The Salvation Army
Australia
The Salvation Army
Submission made on behalf of The Salvation Army Australia
Submission on:
The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition
February 2017
For more information, please contact:
Samuel Pho (Lieut.-Colonel)
National Secretary
The Salvation Army National Secretariat
2 Brisbane Avenue
Barton, ACT 2600
Introduction
The Salvation Army Australia welcomes the opportunity to make this submission to the ‘Joint Standing Committee on the NDIS’ enquiry into the implementation, performance and governance of the National Disability Insurance Scheme (NDIS). This submission is informed by The Salvation Army’s collective experience, knowledge and expertise about the delivery of disability services, including those provided under PHaMss and PIR funding. The submission is also informed by the Salvation Army’s long standing commitment to people with complex needs that are compounded by mental health issues and other forms of disadvantage such as homelessness, addictions and poverty. An emerging concern for this cohort of disadvantaged Australians is their failure to meet narrow NDIS eligibility criteria, or their inability to access services due to the nature of their disabilities and disadvantage. The following response to the standing committee outlines these concerns and emerging gaps in delivery of the NDIS.
Addressing the Terms of Reference
In response to the terms of reference, The Salvation Army (TSA) provides commentary relating to sections:
a. the eligibility criteria for the NDIS for people with a psychosocial disability 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 whether these services will continue to be provided for people deemed ineligible for the
NDIS
c. the transition to the NDIS of all current long and short term mental health state and territory government funded services, and in particular whether these services will continue to be provided for people deemed ineligible for the NDIS
d. the scope and level of funding for mental health services under the Information, Linkages and Capacity building framework
e. the planning process for people with a psychosocial disability, and the role of primary health networks in that process
f. whether spending on services for people with a psychosocial disability is in line with projections
g. the role and extent of outreach services to identify potential NDIS participants with a psychosocial disability, and
h. the provision, and continuation of services for NDIS participants in receipt of forensic disability services.
About The Salvation Army
The Salvation Army is an international movement, recognised as part of the Christian church, and one of the world’s largest Christian social welfare organisations. Operating in Australia since 1880, The Salvation Army is one of Australia’s largest providers of social services and programs for the most marginalised and socially disadvantaged people in the community.
The Salvation Army has a national annual operating budget in excess of $700 million providing more than 1,000 social programs and activities across the country through networks of support services, community centres and churches. Key services include:
e material aid and emergency relief
e financial counselling and assistance
® accommodation and homelessness services e family violence support services
drug and alcohol support and treatment services out-of-home care
child, youth and family services
emergency disaster responses
education, training and employment support services personal counselling and support
migrant and refugee services, and
aged care services.
The Salvation Army is a provider of disability services. Services for people with a disability are home based, in residential care and through Australia Disability Enterprise (ADE) employment services.
The Salvation Army’s disability services recognise that people with a disability want to live, work and socialise with freedom, control and self-determination. They want the opportunity to flourish, to create a good life for themselves and their families, to reach their full potential and to experience everything that life has to offer. They want to fulfil their aspirations.
People with a disability must have access to employment and skills training, education, health care, safe shelter, reliable transport and access to spaces and places. As such The Salvation Army advocates, innovates and pushes the boundaries for people with a disability and their carers and actively encourages and assists them to create their very best life.
While poverty, disadvantage and exclusion remain rife among the one in five Australians who have a disability, including the nearly 4.3 million people affected by mental health issues and/ or physical disability, the Salvation Army continues to challenge inequality of opportunity at every level and on every front.
The Salvation Army makes the following comments in relation to the Terms of Reference provided for this consultation paper.
a. The NDIS eligibility criteria for people with a psychosocial disability: © excludes and marginalises cohorts previously assisted through PHaMs. The eligibility criteria for NDIS includes a requirement of ‘permanent or likely to be lifelong impairment’. This is contrary to the recovery focus that people with a mental illness have embraced and expect. As such the NDIS excludes cohorts of people with a mental illness. Under PHaMs there was not a requirement for a formal diagnosis or evidence of functional impairment so people with a mental illness were able to access services in a timely manner and discuss recovery without the risk of ‘denial of service’. Under the previous funding arrangement workers could receive direct referral and assertively outreach to maintain client engagement. The NDIS does not have the capacity to replace this service as it is built on a restrictive insurance framework that was not designed to deliver the same level or type of supports. It must be acknowledged that these are two separate activities.
o no longer has the capacity to support the transition of new presentations at the front end of the service system due to the redirection of government mental health funding in Victoria. This results in significant gaps in mental health service responses with resulting reports of a higher number of incidents/ distressed clients/ sector stress due to NDIS limited capacity to respond effectively to this emerging gap.
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impacts on GP’s and other clinical practitioners who are required to complete NDIS documentation for access to the scheme and to validate client supports. NDIS lacks the provision to address the necessary expertise, program induction or commitment to the client focussed task. There is a lack of mental health service expertise and limited funding to undertake these assessments resulting in challenges in accessing basic resources such as the process and documentation to commence the process for the establishment of eligibility for the NDIS,
is time consuming with burdensome red tape regarding the processes for accessing NDIS. This generates anxiety, both for clients, due to the need to repeatedly retell their story to assessing GP, as well as for NDIS staff in processing such claims. This burden exacerbates the client’s symptoms of mental illness. In some cases this process has led to the client’s disengagement from the service system increasing the risk of the client ending up in acute systems in the future.
b. The transition to the NDIS of all current Commonwealth government funded services for both long and short term mental health, including PHaMs and PIR and in particular: whether these services will continue to be provided for people deemed to be ineligible for the NDIS
o
TSA’s experience illustrates that there is lack of commitment on the part of government to the ‘continuity of care’ for ineligible clients. More recently, TSA’s plan for transition of remaining clients was accepted only when TSA made the commitment that it would ensure the clients success.
TSA’s experience also demonstrates that it will have further issues regarding ‘continuity of care’ when clients do not transition within six months due to a number of factors such as age, refusal, NDIS ineligibility (e.g. clients qualified for PHaMs but on more than one occasion were deemed to not have severe enough functional impairment to meet NDIS criteria).
c. The transition to NDIS of all current state and territory long and short term mental health, in particular: whether these services will continue to be provided for people deemed ineligible for NDIS
d. The scope and level of funding for mental health services under the Information, Linkages and Capacity (ILC) building framework:
The ILC framework lacks detail, clarity and commitment to adequately address the service gaps that have been created by the introduction of the NDIS.
The ILC framework fails to address the missing Mental Health component within the NDIS which Eddie Bartnik’s work was designed to resolve i.e. pricing, specific mental health categories or support items, other issues as raised by the mental health sector and peak bodies.
e. The planning process for people with a psychosocial disability and the role of primary health networks in that process:
TSA argues that the planning process requires a complete overhaul with specific focus on the following review areas:
3°
The ability of the ILC workforce to professionally deliver appropriate plans is questionable in that the staffs qualifications, skills and experience in mental health specific services seems to be lacking:
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Example 1: a planner did not know the function of a ‘peer worker’.
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Example 2: a planner ‘cut and paste’ details from one plan to another so the new plan stated a client required a hoist and incontinence aids. However when TSA staff met with the client she was found to be an able bodied 19 year old with no incontinence or hoist requirements. The client had a copy of the plan. The planner admitted to staff that she had actually ‘cut and paste’ and stated that the client really needed capacity building support because she stayed 20 hours in her room only coming out for meals. The clients plan provided for core support such as personal care activities rather than the requisite capacity building supports.
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Example 3: a planning meeting was undertaken by phone resulting in a reduction in plan dollars from the previous face to face meeting made twelve months earlier. This resulted in less support leading to the client becoming increasingly isolated, not showering and showing hoarding tendencies
Please Note: TSA can provide many more examples of client plans not being adequate to meet the needs to achieve the client’s goals. TSA currently has in excess of 10 plans under review due to the inappropriate nature of the support items. This creates significant administrative burden on TSA which is an unfunded component.
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There is a 4 to 6 month waiting period between NDIS eligibility being determined and the client receiving their first plan. During this time no mental health support service is paid and no retrospective claiming can be made. Given the client has been declared as NDIS eligible this is of significant concern as no service provider can afford, nor has the capacity to offer support, leaving the client unsupported with the increased risk of declining mental health. It is TSA’s experience that other service systems identify increases in the number of presentations of people who are in need of mental health support but are unable to be referred quickly to a service due to the NDIS criteria versus direct referral to PHaM’s/ PDRSS/ other previously funded service.
f. Whether spending on services for people with a psychosocial disability is in line with governments projections for participation numbers:
o The allocation of mental health plan dollars that have been largely spent within the NDIS
have been inappropriately applied to group activities and personal care assistance rather than individually focused capacity building as would have been applicable in the previous service paradigm. The risk that this poses in terms of recovery for clients is significant. Group focused dollars have proven a concern and been underspent due to:
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Clients reporting that they do not want to attend groups
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Clients not having the capacity to get to group sessions as transport isn’t funded in their plans
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Qualified mental health staff assessments stating that group activities are inappropriate for clients due to the client’s mental health status.
o The NDIS is stating that clients are not using all the funding dollars allocated in their plans. This results in the next year’s follow-up plan being reduced financially. However the underspend is due to the inappropriate initial allocation of the dollars to supports within the plan which are not in line with the clients personal goals or ability.
o The pricing framework is inappropriate and has implications for the sector in terms of the deskilling of the workforce, lowering of organisational infrastructure capacity, potential for organisations financial failure and ultimate closure, outsourcing of the service to private and
for profit organisations with a risk of businesses profit generation priorities overshadowing client recovery aims
g. The role and extent of outreach services to identify potential NDIS participants with a psychosocial disability
oO There is no capacity within the mental health sector in Victoria for this to occur unless appropriately funded
h. The provision and continuation of services for NDIS participants in receipt of forensic disability services. (Salvation Army services are not operating in this area of service, therefore no comment is provided).
Recommendations
The Salvation Amy makes the following recommendations to assist with the future planning for the provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition.
a. The Salvation Army strongly advocates for the eligibility criteria for access to NDIS to be broadened to enable access by clients suffering from episodic mental health issues. Access to services must be available in a timely and appropriate manner to facilitate full recovery from such episodic incidents.
b. The Salvation Army recommends that other relevant long term and short term mental health funded services such as PHaMs are maintained and that those people who are ineligible to receive NDIS services receive services from such alternative sources in a continuity of care process.
c. The Salvation Army strongly recommends that the Information, Linkages and Capacity building (ILC) Framework be reviewed and revised to provide more a comprehensive list services which includes mental health services and provides increased clarity of mental health categories and associated pricing of services.
d. The Salvation Army recommends that the planning processes for mental health services be comprehensively reviewed and revised focussing on workforce training, skills and capacity to meet increased and diverse demand particularly in the development of clients service plans.
e. The Salvation Army recommends that spending is targeted appropriately to the needs of the target group. The aim of NDIS is to build the capacity of the client to fully participate in the community. Services must be tailored to meet those specific needs.