Submission 98 — Anglicare Tasmania — The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition | External submission

JOINT STANDING COMMITTEE ON

THE NATIONAL DISABILITY

INSURANCE SCHEME (NDIS)

On the provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition

ANGLICARE TASMANIA INC.

For further information about this submission please contact:

Dr Chris Jones

Anglicare Tasmania

GPO Box 1620

HOBART  TAS  7001

Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Page 2 of 14

Introduction ……………………………………………………………………………………………. 4 Anglicare Tasmania …………………………………………………………………………………………………………………………. 4

The National Disability Insurance Scheme in Tasmania………………………………………………. 4

Summary of recommendations …………………………………………………………. 6
Terms of Reference ……………………………………………………………………………….. 7 a. The eligibility criteria for the NDIS for people with a psychosocial disability. ……………………………………………………………………………………………………………………………………… 7

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. ………………………………….. 8

d. The scope and level of funding for mental health services under the Information, Linkages and Capacity building framework. ……………………………….. 9

e. The planning process for people with a psychosocial disability, and the role of primary health networks in that process. …………………………………………………………… 10

f. Whether spending on services for people with a psychosocial disability is in line with projections. ……………………………………………………………………………………………………… 12

References …………………………………………………………………………………………….. 14 Joint Standing Committee on the National Disability Insurance Scheme (NDIS) Page 3 of 14

Introduction Anglicare Tasmania (Anglicare) welcomes the opportunity to submit our feedback to the Terms of Reference of the Joint Standing Committee into the provision of services under the National Disability Insurance Scheme (NDIS) for people with psychosocial disabilities related to a mental health condition.

Anglicare Tasmania

Anglicare is the largest community service organisation in Tasmania with offices in Hobart,

Glenorchy, Sorell, Launceston, St Helens, Devonport, Burnie and Zeehan, delivering a range

of programs across the State. Anglicare’s services include accommodation support, mental health services, acquired injury, disability and aged care services, alcohol and other drug services, financial counselling, and family support. In addition, the Social Action and Research Centre (SARC) conducts research, policy and advocacy work with a focus on issues effecting Tasmanians on low incomes. Anglicare is committed to achieving social justice for all Tasmanians. It is Anglicare’s mission to speak out against poverty and injustice and offer decision-makers alternative solutions to help build a more just society. Anglicare provides opportunities for people in need to reach their full potential through our services, staff, research and advocacy. Anglicare’s work is guided by a set of values, which include these beliefs:  that each person is valuable and deserves to be treated with respect and dignity;  that each person has the capacity to make and to bear the responsibility for choices and decisions about their life;  that support should be available to all who need it; and  that every person can live life abundantly. Anglicare is also member of the Partners In Recovery (PIR) Tasmanian Consortium, which is a collaboration between five agencies, assisting people with severe and persistent mental illness and complex needs to access required supports and services. Anglicare has contributed to the development of PIR Tasmania’s response to the Joint Standing Committee and supports the recommendations of that submission.

The National Disability Insurance Scheme in Tasmania

The National Disability Insurance Scheme (NDIS) commenced in Tasmania on 1 July 2013 and is being rolled out over a number of years with a phased approach based on age cohorts.

Introduction date Age cohort

1 July 2013 15 to 24 year olds

1 July 2016 12 to 14 years olds

1 January 2017 25 to 28 year olds

1 July 2017 4 to 11 year olds

1 January 2018 29 to 34 year olds

1 July 2018 3 years; 35 to 49 year olds

1 January 2019 50 to 64 year olds

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As a whole State trial area, Tasmania has had unique insight into potential mental health funding and support responses for those both eligible and ineligible for NDIS support services. This means that Tasmanian consumers, communities and service organisations have the opportunity to learn, reflect and adjust practice as the Scheme reaches full roll out. Anglicare welcomes the NDIS policy aim to work within the recovery model of mental health, as endorsed by the Australian Health Ministers’ Advisory Council (AHMAC, 2013a and b). To date however, the NDIS policy, assessment, planning, line items and pricing frameworks have failed to operate to support this aim. On the contrary, these frameworks often work against this model, leading to a range of operational and implementation issues that will be outlined in this submission. The focus of recommendations within this submission centre largely on a redesign of the NDIS to address the specific needs of the people with a psychosocial disability within the recovery framework.

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Summary of recommendations Recommendation 1: It is recommended that the NDIS eligibility guidelines are reviewed to provide a clearer framework for NDIS Planners and Local Area Coordinators to make more informed and consistent decisions regarding psychosocial disability.

Recommendation 2: It is recommended that both Commonwealth and State Governments invest in a collaborative exercise to determine:  How many people living with mental health conditions will not be eligible for support under NDIS – both those with severe and persistent conditions who currently receive mental health services under PIR, PHaMs and D2DL, as well as an estimate of future numbers and those who currently need but are not receiving services..  What support will be available for consumers not eligible for support through and post-transition.

Recommendation 3: It is recommended that those consumers ineligible for NDIS support are directly engaged in clear pathways of support.

Recommendation 4: It is recommended that a clear decision and communication is provided regarding funding for those not eligible for NDIS on the grounds of psychosocial disability.

Recommendation 5: It is recommended that the Information, Linkages and Capacity Building funding be reconsidered as a direct response to funding supports for ineligible people living with disability.

Recommendation 6: It is recommended that NDIA Community Engagement staff, Planners and Local Area Coordinators (LACs) are specifically trained in understanding the needs of mental health consumers and appropriate service responses within the recovery model, to ensure engagement, planning and reviews are timely and relevant for participants.

Recommendation 7: It is recommended that the NDIA is fully resourced during the roll out of NDIS to manage the demands of conducting appropriate engagement, planning and reviews within reasonable, specified timeframes that do not hinder support provision for participants.

Recommendation 8: It is recommended that the NDIS develop a specific, single psychosocial line item that adequately addresses and covers the range of episodic support required by consumers diagnosed with persistent and complex mental health conditions.

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Recommendation 9: It is recommended that additional resourcing is allocated to cover participants applying to the NDIA for the first time, and to undertake plan reviews. This funding should be allocated outside of a participant’s plan, so that spending on this is not impacted by delays in NDIA administration processes.

Terms of Reference a. The eligibility criteria for the NDIS for people with a psychosocial disability. Some of the issues related to testing eligibility for NDIS amongst those living with mental health conditions are:  Clients being transient, so not having secured a diagnosis to date;  Clients having old diagnoses, so having challenges in obtaining the evidence to back this up;  The ‘permanency’ issue, as described in working against concepts of recovery;  People living with mental health conditions may be slow to grasp the benefits of NDIS and reluctant to surrender their privacy;  NDIS application and planning processes not creating space for trust and relationship to develop with planners.  People living with long term mental health conditions not wanting to identify with the disability label.

The current criteria of severe and persistent diagnoses for participants with psychosocial disabilities to be eligible for the NDIA is in stark contrast to the recovery model that forms the basis for the very support the NDIS would offer. Many consumers – particularly young people - are reluctant to sign up to their condition being permanent and clinicians are reluctant to diagnose young people with a lifetime illness. This is inhibiting access to NDIS support for many potential participants. One of the challenges for people accessing NDIS for psychosocial support is providing medical evidence that a condition is likely to be persistent, as well as it having impacts on their everyday life (NDIA 2015). This is particularly an issue for younger people, which make up the majority of participants in the current NDIS age cohorts in Tasmania. Professionals are often reluctant to both diagnose and label symptoms as a specific illness and to confidently state that this is a permanent condition. Many young people living with mental health conditions are likely to be reluctant to consider that their condition is permanent, given the recovery model’s emphasis on positive improvements. With the dissolving of funding to support consumers in this demographic, their reluctance to identify with the terms of the NDIS leaves a significant number of vulnerable Tasmanians, often living with comorbid and complex support needs with no support options. Based on early patterns with the younger cohort, Anglicare estimates that up to 30 per cent of existing clients will be ineligible and without support funding once PIR, PHaMs and D2DL are cased out following the full NDIS roll out.

Recommendation 1: It is recommended that the NDIS eligibility guidelines are reviewed to provide a clearer framework for NDIS Planners and Local Area Coordinators to make more consistent and informed decisions regarding psychosocial disability.

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Recommendation 2: It is recommended that both Commonwealth and State Governments invest in a collaborative exercise to determine:  How many people living with mental health conditions will not be eligible for support under NDIS – both those with severe and persistent conditions who currently receive mental health services under PIR, PHaMs and D2DL, as well as an estimate of future numbers and those who currently need but are not receiving services; and  What support will be available for consumers not eligible for support through and post-transition.

Recommendation 3: It is recommended that those consumers ineligible for NDIS support are directly engaged in clear pathways of support.

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. Psychosocial support under the NDIS in Tasmania is to be funded in part by transitioning funding from existing Commonwealth funded mental health programs, such as Personal Helpers and Mentors (PHaMs), Partners in Recovery (PIR) and Day to Day Living (D2DL). On 15 December 2015, the Commonwealth and Tasmanian Governments signed a bilateral agreement for the transition to and full roll out of the National Disability Insurance Scheme (NDIS) (COAG 2015). The Operational Plan Commitment between the Commonwealth and Tasmanian Governments specifies a number of commitments to find out the number of people ineligible for NDIS on the grounds of psychosocial disability and a commitment to continuity of support. This commitment stops short of specifying who is responsible for leading these data gathering and funding initiatives. As such, the ‘gap’ those consumers ineligible for the NDIS that are currently receiving psychosocial support will fall into remains unquantified. It is worth noting that the bilateral agreement only commits to continuity of support for those participants who have support through an existing mental health program at the time that NDIS rolls out for their cohort. It does not specifically mention those people living with complex, severe and/or persistent mental health conditions who are not engaged in support services at the time NDIS rolls out – i.e. potential consumers not engaged with any services and any future consumers.

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It is a concern that once funding for psychosocial services through programs such as PIR, D2DL and PHaMs is entirely transferred to NDIS, there will be a significant number of individuals, families and communities ineligible for support under the NDIS, who will have no access to supports that promote their ability to lead a contributing life and engage in developing their potential. Many of these individuals are currently receiving support through Anglicare and are asking us, “what will happen to [them]” and where they will be able to access support. Anglicare Tasmania provides services for approximately 400 individuals through PIR, 200 through D2DL and a further 400 people within PHaMs. Funding under these programs is gradually being transferred into NDIS and so far, Anglicare has been exposed to a 16 per cent decrease in PHaMs funding this year, as the cohort under 25 transferred to NDIS for psychosocial support. Additionally, State Government funded recovery and residential services are also being cashed out to the NDIS, including Anglicare’s Recovery programs and Curraghmore Residential and Recovery Support Service. To date, only a small proportion of young people in the NDIS age cohort have been assessed as eligible for NDIS funding, leaving the remainder unable to access NDIS or Commonwealth funded support programs. The assumption has been that NDIS will pick up support for those living with mental health conditions who previously received support under such programs. However, as the Mental Health Australia states, ‘Emerging evidence reinforces concerns that…the NDIS could unintentionally result in a shortage of services for those people who will remain outside the NDIS’ (MHA 2016, p. 11). For those Tasmanians without a permanent diagnosis but who have comorbid and complex support needs directly and indirectly related to their mental health, the impacts of withdrawing direct mental health support are likely to include more individuals and families needing to put more pressure on already stretched clinical and acute mental health support and intensive family support. This is a much more expense and resource intensive model of support for the State Government longer term. It is also a distinct move away from investing in preventative support highlighted in the State’s mental health strategy, ReThink (DHHS 2015). On a workforce level, the insecurity of mental health services funding means insecurity of employment for many specialist mental health workers. If they choose to leave their current positions, Tasmanians risk losing important mental health expertise within the sector. This would be damaging for the quality and choice of mental health services within Tasmania. The services gap will reach a crisis point in July 2019 when existing funding for mental health programs outside of NDIS will finally be completely withdrawn.

Recommendation 4: It is recommended that a clear decision and communication is provided regarding funding for those not eligible for NDIS on the grounds of psychosocial disability.

d. The scope and level of funding for mental health services under the Information, Linkages and Capacity building framework. At this stage, it is unclear how the Information, Linkages and Capacity Building Framework will cover gaps which will emerge as the NDIS is implemented.

As the Mental Health Council of Tasmania highlight in their submission to the Committee, this funding was being looked to in order to meet some of the needs created by how NDIS has been constructed for people living with mental health conditions.

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Recommendation 5: It is recommended that the Information, Linkages and Capacity Building funding be reconsidered as a direct response to funding supports for ineligible people living with disability.

e. The planning process for people with a psychosocial disability, and the role of primary health networks in that process. In Tasmania, NDIS planning is often conducted by Local Area Coordinators (LACs) who do not have specialist knowledge or understanding of mental health issues and the planning is often conducted via a one-off phone discussion. The assessment and planning tools are not specific enough to capture the needs of Tasmanians living with psychosocial disability and consequently, where eligibility for NDIS support on the basis of psychosocial disability is confirmed, this compressed planning process is often leading to inadequate plans and goals for participants. This then has a knock-on effect on the relevance and types of support participants might access. The lack of clarity in NDIA’s guidelines on what qualifies as a psychosocial disability for the purposes of the NDIS is currently leading to inconsistent assessments. Anglicare often works with participants with ostensibly very similar needs, but upon receiving their Individually Funded NDIS Package (IFP), find that these individuals are offered vastly different levels of funding. In part, this is due to some participants and their families having varied levels of self-advocacy skills, however these discrepancies can also be attributed to issues with the NDIS assessment tools. NDIS participants who have been confirmed as having both a severe and permanent psychosocial disability need responsive support. Their symptoms may fluctuate and change rapidly and often, or may be episodic. This means that their support needs may change equally rapidly and often for them to lead a contributing life. To work within the recovery model, their package of support needs to be flexible to adapt with a participant’s changing needs, as is possible within PHaMS and through PIR Support Facilitators. The rigidity of the NDIS planning and review process, as well as long delays in accessing reviews, do not lend themselves to responsive plans and support to be put in place for participants. This means that when crises occur, participants and their families cannot get any additional support in an effective timeframe. This leaves them to deal with changing circumstances and crises largely alone, which can have catastrophic outcomes. Transitioning to the NDIS can be a confusing and challenging process for many people. Currently there are no funded mechanisms beyond the NDIS website in place to support individuals to test their eligibility and prepare for planning meetings. Not providing support for NDIS applicants is likely to exacerbate inequality of access to NDIS and is another layer of challenge which is leading to participants presenting with vastly different levels of support. Another of the challenges within the NDIS planning and engagement process specific to new participants with psychosocial disabilities is the arrangement for one-off, and largely phone-based planning meetings, often without the opportunity to bring a support worker with them. Due to the nature of their very condition, participants with mental health conditions find it difficult to divulge the full impact that the condition has on their day to day lives to someone they have just met. Furthermore, asking participants to articulate the finer details of a plan that is intended to provide adequate support over 12 months is a daunting and anxiety-inducing task. In Anglicare’s current programs such as D2DL and PHaMs, development of a support plan is undertaken with an incremental planning process between participants and their matched worker which enables a trusting relationship to be developed and a greater understanding of the client’s goals and support needs.

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Anglicare workers have attended a number of planning and LAC meetings with participants at their request as many of our clients prefer the support of a worker they have a strong relationship with in these scenarios. For people living with psychosocial disability it is often challenging to engage with new people in new environments and they require additional support, in the form of a long term worker, to do so. Unfortunately, on multiple occasions Anglicare has experienced both NDIA planners and LACs strongly resisting the presence of support workers despite the wishes of the participant and their family. These situations have caused distress to participants and do not show respect for the principles of choice and control the NDIA is governed by. Anglicare also has concerns about the responsiveness of NDIA review periods. Although operational guidelines mandate that the NDIA has 14 days to decide to review a plan, Anglicare Tasmania have examples of cases where reviews have not been resolved for up to seven months. Other cases of one to three months, with multiple follow ups including phone calls and emails. In all cases to date, timeframes have been very lengthy and involved a huge amount of follow up from families or workers. Given that mental illness may be episodic and support needs may change quickly, an agile review process with 24 hour turn around times is crucial to ensuring that participants have continuity of appropriate support. Current delays within the plan review processes require significant follow up to ensure relevant changes to a participant’s support occur and that changes occur as soon as possible, to ensure continuity of relevant support for participants. To expedite this process, participants are drawing on Coordinator of Support funds to submit a participant’s plan for review. Given that significant follow up is required – well beyond the 14 days of review time specified in NDIA guidelines - participants are spending more of their plan funding on such administration that should not be the case if services were operating within NDIS’ stated service standards. In some cases, when a support item is changed from one provider to another or a new service booking needs to be created to update details, a 60 day delay can occur. This does not occur in all cases, however in situations where this delay does occur, a new Service Booking cannot be created meaning that the service provider is not able to claim for the support delivered for two months. This is a significant timeframe for a service provider to need to carry these NDIA arrears and also impacts on the choice and control of participants as some service providers may not be able to carry this debt or may be reluctant to take on a support role when it is a for a participant who is changing service providers. As mental health is a specialist area of disability, it requires a specialist workforce from assessment through to service delivery and specifically designed operational frameworks. Such specialisations are yet to be embedded into NDIS.

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f. Whether spending on services for people with a psychosocial disability is in line with projections. Given that the assessment and planning tools are not specifically designed to capture needs related to enabling people living with mental health conditions to access social and economic participation, many NDIS line items are not specifically tailored to cater for enabling a contributing life. For example, in response to a client needing support with household tasks, rather than supporting them to manage cleaning themselves as would be the case through PHaMS, under NDIS line items, service providers are able to offer a cleaner; in another case, a client who was formerly able to use public transport to attend TAFE on their own is now being escorted to TAFE under NDIS. Such a change in approach to support is potentially undermining significant achievements consumers may have made in living a contributing life and this appears to work against NDIA’s stated approach to working within the recovery model. To build a contributing life, there is often a need for both clinical and community supports. For example, it is essential that NDIS participants have access to therapeutic conversations that assist people to overcome issues that are a barrier to participation resulting from mental illness. In contrast to existing mental health programs that provide either facilitation or support, such as PIR and PHaMS, such a combination of support is not facilitated through NDIS line items. Accessing occupational therapy for an autistic child may be a crucial part of building a contributing life; Cognitive Behavioural Therapy may support a young person to deal with anxiety related to interacting in an educational or social setting. Although such services may be therapeutic, as clinical services, it is likely that these services would not be permissible under the current NDIS framework. As highlighted by the Mental Health Council of Tasmania in their submission to the Committee (MCoT, 2017), NDIS line item costings are not viable for sustaining a high quality mental health sector. Commonly, Anglicare is losing about 50 per cent an hour on any given NDIS line item, or having to compromise on the service offer. For example, in some cases, Anglicare can only offer a less qualified worker, or half the hours of service specified in their plan with a specialised worker. It should be noted that current pricing is based on SCHADS 2, which is commonly used within the general disability sector, rather than SCHADS 4, which is more commonly offered for specialist mental health support workers. Longer term, this may lead to either a significant decline in the quality of mental health services, or market failure and severe consequences for community-based rehabilitation, as the Mental Health Council of Tasmania has flagged to the Committee (MHCoT, 2017). The cost of providing support for participants with psychosocial needs is also greatly increased through the NDIS in comparison to the current block funding model for programs such as D2DL, PHaMs and PIR. As an example, Anglicare’s total funding allocation in 2016-17 the Day to Day Living (Pathways) program equates to approximately $826 per client per year, with these clients receiving an average of 4.5 hours of individual and group-based psychosocial support per week. On average, the NDIS plans Anglicare is providing psychosocial support for are generally between $10,000 to $40,000 per participant for 12 months of support. This example is testament to the significant discrepancy in the overall costs and mismatched support allocation within the NDIS funding model.

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Transport is a crucial facilitator of social and economic participation for people living with mental health conditions. It is also an important cost for service providers reaching out in their support work. And, its importance is exacerbated within regional and rural areas, where travel to social activities, education, training and employment and clinical and community services may be further and a significant cost. Under current Commonwealth funded mental health programs, such as PIR, PHaMs and D2DL, transport costs for both service providers and for clients are funded as part of the grant. Within NDIS, it is a participant line item. There are a number of issues to address here. Firstly, if transport funds within an IFP run out, this creates a potential barrier to participation in planned activities for participants. Without a responsive review process, this is a challenge to resolve in a timely manner. Transport costs for service providers are no longer funded, but this is still an outlay. So participants living in regional and rural areas are likely to cost more to provide services for. This raises issues of equity and viability in pricing. Of particular concern are those participants who elect not to take up support where they are faced with meeting the costs of transport from their disability support pension.

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References Australian Health Ministers’ Advisory Council 2013a, A national framework for recovery oriented mental health services: guide for practitioners and providers, Commonwealth of Australia, Canberra. — 2013b, A national framework for recovery-oriented mental health services: policy and theory, Commonwealth of Australia, Canberra.

Community Mental Health Australia (2017), Submission to the Joint Standing Committee

on the National Disability Insurance Scheme on the provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition. Council of Australian Governments (COAG) 2015, Bilateral Agreement between Commonwealth and Tasmania – Transition to a National Disability Insurance Scheme, COAG, Canberra. Department of Education (DoE) 2011, Partnering Agreement between Department of Health and Human Services and Department of Education 2011-2013, DoE, Hobart. Department of Health and Human Services (DHHS) 2015, Rethink Mental Health: better mental health and wellbeing. A long-term plan for mental health in Tasmania 2015-2015, DHHS, Hobart. Mental Health Australia (MHA) 2016, Incoming Government Brief, MHA, Deakin. — 2017, The Implementation and Operation of the Psychiatric disability elements of the National Disability Insurance Scheme: a recommended set of approaches. Technical paper prepared by David McGrath Consulting on behalf of MHA, MHA, Canberra. Submission to the Joint Parliamentary Committee, Psychosocial disabilities

Mental Health Council of Tasmania 2017, Submission to the Joint Standing Committee on the National Disability Insurance Scheme: On the provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition, draft. MHCoT, Hobart.

National Disability Insurance Agency (NDIA) 2015, NDIS Mental Health – Key Themes, NDIA,

Canberra. — 2016, Psychosocial disability, recovery and the NDIS, retrieved 21/2/2017: https://www.ndis.gov.au/medias/documents/heb/h21/8799160959006/Fact-Sheet

Psychosocial-disability-recovery-and-the-NDIS-PDF-774KB-.pdf

National Disability Insurance Agency (NDIA), Tasmanian Government and Commonwealth

Government 2016, Operational Plan Commitment between the National Disability

Insurance Agency (NDIA), Tasmanian Government and Commonwealth Government for

Transition to the National Disability Insurance Scheme (NDIS), retrieved 21.2.17 file:///P:/SARC/2.%20Research,%20Policy%20and%20Advocacy/Topic%20areas/Mental%2 0Health/NDIS/Tasmanian%20Operational%20Plan%20Public.pdf Parliament of Australia 2016, The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition – Joint Standing Committee on the NDIS – Mental Health Terms of Reference, http://www.aph.gov.au/Parliamentary_Business/Committees/Joint/National_Disability_Insurance_Scheme/MentalHealth, accessed 9 December 2016.

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Submission 98 — Anglicare Tasmania — The provision of services under the NDIS for people with psychosocial disabilities related to a mental health condition

JOINT STANDING COMMITTEE ON

THE NATIONAL DISABILITY

INSURANCE SCHEME (NDIS)

Dr Chris Jones

Anglicare Tasmania

GPO Box 1620

Contents

The National Disability Insurance Scheme in Tasmania………………………………………………. 4

Anglicare Tasmania

Glenorchy, Sorell, Launceston, St Helens, Devonport, Burnie and Zeehan, delivering a range

The National Disability Insurance Scheme in Tasmania

Community Mental Health Australia (2017), Submission to the Joint Standing Committee

National Disability Insurance Agency (NDIA) 2015, NDIS Mental Health – Key Themes, NDIA,

Psychosocial-disability-recovery-and-the-NDIS-PDF-774KB-.pdf

National Disability Insurance Agency (NDIA), Tasmanian Government and Commonwealth

Government 2016, Operational Plan Commitment between the National Disability

Insurance Agency (NDIA), Tasmanian Government and Commonwealth Government for