Submission 83 — Australian Psychological Society (APS) — The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition | External submission

Provision of services for people with psychosocial disabilities related to mental health conditions under the

National Disability Insurance Scheme

(NDIS)

Dr Louise Roufeil FAPS

Executive Manager Professional Practice

Mr Bo Li

Policy Adviser

Introduction

The Australian Psychological Society (APS) welcomes the opportunity to provide a submission to the Joint Committee inquiry into the provision of services for people with psychosocial disabilities resulting from mental health conditions under the National Disability Insurance Scheme (NDIS). In making this submission, the APS liaised with members who are working or have worked in service provider organisations, other provider entities and key stakeholders.

Diagnosis and mental health conditions The issue of diagnosis is a vexed one among people living with mental health conditions as well as service providers. For many people, the process of having a formal diagnosis can be disempowering and the stigma associated with such labels remains very real. In addition, many people are also concerned with the implications of having a diagnosed mental health condition on their daily lives including finding and staying in certain jobs, or accessing certain services such as life insurance.

The National Standards for Mental Health Services (2010)1 also require mental health services in Australia to adopt a recovery–oriented approach that embeds recovery principles into service delivery, culture and practice providing consumers with access and referral to a range of programs that will support sustainable recovery. The recovery-oriented approach recognises the fluctuating nature of many mental health conditions but emphasises that recovery to a new way of life must be the focus of service provision:

A deeply personal, unique process of changing one’s attitudes, values, feelings, goals, skills and / or roles. It is a way of living a satisfying, hopeful and contributing life. Recovery involves the development of new meaning and purpose in one’s life as one grows beyond the catastrophic effects of psychiatric disability (National Standards for Mental Health Services, p.39)

Personal recovery from mental illness is therefore not necessarily the same as a permanent medical recovery involving absence of symptoms. The concept of personal recovery can sit uncomfortably with the medical notion of a diagnosis.

For these and other reasons, many service providers for people with mental health conditions do not require their client to have formal diagnoses, but rather focus on improving the client’s functional outcomes as a result of their mental health conditions. This recovery-focused approach is also used to underpin government-funded psychosocial support programs including the Personal Helpers and Mentors service (PHaMs), where a formal diagnosis is not required in order to access such services.2

In contrast, participants in the NDIS are required to not only show evidence of permanent disability, but in the case of psychosocial disabilities, such evidence need to be supplied by the participants’ “GP

Australian Government (2010). National Standards for Mental Health Services (2010). Commonwealth of

Australia. 2 See https://www.dss.gov.au/our-responsibilities/mental-health/programs-services/personal-helpers-and mentors-phams#2

or treating psychiatrist”.3 This requirement will present as an access barrier for many people living with undiagnosed mental health conditions and those in “personal recovery” from serious mental illness. There is also the possibility that people who were able to access services under PHaMs may not be eligible to access NDIS services without formal diagnoses.

The artificial divide between disability and health It is widely understood and accepted that the NDIS was established to assist people with disabilities to maximise their opportunities in the community, and that any health-related services such as treatments are to remain in the health system. While this divide between health and disability services may seem straight- forward for people with physical disabilities, it is far more difficult for people with mental health conditions to have their services neatly categorised into such boxes.

Psychosocial disability, by its very nature, requires a mix of evidence-based psychological intervention and broader social support for individuals. Some individuals will also require a psychiatric response. Equally, it is important to recognise that many psychosocial disabilities have their roots in physical disabilities; for example, a person with a severe physical disability is likely to experience psychosocial disability (e.g., adjustment disorder, depression, anxiety) directly related to their physical disability. In both cases, it is challenging (and in many cases not possible) to identify the components of disability that warrant a health-response and those that warrant a response from the NDIS.

To maintain the original intent and integrity of the NDIS in terms of the distinction between disability and health will require applicants with psychosocial (and physical) disability to be assessed by skilled, appropriately trained and qualified assessors with considerable expertise in mental health. The enormity of this task is made more difficult by the expected significant uptake of NDIS participants in the next two and half years. It is estimated that in 2018-2019, around 850 plans need to be approved per day and an additional 1,100 plans also need to be reviewed per day; double the current rate at which plans are being approved.4 It is crucial that the NDIA consider issues of workforce capacity with regard to skilled assessors familiar with clients presenting with mental health conditions and the concept of recovery from mental illness. There must also be appropriate quality assurance oversights in place to assure that people with psychosocial disability are able to get their needs met.

Information, Linkages and Capacity Building (ILC) The Information, Linkages and Capacity Building (ILC) aspect of the NDIS is central to the ongoing operations of the Scheme. The ILC aims:

https://www.ndis.gov.au/html/sites/default/files/Completing_the_access_process_for_the_NDIS_Tips_for_com municating_about_.._.pdf 4

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i. To provide information, referral and capacity building supports for people with disability, their families, and carers that are not directly tied to a person through an individually funded package.

ii. To partner with local communities, mainstream and universal services to improve access and inclusion for people with disability5.

It is also worth noting that the ILC Framework only funds five activity areas:

i. Information, linkages and referrals ii. Capacity building for mainstream services iii. Community awareness and capacity building iv. Individual capacity building

v. Local area co-ordination (LAC). The ILC does not fund activities such as assistance with cooking and banking – activities that are often key areas requiring assistance for people with psychosocial disability. The total funding budget for ILC to 2019-2020 is $132 million, which has been identified as being “insufficient” by the previous chair of the NDIA.

In an ideal scenario, the ILC would have been in place prior to the rollout of the Scheme and gradually strengthened over time as more participants are deemed to be ineligible for individual packages under the NDIS. In the context of people with psychosocial disabilities, it appears that there has been very little (if any) ILC in place. In many instances, support services for people with psychosocial disabilities are funded by health or social service departments in various jurisdictions. It is simply not known how many of these services will continue once the NDIS gradually rolls out and states and territories gradually withdraw their services and transfer these into the NDIS.

The Government has already acknowledged that “one third of the 690,000 Australians with severe mental illness have chronic, persisting illness and most have a need for some form of social support, ranging from low intensity or group-based activities delivered through mainstream social services to extensive and individualized disability support”.6 There is also acknowledgement that there are gaps in services for people with severe mental illness who are not supported by existing state-funded mental health services nor by the NDIS, but have complex needs and require specialist clinical coordination of services.7

The gaps in services for people with psychosocial disabilities seem to be widening and may continue to do so with the transition to the NDIS. This is an area that will require significant ongoing attention in

5 https://www.ndis.gov.au/communities/ilc-home/ilc-commissioning-framework-consultation/ILC-comm-fw draft

6 Australian Government (2015). Australian Government Response to Contributing Lives, Thriving Communities –

Review of Mental Health Programmes and Services. http://www.health.gov.au/internet/main/publishing.nsf/Content/0DBEF2D78F7CB9E7CA257F07001ACC6D/$File /response.pdf 7 ibid.

the coming years to ensure people who may not meet the NDIS eligibility requirements do not fall through the gaps.

Impact of NDIS on state-funded disability services The impact of the NDIS on state-funded disability services has being felt since the roll-out of the Scheme. The APS is aware of the gradual cessation or withdrawal of state-funded services for people with physical disabilities as participants are being assessed as being eligible for services under the NDIS. For example, in NSW, disability services provided under the Ageing, Disability and Home Care (ADHC) area of the Department of Family and Community Services will be transferred to the non government sector by 30 June 2018.

Similarly, in Victoria, the Mental Health Community Support services (MHCSS) are in the process of transitioning into the NDIS. There are grave concerns that MHCSS will cease in the not too distant future, which may leave individuals in Victoria who are not eligible for NDIS services without direct access to any support services, particularly given the number of people requiring ongoing support as outlined above.

Workforce constraints Concerns have been expressed regarding the rapid rollout of the NDIS and its implications on the disability services workforce. In particular, it is not known if the demand for specialist support services for people with psychosocial disabilities can be adequately met. There are similar concerns regarding the workforce capacity within NDIA itself in assessing people with psychosocial disabilities.
Conclusion It is worth remembering the foundations upon which the NDIS is built. While the funding of the NDIS and its operations represent costs to the government, the overall savings across the economy in areas such as health, housing, education and social capital will far outweigh the NDIS investment.

There remain significant concerns regarding the intersection of the health and disability sectors around psychosocial disability and the potential for misunderstanding of the mental health recovery paradigm within the disability sector.

A further area for concern is the quality of the plans developed for NDIS participants. As people with psychosocial disabilities are being enrolled into the Scheme, the issue of quality must be identified and addressed early through the use of a high skilled professional workforce with expertise in mental health. This will, in turn, require the NDIA to invest in staff recruitment and ongoing training in order to expand its workforce capabilities in dealing with people with psychosocial disabilities.

Finally, mechanisms need to be in place to ensure the continuation of existing services for people with psychosocial disabilities until the NDIS is fully operational to ensure people do not fall through the gaps.