Submission to the Joint Standing Committee on the NDIS on the provision of services for people with psychosocial disabilities related to a mental health condition
The high economic cost of mental ill-health to Australia—estimated in 2014 to be about $40 billion a year1—highlights the importance of good mental health services and supports. Only a relatively small segment of the large number of people who receive services for a mental health condition each year will be eligible to receive supports under the National Disability Insurance Scheme (NDIS). At full Scheme, this group is estimated to be 64,000 people with significant and enduring psychosocial disability.
This submission makes several recommendations about NDIS support for this group. In addition, it would ease uncertainty for people currently in programs of support who will not be eligible for the NDIS if continuity of support arrangements could be specified. Their need for assistance will not go away if the programs they currently access are absorbed into the NDIS.
Recommendations
Provide clearer advice on eligibility for people with psychosocial disability People with psychosocial disability, families, carers and service providers have all reported some confusion about the NDIS eligibility criteria for people with psychosocial disability.
It has been suggested that the most common reason for declining an access request for a person with psychosocial disability is the lack of sufficient evidence of disability or impairment. In December 2015, a review of the Hunter trial site noted: “… data from the trial sites indicates that ineligibility rates from access requests from people with primary mental illness are significantly higher than other disability types with 1:4 applications requesting access due to primary mental illness being determined as ineligible compared to 1:9 for applicants across the rest of the Scheme”.2
1 National Mental Health Commission, Report of the National Review of Mental
Health Programmes and Services Contributing lives, thriving communities, November 2014 2 NDIS Independent Advisory Committee Dec 2015.
Submission to the Joint Standing Committee on the NDIS
Recent reports show an ongoing under-representation of psychosocial disability in the scheme. At the end of December 2016, only 6.3% of people with an approved NDIS plan had primary psychosocial disability (note: this figure is likely to be lower at present than it will be at full scheme due to phasing arrangements in states and territories prioritising people receiving or waiting for services that are not used by significant numbers of people with psychosocial disability—such as living in a group home or being on a waiting list for early childhood intervention services).
Fund outreach workers to locate and assist people with psychosocial disability likely to be eligible for the NDIS Some people with a significant and enduring mental illness do not identify as having a disability. In the Barwon trial of the NDIS, a pilot project engaged outreach workers to help identify people with psychosocial disability who were likely to be eligible for the scheme. As a result, the proportion of NDIS participants with psychosocial disability as their primary disability increased significantly in Barwon.
NDS encourages the National Disability Insurance Agency (NDIA) to fund outreach workers to help identify people with psychosocial disability and to assist them to make an access request. Ideally, these workers would be located in non-government organisations which support people with psychosocial disability.
Improve the quality and consistency of NDIS plans With the introduction of the First Plan process, the quality of plans is sometimes poor and there is inconsistency among plans for people with similar support needs.
Many participants have been contacted by telephone for initial information, to be later informed that it was used to develop their plan. As people with psychosocial disability can be reluctant to divulge information (particularly over the telephone to someone they have not met), the resulting plans often need amending. They may be missing essential support such as funding for Supported Independent Living and equipment.
NDS is aware that the Agency has limited visibility of the services that people entering the scheme currently receive; but existing providers do have this knowledge.
The NDIA should develop a template, asking participants and providers to complete it prior to attending a planning meeting. While approved NDIS-funded supports may differ from those currently received, the list of existing services should be used as a check to ensure that new plans are of a high quality, are complete and have a degree of consistency across participants. Where possible and appropriate, the Agency should also draw on information from carers and primary health providers to inform planning.
NDS urges the NDIA to develop psychosocial disability expertise among some planners so they can provide advice to other planners and review all plans for people with psychosocial disability prior to their completion. Plans for this group of participants should generally be done face-to-face at a venue chosen by the participant.
Submission to the Joint Standing Committee on the NDIS
Given the sometimes episodic nature of mental health conditions, the NDIS must have the capacity to make additional funding available quickly if a participant requires it. The current average three-month wait for a plan review is not appropriate for people with psychosocial disability who have a sudden increase in their need for support.
Include support coordination or support connection in all plans for people with psychosocial disability The episodic nature of mental health conditions means the support needs of participants with psychosocial disability will often vary in intensity over time. Funding for support coordination should be included in all plans for these participants to assist crisis responses, management of fluctuating support needs and access to mainstream services (such as health, justice, housing or drug and alcohol services).
The ambitious timeframe for implementing the NDIS has forced Local Area Coordinators to prioritise planning at the cost of providing assistance to connect people with community or mainstream services. Often this responsibility has fallen to providers who have not been funded to undertake it.
Outline continuity of support arrangements for people with psychosocial disability who are not eligible Some people who receive support from Commonwealth-funded programs such as
Partners in Recovery, Personal Helpers and Mentors and Mental Health Carers
Respite will not be eligible for the NDIS. This should not mean that support is unavailable for those who need it.
The bilateral agreements between the Commonwealth and the states and territories require that continuity of sport arrangements must ensure that people are not disadvantaged during the transition to the full NDIS. Further information is needed on how people with psychosocial disability who are ineligible for the NDIS will receive the support they require.
NDS is encouraged by the work of the Department of Health on the Continuity of Support Programme which is being implemented for people 65 years and over (and therefore not eligible for the NDIS) who currently receive specialist disability services. The Department has consulted with the disability sector to design a program that works for older people with disability and for providers. While implementation has only recently begun, the early signs are promising.
Uncertainty about continuity of support arrangements for people with psychosocial disability is unsettling for providers and their clients. The Commonwealth should spell out its continuity of support arrangements for people who currently receive support for mental health programs that the NDIS will absorb but who will not be eligible for the Scheme.
Submission to the Joint Standing Committee on the NDIS
Increase one-to-one support prices for participants with complex support needs NDIS pricing for participants with complex needs remains an unresolved issue. The current two-level prices (core and higher intensity) for one-to-one support do not adequately reflect the costs of providing of support to participants with complex needs. Inadequate pricing risks eroding service quality, reducing consumer choice and causing market failure.
An additional higher price should be set for supporting a person with complex needs. Many participants with psychosocial disability need at least some of their supports funded at a higher level to ensure that workers with the appropriate skills, experience and supervision are engaged to provide appropriate supports.
Monitor the interaction between the NDIS and mainstream systems Supports for people with psychosocial disability who are not eligible for the NDIS must continue to be available, whether delivered by mental health services, mainstream services and/or continuity of support arrangements. It is important that some of these supports are delivered through the community-based mental health services which are familiar to the people who use them.
Information, Linkages and Capacity Building (ILC) services may be available to assist some people with psychosocial disability (who may or may not be participants), but the short-term competitive grants mechanism being used to fund these services gives no certainty. It is unclear what supports for people with psychosocial disability will be available through ILC.
Currently, it is hard to tell how well the interface between the NDIS and other service systems is operating. This should be monitored and evaluated to understand whether people with psychosocial disability (whether participants or not) use mainstream services—such as emergency departments, crisis accommodation services and the justice system—more or less following the introduction of the NDIS.
Respond to the specific challenges of supporting some participants with psychosocial disability In rural and remote areas The NDIA must ensure adequate pricing for psychosocial supports in regional, rural and remote communities to avoid market failure. Rural and remote areas do not have the same level of infrastructure and service provision as urban areas. This will be exacerbated unless adequate prices are set for services in these areas, including services for Aboriginal and Torres Strait Islander people.
Respond to the need for forensic services in the NDIS NDS highlights the importance of having specialist planners work with participants who have contact with forensic services (such as participants with violent behaviour or having committed a sexual offence). These people typically have very complex support needs, with a high likelihood of dual disability or alcohol and/or drug abuse. Quality planning would be assisted by drawing on the knowledge of organisations that support people with disability who have contact with forensic services.
Submission to the Joint Standing Committee on the NDIS
As highlighted earlier, the ability to adjust plans quickly is critical to providing appropriate support for this group.
Invest in workforce development and capacity building NDIS workforce development initiatives need to include a focus on providing people with the knowledge and skills required to work with people with psychosocial disability (including in peer support roles). Some of these workers need to be highly skilled.
Unfortunately, NDIS prices for one-to-one supports allow little scope for support worker training. They assume only two days per year training per EFT worker.
The Australian National Audit Office’s report, ‘National Disability Insurance
Scheme—Management of the Transition of the Disability Services Market’, recommended:
The Department of Social Services should produce and publish a disability care workforce action plan as soon as practicable, which includes specific actions, timeframes, accountabilities, and monitoring arrangements for implementation.
This should occur as soon as possible and include consideration of the workforce required to support participants with psychosocial disability.
Support the creation of a national disability research entity Existing research funding is inadequate to support the scope and ambition of the disability sector reforms. The 2014 Audit of Australian disability research found that the current disability research agenda lacks critical mass, is poorly co-ordinated and is disconnected from sustainable funding.
Existing funding mechanisms for disability research such as the National Health and Medical Research Council (NHMRC) and the Australian Research Council (ARC) have not assigned disability research a high priority and are under pressure from a wide range of research demands.
NDS has support from a range of stakeholders for the establishment of a new entity to drive an Australian disability research agenda. A collaborative research structure similar to the successful Australian Housing and Urban Research Institute (AHURI) is proposed.
The objectives of such an entity would be: efficient co-ordination of disability research activities, expertise and spending, including better connection between existing funded projects from various sources (ARC, NHMRC, CRC programs) applied research to inform market stewardship build capacity and capability of research end-users facilitate system-wide innovation
Submission to the Joint Standing Committee on the NDIS
It would aim to: co-ordinate programs of research that stimulate service innovation and build knowledge; disseminate and promote knowledge of best practice and effective support; connect researchers to industry and consumers as end-users of research; and build the capacity of people with disability to engage with research.
NDS notes that that the Partners in Recovery program which is being transitioned to the NDIS incorporates an innovation fund that allows providers to explore, fund and trial innovative models of delivering services. This type of approach has a role in the success of the NDIS, but it needs to be funded. NDS supports the establishment of such a fund to provide incentives to develop innovative service delivery models, including for people with psychosocial disability.
February 2017
Contact: Dr Ken Baker
Chief Executive
National Disability Services is the peak industry body for non-government disability services. It represents service providers across Australia in their work to deliver high-quality supports and life opportunities for people with disability. Its Australia-wide membership includes over 1100 non-government organisations which support people with all forms of disability. Its members collectively provide the full range of disability services—from accommodation support, respite and therapy to community access and employment. NDS provides information and networking opportunities to its members and policy advice to State, Territory and Federal governments.