7th August 2017
Joint Standing Committee on the National Disability Insurance Scheme
PO Box 6100
Parliament House
Canberra ACT 2600
seniorclerk.committees.sen@aph.gov.au
Dear Madam/Sir
Submission for the Parliamentary Inquiry - Transitional arrangements for the
National Disability Insurance Scheme (NDIS}
This submission has been collaboratively prepared by 4 early childhood intervention service providers that were all part of the NDIS trial in the Hunter Region - Hunter Prelude, Early Links Inclusion Support, Firstchance and Royal Institute of Deaf and Blind Children (RIDBC).
We believe that the experience of operating during the trial and more recently being part of the Year 1 roll out of the ECEI Approach enables us to offer a unique perspective on the provision of services under this approach.
We thank you for the opportunity to make a submission to the Parliamentary Inquiry and trust that the feedback that is received will enable the refinement of the NDIS Transitional Arrangements so that they can facilitate valuable supports for families and an efficient process for service providers.
Kind regards
Sue French
General Manager Early Links Inclusion Support
Darleen Taylor & Linda Rolland
General Manager & Program Manager, Firstchance
Rani Dibley
General Manager Hunter Prelude
Wendy Dorn
Program Manager, RIDBC Hunter
- Boundaries and interface of NDIS service provision and other non-NDIS service provisions, with particular reference to health, education and transport services
Health
Families are finding proving eligibility to access NDIS is easier if the child has been diagnosed with a disability or a developmental delay. However, NSW Health often determines children as ineligible for their service once they know the family will be applying for NDIS and this can be prior to them receiving a diagnosis. The families are then forced into the ECEI (Early Childhood Early Intervention) pathways to be supported with the Access Request Form (ARF) process without supporting documentation and this further contributes to the long waiting lists. Transitioning from Health to NDIS through the ECEI Approach is creating gaps in services as the first priority of the ECEI Transitional Providers was to provide planning meetings for the “defined” children. This remains an ongoing task, therefore, Interim supports are unlikely to be provided as the planning teams prioritise those with the greatest need or those who have been approved for access to the Scheme. As the ECEI Transitional Providers begin to undertake the NDIS Plan review function this will ultimately mean that the interim supports are pushed further back.
Health offer very specialised services such as feeding. When children have an NDIS plan they are no longer able to access the specialist support through health and are required to seek services with providers where the specialist knowledge may sit outside their scope. This is particularly problematic if the specialist skill is not available within the community.
In regional areas in particular Health may be the current service provider for families. Once families are receiving NDIS packages they are no longer eligible to access Health and find themselves with no services at all. While there are strategies in place to recruit to remote areas and build skills within the community, these are long term strategies and leaves the current families in a vulnerable situation.
Families are confused about the interface between services and often find themselves being referred backwards and forwards between health and NDIA. More work is required to clarify the interface between Health and NDIA in order to develop a process that provides continuous support for children and families and to allocate the funding appropriately.
Education
The introduction to NDIS service provision into schools and Early Childhood Settings has required service providers to work together to create the best possible outcome for children on an individual basis. In order to meet the challenges associated with allowing service provision in the education setting, some schools/Preschools have restricted access and in some cases are not allowing therapy to be conducted on school grounds at all. The result of the restrictions has left some families unable to have the services provided in their natural setting. It would be beneficial for Education to continue to work with NDIA to create clear guidelines on the interface between Education and NDIS.
While transport is the responsibility of the Department of Education, there are limitations placed on the access to the scheme. Children have to live within a 45 km radius but many
remote families have a greater distance to travel, particularly if they need to access a specialised service.
Child Protection
When children are living at risk in their family home, there is no funding available for service providers supporting the family through their NDIS Plan to initiate the lengthy process of mandatory reporting as we have been directed not to use paid time from the child’s plan to do so. This leaves service providers to do so as unpaid time. Often part of the reporting process is to connect families to local support services. The services, however, are very limited and sometimes non-existent, leaving services with the burden of providing children with support for which they do not have the expertise or resources. Children are, in turn, placed at greater risk. At risk children is an area that requires further exploration to set in place clear guidelines and funding.
Family Support Services
Family Support Services have a valuable part to play in the protection of children and supporting families to remain strong and available for their children. Unfortunately there are long waiting lists and limited services available. Historically Family Support Services have been engaging with families who have been reported to Child Protection agencies. In many cases the family is fearful of what this engagement may mean for their family and are reluctant for intervention. Early Intervention Services are uniquely placed to work alongside of these families to build capacity of the entire family unit in a more authentic yet targeted manner.
Other interface issues
We have found that there are limited or at times non-existent pathways to refer families to as government departments enforce their boundaries and most publicly funded services are under resourced and have long wait lists. We understand that the role of the NDIS is not to fund the gaps in a community however the current approach can leave a family without the supports they require.
The roll out of the NDIS has resulted in previous avenues for funded support ceasing. The removal of FAHCSIA funding has meant that children who were being supported by private therapists will now need to return to the ECEI pathway in order to receive interim supports and an NDIA plan.
Families/community members are confused about whether mental health is still covered by the NDIA and they should go to receive support.
While NDIA are supposed to provide funding for CALD families, it is often difficult to have it approved in plans. There is also a shortfall as NDIS provides $119 for interpreters when the cost is actually $250. Either families or services are required to fund the gap. Interpreting services are essential for the Early Childhood and NDIS philosophy is to build capacity in the family.
Funding for therapists to travel is very limited, particularly for families in regional or remote areas.
- Consistency of NDIS plans and delivery of NDIS and other services for people with disabilities across Australia
e We appreciate that plans are individual and are developed to meet the needs of the individual and their family. However, there are many inconsistencies in the plans that fall outside of the child and family individual needs:
-
Within our region there are significant differences in the level of funding provided by different NDIS planners e.g some families receive COS and/or CORE supports while others receive no COS supports or Core supports
-
In families with several children who have the same diagnosis with the same functional needs, there is discrepancy between funding within plans.
-
Planners within NDIS appear to have different methods of justification for funding.
-
ARF approvals have very long waiting periods. Some families waiting for up to 3-4 months before their ARF is considered
-
There is an inconsistency in the application of the NDIS rules around access and what is reasonable and necessary.
-
Service providers provide clear information to NDIS for upcoming plan reviews. However some subsequent plans are approved prior to the review being completed. This means that important information on outcomes and goal attainment is not considered and therefore some children have continued to access the Scheme when they didn’t need to or have been funded at levels above their needs. Conversely those children’s needs who have changed have received no funding variation to meet these needs.
-
We understand for this question we would be also including registered partners e.g. St Vinnies or Uniting Care or Transitional Providers in NSW who provide support to families with NDIS plans. Feedback from families on the popular social media site ‘NDIS Grassroots’ have identified that families are struggling with plan implementation and rudimentary portal issues.
Even in the regional area of the Hunter we have seen pockets where there is a market gap in provision of services to families. With the recent introduction of the $3,000.00 travel cap we have identified that there are some families who are not able to access the services that are required as their chosen service provider cannot travel to provide all supports in the natural setting and/or the family afford to travel to a service provider.
We believe that families are penalised when they lodge an appeal or request a review. Not all funding reflects an even 12 month spread of hours. Often assessments are required before an intervention plan can be developed. The assessment process can be lengthy and absorb a large part of particular funds. This means that the funding should be described as episodic rather than spread evenly over a 12 month period. The practice of “Pro-rata” a plan when an appeal is lodged does not take into account the choices of families in how and when their services will be
provided.
- Roll out of the Information, Linkages and Capacity Building Program ILC is a vital part of the Scheme to meet its outcomes to include people with a disability in the
community.
We believe that the most effective use of ILC funding is to leverage the existing relationships within a community. In the Hunter we have enjoyed collaborative partnerships between government and non- government organisations over many years. These partnerships were characterised by services working together to share information, build capacity of services and community and support young children and their families. One such partnership was the interagency network ECICP (Early Childhood Intervention Coordination Program) which was funded by ADHC until funding ceased in 2015. This networks was used to facilitate the inclusion of children and their families and build the capacity of the community to foster inclusive practices through forums, expos, workshops for families and professionals and general information sharing. ECICP successfully operated for over 15 years and was comprised of early childhood intervention providers, government departments such as Housing, Education, ADHC, Community Services and Health in addition to mainstream services such as Northern Settlement Services, KU, Indigenous and family representatives etc. ILC funded services need to understand the local community and be embedded within the community that they operate in.
Often the barriers to a participant’s plan being implementing in a family is the complexity of the family situation. By adding additional and separate ILC providers and government agencies we layer an additional complexity to a family. Often, these families will choose not to open up to government agencies and avoid contact. Using the service providers who already engage with the family to assist in coordinating supports and building capacity would prove to be more effective, including cost effective.