times via email to find out what was happening with John’s application. My phone calls and emails were either not responded to or I was told that the application was still in progress and to reassure my participant.
On one occasion, I received a phone call from the NDIA on the 29/07/2016 stating that they were returning my phone call from 04/07/2016. John also enlisted the support of a worker at Gugan Gulwan Youth Aboriginal Corporation and they assured John that they were going to escalate his case within the NDIA. The Mental Illness Fellowship program My Voice, My Choice was also involved with John and they too struggled to find out any further information. In August 2016, My Voice, MyChoice were informed that the NDIA held no record of John’s ARF. The original (date stamped) ARF was then resubmitted. Nevertheless, no response was received until October 10, 2016.
Impact on PHaMs Participant The participant has a long history of feeling let down by services and alienated from the community due to his disability and Aboriginality.
This unsettling limbo situation with his NDIS eligibility determination left John feeling cynical of ‘the system’ and of achieving his recovery goals. I witnessed his levels of depression, anxiety and disconnection increase during this time.
Planning Process
John and I became aware of his planning meeting one day before it was scheduled. John was willing to proceed, however, and the planning meeting went smoothly.
John, his carer, and the WCS staff member were able to articulate his goals and complex needs adequately in this meeting. John stated that he required assistance to reduce social isolation and to build his skills and capacity in a wide variety of areas: job searching, using computers, life transition planning and developing independent living skills.
John’s First Plan
John received his first NDIS plan in early December 2016, eight months after applying for eligibility. Unfortunately, after waiting so long, the completed plan is inadequate and does not provide the reasonable and necessary supports to meet his complex needs and to address his recovery goals.
There is no budget in the plan for skills and capacity development. There is no budget to support him to find and keep a job, to access therapeutic support, to help him build independent living skills and to mentor him through life transition planning. The budget in John’s plan does not address his stated goals, improve his independence, build his capacity or suitably enhance his economic participation. It leaves him in a disadvantaged position when compared to the support that he received as a PHaMs participant. We have applied for a review of his first plan.
John’s NDIS Experience
John is motivated and has the potential to be an active participant in his psychosocial recovery with the right level of support and intervention. Unfortunately, John’s first plan and budget does not match the discussions that took place in his planning meeting. His transition from the PHaMs program to the NDIS has been long, arduous and disheartening for him.
b) Transitions from Commonwealth Programs WCS delivers two Commonwealth Government programs that have been cashed out to the NDIS – Personal Helpers and Mentors program (PHaMs) and Partners in Recovery (PiR). The former was introduced by the Howard Government in 2008 and was intended to by a long term program that assisted people with severe functional limitations due to persistent mental illness by building enduring supports for people throughout their lives.
WCS is involved in a consortium to deliver PiR services – led by the Primary Health Network and five community organisations. PiR focuses on care coordination for people with severe mental health conditions to access a broad range of services to support their independent living.
WCS has been “transitioning” participants from both programs into the NDIS. As explained earlier WCS also supported 14 people from another service who were considered to be eligible for NDIS (prior to testing their eligibility). WCS has been working with participants in all three programs to assist them to test their eligibility, undertake preplanning, participate in the planning process and advocate for internal reviews of plans that do not meet reasonable and necessary support needs, or indeed breach the “no disadvantage” commitment of the NDIA.
The transition of services confirmed to WCS that PSD was a poorly considered scheme “add-on” that didn’t readily fit the scheme’s architecture, despite (undoubtedly good intentions) some of the best people working on it (Eddie Bartnick). In reality, due to the ages and stages roll out of the ACT transition, people with PSD have been the last to transition to the scheme in the ACT which we believe also reflects the challenge of PSD within the scheme’s framework (it has also led to extended decision making periods within the NDIA).
The eligibility and planning processes for people with PSD is overwhelming – the name itself (disability insurance scheme) does not readily lend itself to people with a mental illness and for this reason people with PSD do not think that it refers to them. The requirement of people to test their eligibility has created anxiety for them, the process of testing, the wait for the outcome and if accepted the planning process which requires them to list their deficits and identify the supports required. Perhaps the biggest anxiety provoking challenge is dealing with the NDIA bureaucracy, the inexplicable letters, the preplanning, the face to face planning meeting and then the follow up once the plan has been approved – does it reflect the supports identified? If not, the review/appeal process that may need advocacy.
Just understanding the complexity of the system is overwhelming for advocates and clients alike, as is understanding the power imbalance between the arbiters of the scheme (planners) and their understanding of PSD and its application to people’s lives. This has been exacerbated in the ACT due to our “trial” status where processes have changed regularly without notification or explanation.
Community managed mental health service staff have been vital in assisting people through all the NDIS processes, even though it was not initially part of their work. The role of staff changed frequently throughout the trial especially in attending planning meetings and in advocating for substandard and inconsistent plans. The workers often bore the brunt of the planner’s displeasure for their determined advocacy in light of inconsistent plans that were not focused on client choice and control. The transition of people into the scheme would have been impossible without the support of workers, however the frustration of staff has risen due to the increasing tightening of processes and decision making by NDIA staff.
Given the nature of the work in the mental health and recovery sector the skills set and qualifications required of staff are high, especially given the level of interaction with participants, focused on recovery through, in many instances, incidental therapeutic intervention. The fragmented nature of the NDIS, particularly into itemizing supports required, will see the loss of workforce skills and a diminution of the focus on recovery and rehabilitation. This is the opposite of what is required in the mental health services area, both clinical and community managed, which is undergoing a significant period of growth as the issues of mental health become more prevalent in the community.
The loss of Federal, State and Territory funded services through the cashing in of previously earmarked mental health services, such as PHaMs, PiR and Carers Respite and the decision of State and Territory Governments, such as Victoria where the previous government decided to cash out most of its funded services to the NDIS, has
left a huge hole in the service delivery continuum for people with illness. There are now fewer options for people and for service to refer to for support. The advent of the NDIS has drawn resources away from alternative service options or limited those options within existing services as organisations prepare for and deliver NDIS services. Group and community gathering options are rapidly closing in the ACT, reducing opportunity for social participation. “Market based” services will become the focus of service delivery as organisations seek to maintain their financial viability.
As a result the market is driving services away from recovery and rehabilitation principles and practices solely to pursue financial stability – the community is under threat of losing key service skills, especially in the PSD sector - to organisational survival.
The extension of the PHaMs program, while appreciated, only really delayed the inevitable, however it has supported the transition and the transference of expertise and knowledge about participants to new NDIS programs.
While the ILC held hope for people ineligible for NDIS this is no longer proving to be the case. There is a substantial gap in service for people ineligible for NDIS that needs to be addressed as a matter of urgency. It must also be noted that there are also people who are not appropriate to transition due to their perceptions /views of the NDIS or the impact of their conditions that prevent them from wanting to engage with the scheme.
Communication with the NDIA has been a significant issue for community managed organisations. The NDIA can be characterized as a “black hole” in which information is sucked into and no response ever comes out. WCS has had numerous meetings with NDIA staff, including regional managers, providing them with information outlining concerns with the scheme, rarely receiving responses to our inquiries.
c) Transition from Territory Government program WCS assumed responsibility of an ACT Government funded program that a service had decided to quit prior to the end of the funding period – a HASI program that supported people with care coordination, housing, community access and clinical services. The service was relinquished prior to participants transitioning into NDIS. They have significant and complex mental health issues and required extensive support to transition into the NDIS which took much longer than expected by the funding body.
As a result the program underwent a forced closure with limited funds to support participant transition. WCS was left with the financial responsibility of supporting these participants to allow for continuity of their supports while appropriate NDIS funded supports were in place. WCS worked with the NDIA to establish plans while people were stepped through the eligibility and planning process. The NDIA was responsive at this time and established a specialist team to assist with the development of complex PSD plans. This team has since disbanded after only a short period.
The “mirrored plan process” was needed for a few of these participants who we were clinically advised not to engage in the process directly due to the nature of their
mental illness, but needed to get into the scheme for continuing support. The process was confusing and inappropriate for clients as it did not result in the same level of supports of clients. It was equally confusing for services who not only had to advocate for the mirrored plans but also had to work with the NDIA around eligibility and planning process for clients with clients who had no idea what was going on or why they had to comply with the NDIA when they were already receiving services.
d) ILC for PSD The announcement of the ILC grants and the subsequent information sessions have demonstrated the complex application process which seems to be a deliberate attempt to dissuade organisations from applying for very limited funds. WCS has argued to the NDIA that the ILC process should have been the first tranche of the scheme which would have engaged people with PSD in a range of capacity building activities, particularly community engagement which would have lessened their reliance on a funded plan.
See Attachment 1 – Letter to Minister re Local Area Coordination
e) Planning Process The planning process has continued to change throughout the roll out in the ACT, particularly for people with psychosocial disabilities. Initially support workers were welcome to planning sessions, then they weren’t. There were times when workers were permitted to attend however not say anything. Planners had follow up sessions with clients following plan development, they now email the plan to the client and if there isn’t agreement about the plan the client must now request a review which can take up to three months or more.
The planning process is incredibly time consuming for clients and service providers. For clients, they must first agree to test their eligibility and therefore accept that they have a disability and agree to engage with government bureaucracy regarding their conditions and their personal lives and consent to allow the NDIA to hold information about them.
For this to occur, they must first understand the nature of NDIS and what it means for them. This usually requires continuing conversations, continual encouragement and support and ongoing work regarding the preplanning phase, working with clinical services regarding information for their plans and support through the planning process.
All this work is unfunded – of course some of it is covered by people who are in block funded program, however there are many who are not. Much of this work falls to the support worker as there often aren’t families or support networks around clients experiencing mental illness.
The preplanning and planning process take over 10 hours and in some cases more. The planning meeting with the planner only takes 50 minutes. It is apparent that there is significant cost shifting to the not for profit sector through this process.
It is also very difficult to plan for the episodic nature of people’s illness – WCS has found that funds are insufficient when a client experiences a sudden change in their condition and require additional support. An example of this was a client “disappearing” for a number of days and hours were spent trying to find her. She was eventually located in a regional NSW mental health unit. We had spent 15 hours trying to find her – she only has 15 hours per year on plan coordination which would have been expended just on this activity.
See Attachment 2 – Letter to Minister re Plan inconsistency See Attachment 3 – Letter to Minister re Capping numbers in ACT and NDIA response
Consistent planning requires consistent planners – WCS’s experience of NDIA planners has been less than satisfactory as they have changed regularly and sometimes not completing the plans they have commenced. In the PSD area we requested dedicated PSD experienced planners, particularly with one set of clients with profound mental illnesses. Originally the NDIA did establish a specialised team to work with this client group however this was short lived and reflected the lack of leadership commitment to this group. The Regional Manager who possessed extensive experience in mental illness moved on and with her the commitment to targeted PSD plans.
The lack of planners’ PSD experience also affected the planning process and overall quality of plans. WCS has devoted much time into developing our knowledge of the NDIS to allow greater advocacy for clients through the preplanning and planning process to set goals which are well supported by the plans. Sometimes this has included recommending plan management rather than agency managed plans as this often gives people greater flexibility in their activities. We were accused by a planner of recommending this as we stood to make money out of the arrangement. We complained about this claim made by the planner (twice) and have not received a formal response from the NDIA, despite writing to the national office.
The plans that are now being created, based on computerized bench marks, do not appear to be consistent. At one stage WCS was informed by a planner that the computer would be generating the plan. We have presented the NDIA with comparative plans for different people with very similar psychosocial disabilities which demonstrate the wild variation in funding for clients. The NDIA did offer to forward this information onto their quality team however again there has been no response to this inquiry.
See Attachment 4 – Comparison Table
The plan review process that has been recently instituted, without any consultation, is an insult to clients and providers alike. The plans have incredibly reduced plan coordination and capacity building hours. The plan coordination hours are essential for maintaining the consistent delivery of service through close engagement with clients reliant on support coordinators, particularly at times of crisis.
There has also been a significant reduction in plan capacity building activities which support people to become more independent and over time will lessen their reliance
on NDIS funding. However there has been an increase in core funds for services, such as cleaning and shopping that only create reliance on ongoing funding.
Other related matters not in the list from the TOR
Despite all the negative experiences with the NDIA and NDIS there are many positive examples of the impact of good consistent planning with appropriate funds to support the goals set by clients. WCS is involved in many wonderful outcomes for people with NDIS plans and can see the potential of what a “good plan” can achieve for someone living with a psychosocial disability. Having a reasonable spread of funded activities, including a focus on capacity building activities, allows the participant and the provider to keep a recovery focus to the support provided.
WCS is concerned about the inherent risk to support worker staff that is created by the NDIS processes and funding constraints.
When taking on a new participant there is no communication from the NDIA of the potential risk that clients might pose to support staff. For example, when the agency receive the plan and agree to work with a participant there is no background information provided. WCS may have no idea if there may be substance use or violence presenting, and now need to work this out ourselves. This would never happen in the clinical system. Plans also do not include or afford ‘two support workers to attend’ policies which most agencies have in place when assessing new clients. This can potentially put workers in dangerous situations.
WCS is also concerned that the NDIS is starting to diminish quality service provision due to the pricing schedule. Direct service delivery must now be provided by staff on lower wages and hence lower skills than were previously experienced in a block funded system. Block funded schemes allowed for the training of staff and in the ACT mandated that all staff delivering ACT Government funded services have a Cert IV in Mental Health. This is not a requirement of NDIS funding. This is leading to the recruitment of support workers with lesser qualifications and thus the requisite skills and places both staff and clients at greater risk. The NDIS pricing schedule also does not allow for the same level of supervision of staff to ensure adequate support for them and in exploring ways to better engage and support clients.
The NDIS puts increasing burden on clinical services when a participant becomes unwell. Support workers are not trained to work with these situations whereas in PHaMs and PIR they may have been able to avert a crisis or provide increased therapeutic intervention due to their skill sets. Best practice psychosocial service delivery is strongly focused on recovery principles and practice. The NDIS helps to provide much needed psychosocial supports but it does not easily support a recovery approach, fragmenting people’s lives into scheduled items and activities.
Transport is another area that has been neglected by the NDIA. Provision of transport support in plans in this area is totally inadequate for this target group who often live highly socially isolated lives, who are anxious, particularly in public and need support, encouragement and transport to get out and engage with others.
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Attachment 1
Hon Christian Porter MP
Minister for Social Services
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600
Cc Jane Prentice, Assistant Minister, Andrew Barr, ACT Chief Minister, Jenny Macklin
Shadow Minister
Dear Minister Porter
I am writing to express my deep concern at the NDIA decision to transfer support coordination from NDIS registered providers in the ACT to the Local Area Coordination service provider. This decision is yet to be confirmed and the LAC provider is yet to be announced in the ACT.
This is another example of the poor consideration of providers by the NDIA and the ongoing changes that providers have had to manage in a chaotic two year transition that has had a marked effect on the local service network. The ongoing trial of the NDIS in the ACT is starting to reflect market failure and this latest decision is a further indicator of the demise of registered providers.
It was only last year that the ACT NDIA was requesting providers to take up support coordination as individuals and families were struggling to activate their plans due to lack of knowledge of registered providers and their ability to navigate the new service landscape. This resulted in appropriate plan coordination hours, particularly for people with complex disabilities including psychosocial disabilities.
Individuals with co-occurring psychosocial disability and complex needs who were allocated 100 hours and over for support coordination for the year in their first Plan are now receiving significantly reduced hours for the same service after the plan review. Supporting complex psychosocial disability requires sophisticated, flexible and responsive coordination that also appreciates the episodic nature of mental illness.
Recently a WCS Support Coordinator took more than five hours in a single day attempting to intervene appropriately and get clinical support for a client experiencing an acute episode of mental illness (not to mention the administrative work afterwards). There were several similar episodes of acute illness and points of crisis to resolve over subsequent weeks effectively exhausting this client’s coordination hours. Coordination is a significant component of Capacity Building in psychosocial disability and the NDIS. It requires competent, skilled, qualified and experienced staff who can win the trust of their participants to navigate the labyrinthine nature of the new and emerging NDIS service sector.
I believe that government has an obligation to promote business confidence in such a new and emerging sector – instability and low morale is rife within the sector due to the constant shifting of the goal posts. The rumours and strife that have been allowed to occur is reprehensible given the vulnerability of people with disability and the orgs that are trying to provide services to them.
Support coordination is the only aspect of the NDIS that is in anyway cost neutral to organisations – whilst the NDIS is a great social innovation for many people living with a disability; it is a financial risk being carried by the community sector which will lead
to market failure. This was acknowledged by David Bowen at the recent NDS CEO conference.
I believe the decision to transfer support coordination to the LAC is contrary to their role that was promoted in the ILC consultation process. It is also contrary to their traditional role of connecting people to natural supports in their community. The decision is focused on delivering a financial efficiency for government by taking this critical role away from people who are actively engaged in the lives of people with a NDIS plan.
The LAC service is being gifted a service advantage that service providers have worked to develop in delivering support coordination. This is another factor contributing to NDIS market failure. This approach will only lead to greater fragmentation of service for individuals. A more appropriate role for the LAC would be in assisting people to develop and activate their plan by identifying an appropriate support coordinator and working with the support coordinators to ensure the delivery of plans, including appropriate service providers.
While I am sure that such market failure was not intended as a result of NDIS. However, the impact of such decisions as these for organisations, who have the welfare of people living with disability as a core component of their values and service delivery and who have borne the financial burden of the transition to the choice and control model, is significant.
I request a reconsideration of the decision to transfer support coordination to the Local Area Coordination service.
Yours sincerely
Chris Redmond
CEO
Woden Community Service
23 December 2016
Attachment 2
Hon Christian Porter MP
Minister for Social Services
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600
Cc Jane Prentice, Assistant Minister, Andrew Barr, ACT Chief Minister, Jenny Macklin
Shadow Minister, Rachael Stephen-Smith MLA, Shane Rattenbury MLA
Dear Minister Porter
I am writing to express my deep concern at the inconsistency of NDIS plans (Plans) that are being developed by NDIA planners that create significant disparities for people using the scheme to improve their lives. This issue underlines the apparent trend to minimise budgets for capacity building activities in Plans for people with psychosocial disabilities while increasing core budgets.
Woden Community Service (WCS) supports the introduction of the NDIS and the opportunity it provides people to improve their life outcomes. However, the inconsistencies in Plans and the reduced levels of capacity building in reviewed Plans will mean that people may not receive the range of assistance and higher level skill development required to allow them to live the lives that the NDIS would aim for them to achieve.
This issue of the inconsistency of Plans has been raised by WCS with the ACT NDIA office, accompanied by a table of comparisons that demonstrates the disparities for people with similar disabilities, particularly in the area of psychosocial disability.
While WCS has not received a response we did undertake to provide the NDIA’s Quality Team the comparisons for consideration and planner decision making. I have since heard that a planner referred to a computer generated plan which seems to indicate that the human element has been replaced altogether in the plan decision making process. Having said that, one of the Planners on the Psychosocial Team here in the ACT has had significant experience working in the community managed mental health sector (including PHaMs). He has managed with our input to issue Plans that are flexible, responsive and which recognise the high level of PSD, complex needs and level of coordination needed, particularly for higher levels of crisis resolution in the cohort of NDIS participants we support. On the other hand, given how often we receive Plans that are manifestly inadequate on all accounts, this does seem to go to the competence or inexperience of NDIA Planners rather than something that can be blamed on a computer program.
What has been disconcerting and a source of frustration for providers however, since the beginning of the new financial year, seems now to be developing into a serious trend. The NDIA seems to be squeezing participants with psychosocial disabilities of funding for capacity building and appropriate levels of support coordination with its additional function of resolving points of crisis. Recent plan reviews received have significantly reduced capacity building activities while often increased core activities. This is counterintuitive. In the realm of PSD it should be the reverse. Increased CB in the initial years should enable core supports to be reduced over time because of the recovery focus and increased opportunities for skill development and participation.
We do hope this is not the trend and a sign that the NDIA is not giving up on the hope of people living full and contributing lives despite perhaps ongoing symptoms of PSD. We do not want to see the NDIS render people with PSD dependent on personal
assistance and domestic support services (with some community access activities) with little hope of recovery.
One example of note concerns a Plan recently received for a 22 year old man who had an extraordinary$96,000 for core supports but only $4,600 for capacity building activities. From a purely actuarial perspective, this young man has years of earning capacity ahead of him and he would prefer to work, however the plan does not recognize this potential but only seems to emphasise his disability.
This is a serious flaw in the scheme for people with psychosocial disabilities – complex lives that do not fit the scheme as it was originally intended.
I request an urgent review of the scheme’s approach to assisting people living with a psychosocial disability as it is creating a dependence on the day to day needs of people without using the opportunity to change their life trajectory which is aligned to the choice and control mantra of the NDIS.
Yours sincerely
Chris Redmond
CEO
Woden Community Service
23 December 2016
MC17-000034
GPO Box 700
Canberra ACT 2601
1800 800 110
ndis.gov.au
Mr Chris Redmond
Chief Executive Officer
Woden Community Service
PO Box 35
WODEN ACT 2606
Dear Mr Redmond
Thank you for your letters of 23 December 2016 to the Minister for Social Services, the Hon Christian Porter MP, about National Disability Insurance Scheme (NDIS) plan consistency and support coordination. The Minister has asked me to reply to you on his behalf.
With regard to plan consistency, | can confirm each NDIS plan is individually developed, taking
into consideration an individual’s needs and access to informal and mainstream supports, and is informed by the evidence made available to the National Disability Insurance Agency (the
Agency). It is anticipated there will be variation across participants’ plans. As | am sure you
can appreciate, each person has individual circumstances that must be considered and functional capacity and support needs may differ even where participants have the same diagnosis.
| can also confirm the Agency does not have a directive to reduce capacity building funding
whilst increasing core funding. This would be, as you mentioned, counterintuitive to maximising a person’s capacity and independence.
In relation to support coordination, where there is evidence a participant requires a higher level of support, the Agency can consider funding support coordination or specialist support coordination.
Support coordination refers to assistance to strengthen a participant’s abilities to connect to and coordinate informal, mainstream and funded supports in a complex service delivery environment. This includes resolving points of crisis, developing capacity and resilience in a participant’s network and coordinating supports from a range of sources.
Specialist support coordination refers to the provision of support coordination within a specialist framework necessitated by specific high level risks in the participant’s situation. This support is time limited and focuses on addressing barriers and reducing complexity in the support environment, while assisting the participant to connect with supports and build capacity and resilience. It may also involve development of an intervention plan, which will be put in place by disability support workers.
The Agency has also engaged Local Area Coordination (LAC) Partners via an open and transparent tender process. The aim of LAC Partners is to provide core NDIS functions, as an extension of the Agency itself. LAC Partners provide support coordination at the level of ‘support connection’, which is time limited assistance to strengthen a participant’s ability to connect with informal, mainstream and funded supports, as well as, to increase capacity to maintain support relationships, resolve service delivery issues and participate independently in Agency processes.
Delivered by the
National Disability
Insurance Agency
Participants who receive LAC Partner supports will not receive funded support coordination, as this would be deemed a duplication of supports.
You have described circumstances where NDIS funded support coordination is quickly exhausted during an acute episode of a participant’s mental illness. The Agency would expect that with the timely and appropriate engagement of relevant state health services, this should not generally occur. It it vital to a person’s wellbeing and recovery that the appropriate clinical support is accessed via the health system in a timely manner to review, treat and stabilise the illness. This is a mainstream support and remains the responsibility of the health system. Funding under the NDIS is designed to compliment mainstream services, not replace or duplicate these supports.
Thank you for bringing your concerns to the Minister’s attention.
Yours sincerelv
Christine Faulkner
General Manager
Operations Division
41 February 2017
Page 2 of 2
Attachment 3
Hon Christian Porter MP
Minister for Social Services
PO Box 6022
House of Representatives
Parliament House
Canberra ACT 2600
Cc Andrew Barr, ACT Chief Minister, Jenny Macklin Shadow Minister
Dear Minister Porter
I am writing to you to express my extreme concern at the recent National Disability Insurance Agency (NDIA) announcement of capping the number of people in the ACT with NDIS plans at the bi-lateral agreement level of 5075, and the uncertainty this has created. Although we are aware that there are now further announcements encouraging people to still apply and continue with planning, and that there are now negotiations underway to clarify further funding, we are concerned that this will still create a blockage for future participants while these negotiations are underway, and that this event has seriously eroded the public’s confidence in the scheme. As the transition to the scheme is underway it is important that there is a sense of trust in what it can and will offer people with a disability.
The ACT is a whole of jurisdiction trial site and has experienced the highs and lows of that distinction – we have been trailed for every possible permutation that the NDIA wanted to test, and have had systems and processes constantly changed making it very difficult for us to plan. The PRODA debacle left agencies unable to bill for services for some two months, left a backlog of unapproved plans and the decision not to back date plans that were held up by the PRODA, left many providers out of pocket as they continued to fund participants in the interim. This recent announcement is another of these oversights and could create a similar pressure on service providers as they continue to support people until plans are again approved.
The recent announcement particularly highlights the difficulties for people with psychosocial disabilities, who have been amongst the last to transition into the scheme, which really hasn’t been designed for them.
The scheme is intended for only 10 per cent of people living with a mental illness, those at the more severe end of the spectrum with need for regular psychosocial support. In the ACT this cohort have proved to be the most difficult to engage in the scheme with most transitioning in the last six to nine months (January – September 2016) due the ACT ages and stages roll out, and many still to build the confidence to agree to commit. For some their engagement with the eligibility and planning process has been protracted leaving uncertainty about the scheme and the Agency’s ability to respond appropriately to their requirements. Some are still awaiting the outcome of their eligibility request made months ago.
We are also concerned about the mental health participants who have previously been supported by block funded programs that are now being rolled into the scheme (Personal Helpers and Mentors Program and Partners In Recovery), but who are not eligible or inappropriate for the scheme. These people still have no certainty about where their future supports will come from and this is becoming a glaring gap in service as existing services close.
Can you please act with urgency on negotiating this capping issue in the ACT, for the benefit of all participants and for the future success of the NDIS. For the ACT this has been just another lesson of being a trial site.
Yours sincerely
Chris Redmond
CEO
21 November 2016
NDIS Plan comparisons of participants in our service with complex and enduring mental illness and co-occurring conditions Attachment 4 Approx budgeted Hrs per week
Capacity
Ag Co-
gender building Core Notes
e ordination (CB)
1 30 Male 3 14 8.5 Formerly a HASI/HARI participant and institutionalised for over a
year, this Plan is flexible and responsive and recognises high level of PSD, complex needs and level of coordination required. The Plan has helped the transition from BHRC to a suitably situated and safe Public Housing tenancy and will assist XX to build on his independent living skills, access to services in the community and mainstream services to address complex health and mental health issues and increased social and community participation. This plan has enable XX to improve daily living skills, sustain his tenancy and increase social & community participation. Family members have stated that XX has never had the quality of support and level of services he now enjoys.
2 35 Male 1.25 5 2.8 This Plan does not meet the “no disadvantage” commitment of
the NDIA, XX was a HASI/HARI participant, has multiple health and mental health issues very similar to 1. above.
3 47 Male 2 12 14 A Plan that is flexible and responsive and recognises high level of
PSD, complex needs and level of coordination needed, given need for higher levels of crisis resolution. XX has complex mental health and co-occurring conditions of substance use, physical health and cognitive dysfunction. This plan has enabled workers
to assist XX to address severe squalor issues and improve personal hygiene and other daily living skills. As a consequence social participation has improved also with the level of assistance provided.
4 39 Male 2 1 8 The majority of work required here is in CB and coordination.
Should be like 1 and 3 above. Does not meet the no disadvantage commitment of the NDIA. Does not recognise level of PSD and complex co-occurring mental & physical health and AOD issues. Does not recognise the high level of crisis resolution required.
5 25 Female 2+ 8.5 5 Mild/moderate ID with co-occurring schizophrenia. Plan allows for
$1000 establishment for community access & community & social activity cost and a separate budget for 2 weeks of respite accommodation. This Plan also has a generous “Improved Daily Living” (therapy services) and “Health & Wellbeing” budgets to meet therapeutic needs.
6 53 Male 1.2 0 10 Mild/moderate ID with co-occurring paranoid schizophrenia. Very
isolated, paranoia and agoraphobia and other post-traumatic symptoms. Attends our CB groups. Has a worker from clinical service doing several activities which will cease with new model of care. This Plan doesn’t recognise CB potential given willingness to engage.
7 35 Female 2 2.6 14 So much potential with this participant to build capacity – so little
recognition of level of PSD in Plan – should be more like 5. above
8 51 Female 1.9 0 9.3 This Plan doesn’t recognise the complexity of the work required to
coordinate the multiple co-occurring issues involved. Does not recognise high level of PSD and complex co-occurring mental &
physical health and AOD issues. Does not recognise the high level of crisis resolution required and risk involved.
9 55 Female 0.5 4.6 1 Schizophrenia, social anxiety, extreme isolation. This Plan doesn’t
support the complexity of this participant’s issues, the high level of coordination dependency and is not sustainable. A seriously inadequate Plan with little understanding of the needs of XX, despite all the information provided to the Planning process
10 53 Female 1.5 0 7.3 Complex OCD and chronic isolation. No Coordination, no CB
Support budget, so little prospect of working on greater self-reliance and Connecti increased participation. A poorly put together Plan with little on understanding of XX’s needs.
11 40 Female 1 2 30+ While this Plan has a generous Core budget, the Coord budget in
s no way recognises the sheer complexity of implementing this Plan, and the complex and multiple co-occurring issues involved. Resolving points of crisis would be a high requirement if services are to succeed for this person.
Sustainable Plan likely to succeed in goals and building capacity for greater independence from services in future
Poorly allocated budget areas, unsustainable and at risk of failing to meet goals or sustain engagement
Poorly allocated budgets, unsustainable and at serious risk of failure
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