Mental Health

Australia WN

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 Mental Health Australia

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Foreword4 Executive6 Introduction Population11 Estimates13 National13 Individual15 Group17 Residential19 Family20 Contributing22 Current25 Expenditure Community25 Service26 Policy28 Defining28 Potential30 Recommended35

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Foreword

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4. Introduction

The purpose of this paper is to consider the existing policy framework underpinning the NDIS, as it applies to psychosocial disability, and to recommend policy shifts and operational changes. This analysis is informed by data from the NMHSPF regarding the needs of the population in question.

The original conception of the NDIS by the Productivity Commission (PC) reflected an intention to ensure the needs of the severely disabled were catered for over the duration of their lifespans. The PC report makes clear that the intent of the NDIS is not for “the scheme to address the care and support needs of all individuals, but rather should focus on those where such needs are greatest”.

The PC foresaw three tiers of support, ranging from early, population based, interventions, through linkages to care pathways through the Information, Linkages and Capacity Building Framework (ILC), previously known as tier 2, and finally intensive Individually Funded Packages (IFPs), previously known as tier 3.

In the area of psychosocial disability there are already a range of services being provided in the community by the Commonwealth government and individual state and territory governments that cut across each of the three tiers of support.

Funding of the NDIS has involved bi-lateral agreements between individual state and territory governments and the Commonwealth Government. The inclusion of existing mental health program funding in those financing arrangements has not been uniform: in some states existing mental health funding has been added to a state’s contribution to the NDIS; in others it has not. In some cases state-funded, IFP-targeted programs have been transferred but programs targeted at tier 1 and ILC populations have been retained by the states. In some cases programs that traverse all three tiers have be transferred in their entirety.

Policy accountability for the implementation of the NDIS sits with the Disability Reform Council under the Council of Australian Governments (COAG) framework. This body is made up of Ministers from the Commonwealth, states and territories with responsibility for disability services, but does not include Ministers with responsibility for health or mental health.

There are a number of unanswered questions which arise from these funding and policy arrangements. For example, what is the NDIS responsible for in a policy and operational sense? Is the Disability Reform Council only setting policy parameters for supports for those with an IFP? If so, how are they being synthesised with the policy parameters for those who don’t meet the IFP criteria?

There is a risk that the NDIS will set up a funding and policy framework for IFP only, and other governments will have to work reactively around that in determining responses to other types

of presentations. This creates a significant risk that policy will be driven by cost shifting, rather than by a focus on improving outcomes.

A related concern is about what happens to the services transferred into the NDIS, which currently provide services for clients out of scope for an IFP. How will the continuity of service guarantee in the Intergovernmental Agreement (IGA) be monitored, and which jurisdiction is responsible for rectifying poor outcomes? Who is responsible for ensuring that a community support system exists for those who do not qualify for an IFP? How are those who would have received support in the future, if current arrangements had continued, meant to navigate this system?

Annexure E of the IGA for the NDIS provides for continuity of support for existing recipients of community support who do not meet NDIS access criteria. However, it only applies to those already receiving a service when the launch sites were established. It does not apply to the cohort of individuals with the same presenting circumstances who were not in a program at the time, or whose need for support at that level manifests in the future. As such there is a future cohort of people who under current policy arrangements are considered to require support, who under the NDIS implementation will no longer be able to receive it, unless some alternative non-NDIS arrangements are provided. In the psychosocial disability space this population is substantial, as this paper will make clear.

ILC supports may address these questions, but that appears doubtful if current policy thinking is any guide.

Annexure E of the IGA does not specify the precise funding or policy commitments that governments are making to ensure continuity of support. Clause 14 states ‘each government will be responsible for determining how it wishes to provide continuity of support’. This lack of detail could lead to significant confusion for referring services and public sector agencies and incompatibility across systems. This may mean, for example, that consumers receive conflicting advice from their clinical service providers on the ground.

The underlying message of the continuity of support commitment as articulated in Annexure E appears to be that support arrangements are a matter for the national framework only if someone is accepted into the NDIS. This does not allow for the creation of a seamless, well-understood system, where perverse incentives and the risk of gaming or cost-shifting are minimised. The narrow focus on those already receiving support could be interpreted by those charged with implementing policy that any support systems outside the NDIS are only legacy systems which will decay as current participants transition into the NDIS. There is a clear need to review the existing continuity of support commitments prior to transition to full scheme.

The NDIS offers considerable opportunities for those with a mental illness to achieve the supports they need to live in the community, and to do so within a predictable, organised system driven by their own goals and perspectives on service offerings. To prevent unintended consequences in the reform process, it is important that the NDIS builds on the strengths of the existing system wherever possible, and utilises expert judgements about the impairment thresholds necessary for different kinds of support.

This paper will address the concerns of the mental health sector about the impact of the NDIS on the existing mental health support system. Some of these impacts will be a highly desirable, while others will be significantly problematic. The paper:

¢ Quantifies the number of people requiring community support for a mental health condition.

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PAGE 24

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Page 41

The policy framework does not indicate however the overall budget for the ILC program or the split between the five streams.

The final stream, Local area Co-ordination is a navigation tool for people to make full use of mainstream services and informal services outside the NDIS. It has a heavy focus on prevention activities, community inclusion and the development of networks. It is unlikely to have a significant overlap with the NMHSPF taxonomy however there are some components that are reflected in this stream.

It is important to understand how much funding is going into the ILC program and how it is to be split between the streams, in order to assess how much of the non IFP need will be met by this program.

The implementation and operation of the psychiatric . <A g 41 disability elements of the National Disability Insurance mhaustralia.org =°> Scheme: A recommended set of approaches WN

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The implementation and operation of the psychiatric disability elements of the National Disability Insurance Scheme: A recommended set of approaches

Mental Health

The implementation and operation of the psychiatric disability elements of the National Disability Insurance Scheme:

A recommended set of approaches

Page 3

Foreword

4. Introduction

The Provision of Services Under the NDIS for People with Psychosocial Disabilities Related to a Mental Health Condition

Individual

Page Text

Page Text

Governments Commit

Page 41