Submission regarding the Joint Standing Committee on the NDIS: Transitional arrangements for the NDIS
August 2017
We welcome the opportunity to provide a submission to the Joint Standing Committee on the National Disability Insurance System (NDIS) into transitional arrangements for the NDIS.
The introduction of the NDIS presents the opportunity to improve the lives of thousands of people living with disability and their family and carers. Already, there are many great stories of how lives have been changed as a result of these reforms. However, we have concerns about how the implementation of these reforms will work for vulnerable groups. The success of the reform is based on an assumption that all consumers have equal capacity to exercise choice and control - a key challenge is how to ensure that the reforms work for everyone. Our submission details our concerns and potential solutions to the significant implementation challenges ahead.
Judy Slatyer
Chief Executive Officer
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Summary of Recommendations
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The NDIA develops targeted mechanisms to ensure that vulnerable people, particularly those most at risk of deep social exclusion, are supported to access and engage with the scheme and that these mechanisms are co-designed with participants.
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The NDIA continues to investigate thin markets and co-designs mechanisms for addressing thin markets with participants and other key stakeholders.
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Further attention is focused upon transport as a critical enabler to service access.
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The interface between the NDIS and justice systems are urgently examined to implement an effective and integrated throughcare approach for people who are NDIS participants or who may be eligible for the NDIS, with particular emphasis on Aboriginal and Torres Strait Islander peoples.
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The NDIA consistently assesses and monitors the scheme eligibility (prior to full scheme rollout) for people experiencing psychosocial disability and provide “continuity of care” during the transitional period.
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Commonwealth, State and Territory Governments develop with relevant stakeholders, appropriate longer term support arrangements for people experiencing psychosocial disability to ensure that they are not disadvantaged by the implementation of the NDIS.
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The options detailed by Mental Health Australia on recovery oriented psychosocial support be adopted to provide clearer definitions of NDIS eligibility criteria for people with psychosocial disability.
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The NDIA ensures that initial assessments and planning with participants and their families be conducted face to face with adequate notice for people to prepare, including arranging supporters or advocates to be present as necessary.
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The NDIA ensures that planning teams have relevant skills and expertise including in psychosocial disability and co-morbidity factors, in order to better support the crucial initial planning session with participants.
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That the Commonwealth implement the Productivity Commission’s recommendation that ILC should be fully funded during NDIS implementation in order to ensure successful implementation.
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The boundaries and interface of NDIS service provision, and other non-NDIS service provision, with particular reference to health, education and transport services.
We recognise the immense challenge of implementing the transitional arrangements in a reform of such ambitious size and scope within a relatively short period of time. We have concerns about how the NDIS will interface with mainstream services. In particular, we are concerned for consumers who may be at the intersection of various systems including the aged care and disability service systems, such as those people currently receiving state funded disability services who, because of their age, will be ineligible for an individualised support package. Whilst we recognise the Department of Health’s commitment to Continuity of Care packages for people currently receiving supports, we are concerned that older people who acquire or develop a disability after the NDIS is implemented and for whom state-based supports are withdrawn, will be unable to access the supports they require.
We commissioned a review on how user choice reforms (NDIS and aged care) might impact people experiencing extreme vulnerability (refer Attachment 1). We are concerned that without support, people experiencing vulnerability may struggle to navigate across the NDIS and other systems and be unable to access the supports they require. This is a particular concern given that the role of funded advocacy supports remains unclear at this time.
Recommendation:
The NDIA develops targeted mechanisms to ensure that vulnerable people, particularly those most at risk of deep social exclusion, are supported to access and engage with the scheme and that these mechanisms are co-designed with participants.
We are concerned about the emergence of thin markets and the effect of this on vulnerable people, particularly in rural and remote locations. In remote locations, it seems likely there will not be an increase in choice and control for many people. It is critical that needs of Aboriginal and Torres Strait Islander peoples and communities are well understood and that planning fully engages them in the design of solutions.
Recommendation: The NDIA continues to investigate thin markets and co-designs mechanisms for addressing thin markets with participants and other key stakeholders.
In a recent co-design project we interviewed clients, volunteers, carers and staff from three diverse Personal Helpers and Mentors (PHaMs) sites to better understand the experience of mental health and the service supports available. From this process, several potential solutions emerged that were designed to enable people living with mental health concerns to live connected, meaningful lives as valued members of their communities. We are now in the process of testing the feasibility, viability and desirability of some of these solutions in a real life context. Through this project, we were interested to discover the extent to which access to transport was an issue for consumers, volunteers, carers and sector stakeholders across all locations (Port Pirie, Kalgoorlie and Hervey Bay). For consumers transport was a limiting factor in people’s social lives in addition to affecting their access to health and medical services. Amongst a range of concerns, people spoke of the challenges
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posed by public transport (physical access, safety, timing, infrequency and limited travel routes), taxis (cost, short trips and refusal of service) as well as specialised vehicles (lack of access and constraints on availability). The issue of access to transport is a factor in the case study of Demi, in attachment one, who uses a public bus service to travel 43 km to see her GP and mental health nurse. Transport was also raised by volunteers as being a barrier to be able to do the type and amount of volunteering they would like to do. Service providers reported that a lack of transport was a barrier to being able to access hard to reach clients through outreach services.
Recommendation:
Further attention is focused upon transport as a critical enabler to service access.
Through our co-design project, we also discovered that people with mental health concerns faced barriers interacting with the health system. People found it very difficult to access a GP who could understand their concerns, often a function of short appointments and long waiting lists and times between appointments. In regional locations, specialists such as psychiatrists operate on a fly in fly out model, making it difficult to build a trusting connection and receive meaningful support. Conversely, finding a peer worker that better understood their experience was often seen as life changing experience.
We are concerned about the lack of integration between the NDIS and the justice system, particularly given the high rates of disability in prison populations and in particular for Aboriginal and Torres Strait Islander peoples who are significantly overrepresented in the criminal justice system.
Recommendation:
The interface between the NDIS and justice systems are urgently examined to implement an effective and integrated throughcare approach for people who are NDIS participants or who may be eligible for the NDIS, with particular emphasis on Aboriginal and Torres Strait Islander peoples.
The consistency of NDIS plans and delivery of NDIS and other services for people with disabilities across Australia.
We have significant concerns about eligibility for NDIS individualised funding packages for people experiencing psychosocial disability. Our initial estimates of eligibility with our Personal Helpers and Mentors program clients indicate that only 30% would be eligible for a package, leaving many without necessary supports and uncertain where else to turn for help.
Recommendations:
The NDIA consistently assesses and monitors the scheme eligibility (prior to full scheme rollout) for people experiencing psychosocial disability and provide “continuity of care” during the transitional period.
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Commonwealth, State and Territory Governments develop with relevant stakeholders, appropriate longer term support arrangements for people experiencing psychosocial disability to ensure that they are not disadvantaged by the implementation of the NDIS.
The options detailed by Mental Health Australia on recovery oriented psychosocial support be adopted to provide clearer definitions of NDIS eligibility criteria for people with psychosocial disability.
We are concerned that for those who are deemed eligible for an individual package on the basis of their psychosocial disability, reports are emerging of NDIA planners having limited experience and expertise in developing appropriate support packages. A specific issue with planning has been the reliance on planning meetings by phone and that participants and carers were unable to fully prepare for and represent their needs. For many people, (particularly vulnerable people who may face barriers in engaging with government service systems), the development of their first NDIS plan is a critical point that not only ensures they are able to access the supports they need, but will also shape their first impressions and willingness to engage with and trust the NDIS. Breaking trust at the initial planning point through either a poor understanding of psychosocial disability or pursuing a plan over the phone before a participant is ready may turn people away from the scheme.
Recommendation:
The NDIA ensures that initial assessments and planning with participants and their families be conducted face to face with adequate notice for people to prepare, including arranging supporters or advocates to be present as necessary.
The NDIA ensures that planning teams have relevant skills and expertise including in psychosocial disability and co-morbidity factors, in order to better support the crucial initial planning session with participants.
The rollout of the Information, Linkages and Capacity Building (ILC) Program
We believe that the ILC is an essential component of the overall scheme.
We anticipate that it will be able to provide holistic support for vulnerable groups who may struggle to navigate the system, or engage across mainstream and disability services, including for:
People with non-permanent or episodic disability People who formerly received state/territory disability support People in need of advocacy support People with disability with other complex support needs delivered by mainstream sectors such as health, mental health and housing People with disability needing referals to mainstream supports generally.
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The final report from the previous inquiry undertaken by this committee on psychosocial disability indicated that there is concern that ILC is not going to be able to fill the transition gaps. It appears that additional investment will be required to meet the needs of people outside of individually funded packages, particulalry in the capacity building stream.
Recommendation:
That the Commonwealth implement the Productivity Commission’s recommendation that ILC should be fully funded during NDIS implementation in order to ensure successful implementation.
A note on the User Choice Report and Forum
The launch of the Who’s at risk of missing out in the user choice reforms? report (attachment 1) was held during the User Choice Forum (18 August 2017). Red Cross hosted this forum to discuss the findings of this report with stakeholders from across the aged care and disability sectors. Over 30 representatives from the Department of Social Services, Department of Health, service organisations, peak bodies, academics and corporates attended. Participants came together to hear from representatives from the Department of Health and Department of Social Services about the implementation challenges involved in each sector (aged care and disability), the research into who was at risk of missing out and the case for considering the challenges of the new user choice reforms across both sectors. Participants developed a shared vision of what it would look like in 2030 if these reforms were successful and the enablers that would be the major influences on success. While analysis and follow up from the event is still underway, we are working to develop and facilitate a shared program of service development, advocacy and research activities across the sector that will work directly towards the vision for a successful NDIS (and aged care reforms) by 2030.
Attachment 1
Report: Who’s at risk of missing out in the user choice reforms?
This report is a summary of a rapid review we commissioned in 2016 to help us to understand who was at risk of being disadvantaged through the introduction of user choice systems across both the NDIS and aged care reforms. The full review can be made available upon request.
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