Adequacy and accessibility of the Approach
This chapter explores adequacy of information and accessibility of the ECEI
Adequacy of information
Families and carers require accurate and accessible information to be
able to make informed decisions about their child's early intervention.
Evidence received indicates widespread dissatisfaction with the quality
of information currently available.
Submitters highlighted that information about the ECEI Approach is
uncoordinated and can only be found through several sources, such as the NDIS
Act, PITC Program Grant documentation, NDIS Price Guide, Operational
Guidelines, and the NDIS website.
The committee received feedback that even experienced staff working for
specialist service providers are finding it difficult to locate relevant and
Ms Michelle Crozier, NDIS Project Manager, Deaf Services Queensland, argued
that information could be presented in a more user-friendly way:
I consider myself quite well versed in the NDIS. I do a lot
of research, I address all our internal questions and I have an academic
background in it, but I still cannot find information doing a simple google
search on the website. It is incredibly frustrating. It requires that I read
the operational guides or it requires that I find the bilateral agreements. It
requires that I know all of those things quite intimately if I'm going to give
a factual and correct answer to a participant who just wants something very
basic. I find that an incredibly frustrating part of it. Yes, the information
is there—I won't say it's not—but to actually interpret it, translate it, find
it and deliver it to a participant who has no service literacy is an incredibly
Ms Natalie Rose, Manager, Advocacy and Engagement, Li-Ve Tasmania,
argued that, for individuals who do not understand the system and are just
reading the Agency's documents, 'it's probably not going to be enough'.
Lack of overarching policy information
Submitters pointed out that information about the ECEI Approach is
currently available through a range of sources. However, the information is
fragmented and fails to provide an overarching explanation of how the ECEI
Approach will support children with disability or developmental delay and their
Submitters expressed concern that there is no uniform understanding of
what Early Childhood Partners should be delivering as part of short-term
At the public hearing in Sydney, Ms Kay Turner, Chief Executive Officer,
SDN Children's Services, argued there needs to be discussion around how
Partners should best use their short-term funds to support families:
...there have been different approaches to early intervention
across the country. But there have been issues, as there are in human services,
in demonstrating efficacy—which things lead to the outcomes? For very young
children, development is happening anyway and young children are involved in
families, so it is very hard to draw correlations between what is working and
what isn't. The literature around best practice early intervention is
available, but when we look at ECEI with the broad requirements and the very
short-term interventions, I would say the evidence is not clear for consistency
nationally about what those short-term interventions should be. There could be
a range of selected processes. For New South Wales, for example, our funding
envelope would have been around $6,000 per place. So to make a decision about
what would work when you have, say, $1,500 per child needs to be a discussion.
Peak body, Early Childhood Intervention Australia (ECIA), argued that
the development of a national policy and guidelines for the Approach would
improve procedural consistency across jurisdictions, provide clarity, improve
response times, and reduce confusion.
Submitters were critical of the NDIS website, and expressed a myriad of
concerns; including that it lacks clear information about the ECEI Approach, is
fragmented, unnavigable, has had documents changed or removed, and provides
According to the Victorian Autism Specific Early Learning and Care Centre, families
across the spectrum are experiencing difficulty finding relevant information
Ms Dee Hofman-Nicholls, Director, Enhanced Health Therapy Services, encapsulated
the criticism when she likened the Agency's website to a 'rabbit warren'.
Suggestions for improvement
The Commonwealth Ombudsman argued that the NDIA could better manage the
expectations of families, providers, and professionals involved in the ECEI
Approach by improving its online material. The Ombudsman suggested the Agency
publish information about the focus of the ECEI Approach, what can and can't be
covered under the Scheme, why Plans may vary, the likely timeframe for
receiving a Plan, and review rights.
The Royal Children's Hospital submission suggested that information should
be relevant to the child's age and difficulties, and provide links to related
services, such as Medicare rebates and community services.
AMAZE argued that the website should provide cohort-specific
information, for example, a dedicated autism section.
Similarly, Mr Brett Casey, Chief Executive Officer, Deaf Services Queensland,
argued that information for the deaf community should be made available in
If we're talking about the website and access to the plan,
all of it is English based...there is no information...in Auslan. The NDIA
recently, early this year, provided some information in Auslan, but we had the
rollout start in July in Queensland last year and until recently there was no
information available in Auslan. Even the information they do now have available
is limited...'What is the NDIS?' and 'Accessing the NDIS' are very, very short
videos that have been made publicly available. In terms of fairness and
accessibility, deaf community members are so far behind in getting access to
Noah's Ark argued that information about ECEI Partners should clarify
the multiple roles they are undertaking, and provide information about the
Partner's relationship with the community.
Service providers argued that the website should also include
for prospective providers interested in learning about the
on the model of intervention being implemented;
to alert stakeholders about changes to policy and procedure;
that is consistent with the 1800 line;
on conflict of interest;
on how Planning priority is determined; and
provide timeframes for determining Access and Plan approvals.
Australian College of General Practitioners (RACGP) stressed the
importance of the role of General Practitioners (GPs) in the ECEI Approach. It
highlighted that GPs are often the first to meet with families who have
concerns about their child's development, and play a significant role as
sources of information and advocacy, in the diagnostic process, referral to
services, and managing associated health issues.
The RACGP argued that the NDIS is currently underutilising this network
of professionals. A recent poll conducted by the RACGP found that 93 per cent
of respondents 'had little information to help facilitate NDIS requests' from
James Best, Member, Specific Interests Child and Young Person's Health Network,
RACGP, told the committee that general practice was
frustrated it had not had enough input during the development of the NDIS,
which has made consistent communication with families difficult:
We really are a bit in the dark once we send people off to
the NDIS to make an application, and we're frustrated that we don't have enough
input into the process. It all seems a bit of a mystery once it goes over to
the NDIS, and we certainly don't get any feedback, as well as not being
integrated into the process.
Best acknowledged that NDIS general practice fact sheets would assist
in one respect, he argued that education programs targeting the role of GPs in
the ECEI process would be of greater benefit to the sector. 
The Agency drew the committee's attention to its general communication efforts
targeting GPs and other health professionals. For example: publications;
information booths and presentations at GP conferences; advertisement on the
Australian Medical Association's 2017 GP Year Planner; and an article in the
December 2017 Good Practice magazine.
The committee acknowledges that the NDIA has made efforts to publish a
range of ECEI-related material on its website. However, it agrees with
submitters that the quality of information currently available for families and
carers could be improved. The committee is concerned by reports that even
experienced personnel working in the sector are having difficulties locating
The NDIA should ensure that information on the NDIS website is logically
presented. All information should be clearly dated, indicate if it has been superceded,
and identify related historical information. Information relevant to the ECEI
Approach should consolidate information from multiple sources, and remove
redundant and contradictory information. Tailored information should be
provided for disability cohorts, such as Auslan and ASD. The Agency should
incorporate submitters' suggestions for improvement, such as: providing a
substantive explanation of the ECEI Approach, its purpose and focus, the role
of Early Childhood Partners, why Plans may vary, Participants' review rights,
and link to websites with relevant information for families.
The committee recommends that the NDIA consult and engage with key
stakeholders to continually improve ECEI information on its website.
Information for GPs
GPs are often the first point of contact for families with concerns
about their child's development, therefore the committee is of the view that
particular attention should be given to information and resources for general
The Agency's GP's Guide to the NDIS factsheet provides brief
information regarding the general pathway, such as: how GPs can provide
supporting evidence for an Access Request, and the process once a person is
granted access to the Scheme.
However, it does not provide GPs with substantive information about the ECEI
The NDIA should harness the opportunity general practice offers as a
source of information to families with concerns about their child's
development. GPs should be provided with information about the ECEI Approach,
the role of Early Childhood Partners, how eligibility is determined for
children under the early intervention requirements, what supports and services might
consist of, and be provided with details of the ECEI Partner arrangements in
their Service Area.
Submitters raised concerns that families of children with a disability
or developmental delay can be overwhelmed by new information at a time when
they are unsure what to look for.
Professor Matthew Sanders, Professor of Clinical Psychology and
Director, Parenting and Family Support Centre, University of Queensland, argued
that more can be done to improve the ability of families and carers to exercise
the principle of choice under the ECEI Approach. He drew the committee's
attention to the current lack of independent information about evidence-based
practices, and the evidence of their value to particular populations:
If we had a website where all evidence based practices that
are pushed out there as having value to this population were accessible
directly to parents as consumers, they could have a look at and get a feel for
what the intervention involves, what their commitment is and what their
requirement is. They could make judgements about whether they feel they have
the capacity to engage in what's being required of them in the intervention...If
you...inform the consumer better about the different products that are available
and had some common lens through which to look at all of them...parents, with an
adviser, could make a truly informed choice about whether it would be
worthwhile to invest their time, effort, money and resources as an individual...
Peak body, ECIA, advised that it is currently developing online modules to
help families and service providers understand what best practice might mean,
however, this does not address the absence of a consolidated, comprehensive hub
of information from the NDIA about available practices and their substantiated
benefit to certain cohorts.
Submitters raised concerns that vulnerable families may be at risk of
disadvantage under the ECEI Approach, as parental competence and advocacy
skills can directly impact the level of funding allocated to a child. This in
turn, can result in inconsistencies between the levels of funding allocated to
families that can clearly communicate their child's needs and those that
struggle to articulate the services required.
Ms Maureen Fordyce, Manager, AMPARO Advocacy Inc, described the difficulty
some vulnerable families can face:
We have an example of a family in Toowoomba with very complex
needs and from a refugee background needing access to interpreters. They
provided evidence from their local GP about their disability, and that evidence
was inadequate, so the NDIA wrote to them and asked for further evidence. They
couldn't read the letter and they had no-one in their lives to explain what was
required, so they never responded within the time frame. So when we contacted
them, they had to restart their application to the NDIS again. That
is not uncommon, from our previous experience, with people trying to access
During the committee's hearing in Melbourne, NDIA officials assured the
committee that the role of the ECEI Partner, and individualisation of packages,
is intended to mitigate potential inequity:
We are expecting our partners to be out in the community and
to visit families and children in the home and natural settings...they can go
into a home and get a really good understanding of what the informal supports
are for the child, and if there is a need for some more supports, from a child
and family support perspective. It's not actually around the family advocating...the
package for the child in the first place, or how they target the supports for
that family, should be geared to where the family is at, and in making sure
that if there's additional supports required to address the needs of a child,
that happens... the individualised package, or the planning and the support that
will be targeted to what's required. So yes, a family that is more
middle-class, and doesn't need more or other linkages to community or
services—as, perhaps, a more vulnerable family would—that would look
differently in that way.
The Victorian Autism Specific Early Learning and Care Centre argued that
establishing and funding advocacy support services for vulnerable ECEI families
is an essential safeguarding framework that must be built into the NDIS.
The Royal Australasian College of Physicians argued that programs specifically
designed to identify and support vulnerable families should be developed, and
charged with identifying developmental delay and providing advice and
Ms Teigan Leonard, Team Manager/Psychologist, Kalparrin Early Childhood
Intervention Program Inc, argued that there is currently a lack of support for
I think it's also using an advocacy model to support the
families, and that's certainly what we find families are looking for. Your
planning meeting is challenging. You're talking about your child on their worst
possible day and all of the things that you need help with as a parent. Some
families have described it as throwing your child under the bus. Having an
advocate there who can help you say what you're trying to say in a way that is
meaningful and who can support you afterwards as well—I think that's the model
that's needed in this sector.
AMAZE recommended that a trusted, independent, and experienced
organisation should be commissioned to develop resources about autism for a
range of audiences in co-design with the NDIA, including autistic
parents/carers, CALD communities, and Aboriginal and Torres Strait Islander
populations to assist families in navigating the system.
The committee is of the view that ECEI Partners do not currently have
the capacity or funding to conduct essential outreach and support services for
vulnerable cohorts. The committee agrees with the Productivity Commission that
adequately resourcing Information, Linkages and Capacity Building (ILC) is
critical to ensure people with disability are connected with appropriate
Whether this is put in place through an advocacy model, or some other type of
support model, the committee welcomes the Commission's recommendation that ILC
funding should be increased throughout the NDIS transition phase. The committee
considers that allocating specific funding for information and support for
vulnerable families to connect with ECEI Partners through the ILC program is
essential to the success of the ECEI Approach.
The committee recommends that the NDIA allocate specific funding for
information and support for vulnerable families to connect with ECEI Partners
through the ILC.
Accessibility of Approach
Aboriginal and Torres Strait
Absence of culturally sensitive
There are concerns that the unique cultural circumstances of Aboriginal
and Torres Strait Islander people are not being taken into consideration under
the ECEI Approach.
For example, the Planning process does not account for flexible family and
and the design and use of assessment tools are inappropriate for Aboriginal and
Torres Strait Islander communities.
The committee heard evidence that the concept of 'disability' is not one
that Aboriginal and Torres Strait Islander people readily identify with,
and there is often no equivalent term for 'disability' in many Aboriginal
The Queensland Government raised concerns that engaging one ECEI Partner
for each geographical location may have a negative impact for Aboriginal and
Torres Strait Islander children who require culturally appropriate supports.
Submitters argued for improved cultural competency within the NDIA, and
non-Indigenous providers, and for services to be tailored to meet the needs of
Aboriginal and Torres Strait Islander people.
ECIA highlighted that there are currently few incentives for service
providers to actively show that they are able to respond to the needs of Aboriginal
and Torres Strait Islander communities. It suggested that early intervention
services should be required to incorporate cultural awareness training for
General accessibility concerns
In addition to specific cultural needs of Aboriginal and Torres Strait
Islander communities, the remoteness of some communities means there is limited
phone and internet coverage for access to the portal or the NDIA, and an
ongoing lack of specialist services.
The committee's attention was also drawn to the lack of sensitive,
targeted material for Aboriginal and Torres Strait Islander populations.
Following consultation with remote communities, the Commonwealth Ombudsman
reported that many Aboriginal and Torres Strait Islander people are having
difficulty understanding NDIA materials.
It found that many families who have received a Plan are often unsure how to
use it to access supports and, as a result, many have not spent any funds
during the 12-month period.
Mr Mark Baigent, Chief Executive Officer, Kalparrin Early Childhood
Intervention Program Inc, expressed similar concerns:
We are dealing with nine ATSI families at the moment within
our organisation—not a significant number, but it's very hard work even getting
that nine well connected. It's crucial that those families have a culturally
sensitive pathway from the beginning to the end in terms of their interaction
with the NDIS, and we are certainly aware of two families that are funded in
excess of $25,000 per child with up to three children in each family involved
under the NDIS. They've been holding their money for six months because they do
not know how to enter the scheme, they do not know who is going to support them
and they can't find culturally sensitive pathways, and their linkage from the
scheme into the support regime hasn't been effectively handled. So there are
gaps there that the ATSI families need support and help with to ensure that
they're given the same opportunities as every other family.
Submitters argued that information should be developed in co-design with
communities, and delivered in a variety of languages to ensure that particular
cohorts are not disadvantaged.
In March 2017, the NDIA released its Aboriginal and Torres Strait
Islander Engagement Strategy. The strategy was based on the experience of the
trial sites and the expertise of the Aboriginal and Torres Strait Islander
Reference Group and associated working groups. It outlines the Agency's
commitment to working with Aboriginal and Torres Strait Islander peoples, and identifies
10 priority areas for engagement.
The NDIA is currently working to develop tailored pathways for people
from Aboriginal and Torres Strait Islander communities.
For example, it is developing culturally safe and responsive strategies
to improve access to holistic allied health services for Aboriginal and Torres
Strait Islander peoples with disability in collaboration with Indigenous Allied
The Agency—with the Department of Premier and Cabinet and the Department
of Social Services—is partnering with local communities to develop place-based
models for the delivery of the NDIS. Projects are underway in Anangu
Pitjantjatjara Yankunytjatjara; East Arnhem; Ceduna; Mornington and Doomadgee;
and Western Sydney.
The NDIA is also proposing to launch a grant round of ILC specifically
targeted to rural and remote communities in the second half of 2017.
The committee is troubled by reports that there are Aboriginal and
Torres Strait Islander families unable to use allocated funding because they are
unsure how to access services. The committee agrees with submitters that investment
in accessible information for a range of audiences is required. The committee considers
that resources should be developed in co-design with people with disability, Aboriginal
and Torres Strait Islander populations, and CALD communities to assist them to
understand the Scheme, and how to use their funds to access services.
The committee recommends that the NDIA collaborate with people with
disability, Aboriginal and Torres Strait Islander, and CALD communities, to
co-design and develop accessible information about the Scheme, the ECEI
Approach, and how to use funds to access services.
The work undertaken by the NDIA in developing an Aboriginal and Torres
Strait Islander Engagement Strategy is a positive step. However, it is
imperative that the NDIA develop a specific strategy to ensure that culturally
appropriate early intervention services are delivered for this community by
The committee recommends that the NDIA develop a specific strategy to
deliver culturally appropriate services for Aboriginal and Torres Strait
Islander people under the ECEI Approach.
Hon Kevin Andrews MP
Senator Alex Gallacher
Navigation: Previous Page | Contents | Next Page