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Issues raised in evidence
This chapter considers progress made in addressing issues identified
during four inquiries undertaken by the committee, and which have received a
Government Response, namely:
- Provision of services under the NDIS for people with psychosocial
disabilities related to a mental health condition (report tabled 15 August
- Provision of services under the NDIS Early Childhood Early
Intervention Approach (report tabled 7 December 2017);
- Transitional arrangements for the NDIS (report tabled 15 February
- The provision of hearing services under the NDIS (Interim report
tabled 14 September 2017 and final report tabled 21 June 2018).
Provision of services under the NDIS for people with psychosocial
disabilities related to a mental health condition
Between November 2016 and August 2017, the committee undertook an
inquiry into the provision of services under the NDIS for people with
At the time of the inquiry, the key issues raised in evidence were
- the eligibility criteria, including the lack of clarity and
guidelines leading to inconsistency in eligibility outcomes;
- access to the NDIS and its planning process;
- continuity of supports for people not eligible for NDIS support;
- provider of last resort arrangements, including for people in
indefinite detention; and
- access to NDIS support services for people in custody.
On 15 August 2017, the committee released its report and made 24
recommendations aimed at strengthening the effectiveness of the Scheme to
ensure that people with psychosocial disabilities can be appropriately
A Government Response was provided in March 2018, indicating support for
20 recommendations and providing information of initiatives underway to address
the key issues raised in the report.
On 26 February 2019, the committee held a roundtable with
representatives of the mental health sector to gauge progress since the release
of the report.
Notwithstanding the recent initiatives undertaken by the NDIA to
ameliorate support for people with psychosocial disability eligible for the
NDIS, it appears that very little progress has been made to address the key
issues identified during the inquiry.
In essence, the challenges associated with the transition to the NDIS
for eligible participants and continuity of support for those outside the
Scheme remain significant.
At the roundtable, the committee heard that issues around
inconsistencies in eligibility and planning outcomes, as well as issues with
the planning process and adequacy of plans, were continuing to jeopardise
people's access to appropriate, reasonable and necessary supports.
Roundtable participants also expressed deep concerns about the
uncertainty of and lack of clarity for access to continuity of supports for
those ineligible for the NDIS. Whilst this issue had been identified during the
initial inquiry, roundtable participants flagged the urgency of progressing
this matter as key Commonwealth funded programs such Partners in Recovery (PIR),
Personal Helpers and Mentors (PHaMs) and Day to Day Living (D2DL) are scheduled
to end on 30 June 2019.
The NDIS experience
At the time of the inquiry, the committee received evidence that access
to the NDIS, as well as, the planning process to develop and review NDIS plans,
had not been operating well and had often resulted in unsatisfactory outcomes
for participants with a psychosocial disability.
The NDIA has recognised the need to improve the NDIS process from the
points of access to the Scheme to the implementation of participants' plans. As
a result, the NDIA is currently rolling out a range of initiatives to improve
people's individual journeys with the NDIS through NDIS participant pathway
reform. This includes the establishment of tailored pathways for cohorts who
have specific disability, cultural and / or communication needs.
Psychosocial disability stream
On 10 October 2018, the Minister for Families and Social Services
announced the establishment of a 'psychosocial disability stream' to provide a
better pathway and support to people with a psychosocial disability eligible
for the NDIS.
The new stream includes:
- the employment of specialised planners and Local Area
- better linkages between mental health services and NDIA staff,
- a focus on recovery-based planning and episodic needs.
The psychosocial disability stream was introduced in specific locations
in Tasmania and South Australia in November 2018, followed by Victoria and NSW
in conjunction with the implementation of the complex support needs pathway.
Roundtable participants were unable to comment on the new psychosocial
disability stream as it is yet to be rolled out beyond a few specific
Ms Carmel Mary Tebbutt, CEO of Mental Health Coordinating Council
(MHCC), said it was 'a very welcome announcement' but added that more
information about how the stream is operating would be beneficial:
[...] there would be a desire for a greater amount of
information about how those trials are running and how they're going to be
evaluated to take advantage of the great wisdom and knowledge that sits with
service providers and consumers in contributing to the trials, because there
isn't a lot of information yet as to how that is all actually rolling out.
Mental Health Australia agreed with the MHCC statement and emphasised
the need to evaluate those trials so they could be taken to scale.
Mental Health Australia also pointed out that these trials were 'an
opportunity for collaboration between the mental health sector and the NDIA to
refine NDIA's approach to planning and pricing services'.
Roundtable participants pointed out that the sector has done significant
work with Mental Health Australia on the 'Optimising Psychosocial Support
Project', which can be used to refine the psychosocial stream pathway.
Mental Health Australia recommended that the implementation of the
psychosocial disability stream 'be carried out in an open and transparent
manner, with relevant data and information on progress published on a regular
Inconsistency in eligibility and
At the time of the inquiry, the lack of clarity around eligibility
criteria, the apparent reliance on diagnosis rather than functional needs, the
absence of a validated assessment tool for planners, and reported lack of
skills and expertise of planners in the mental field were identified as key
contributors to inconsistencies in eligibility and planning outcomes.
At the February 2019 roundtable, according to Mind Australia, inconsistencies
in eligibility outcomes remain common:
I have with me some examples of people with the same
diagnosis and presenting functional impairment in similar contexts, but one
gets in and the other doesn't.
Similarly, inconsistencies in planning outcomes continue to be observed:
I've certainly had national providers say to me that
demographic groups that look very similar in two different parts of the country
can have variants of plan size of to 100 percent – so, $15,000 averages in one
region and $30,000 averages in another region – for population groups that for
their intents and purposes look exactly the same.
Mr Mark Orr AM, CEO of Flourish Australia Ltd, also commented on the
differences in funding and supports between regions:
[...] depending on where you are in the country you get a very
different experience, a very different plan and a very different amount of
support that's funded.
The key drivers of these inconsistencies appear to remain the absence of
a standardised assessment tool and the lack of skills and expertise in mental
health of planners.
Standardised assessment tool
The committee had recommended the development and introduction of a validated
fit-for-purpose assessment tool to assist addressing these inconsistencies in
eligibility and planning outcomes.
The Australian Government supported this recommendation and advised the
committee that the NDIA was progressing the selection of an existing
appropriate functional assessment tool, and the development of reference
packages for people with psychosocial disability. The assessment tool was
expected to be progressively introduced from early 2018.
The NDIA recently advised the committee that the Agency continues to
trial appropriate functional assessment tools for people with psychosocial disabilities.
This includes the Life Skills Profile (LSP) assessment tool, which has been
included as part of the Independent Assessment Pilot in service delivery areas
in New South Wales.
At the roundtable, Ms Robyn Hunter, CEO of Mind Australia pointed out
that there was still a need for 'adoption of an assessment process that
actually takes into account fluctuating functional impairment, not just
Mental Health Australia also reiterated the urgent need to implement a
validated, agreed and transparent assessment tool.
Training of staff
A perceived lack of skills and expertise of planners remains a concern as
it impacts on consistency of eligibility decisions and adequacy of plans.
As part of its efforts to ameliorate its processes, the NDIA advised
the committee it had delivered training on access and psychosocial disability
to approximately 1440 NDIA staff, LACs and providers during 2018. Additionally,
the NDIA indicated that all staff are supported in decision-making by a range
of technical and operational advice materials, specialists and advisors.
Mr Angus Clelland, CEO of Mental Health Victoria, is of the view that
some of the challenges will be overcome by the NDIA commitment to train
planners in psychosocial disability, but pointed out that this initiative needs
to be 'fast tracked'.
Ms Carmel Tebbutt, CEO of MHCC, explained to the committee that MHCC has
delivered some training to NDIA staff but that 'it is difficult for people to
find the time to attend the training because there are so many demands on NDIA
Mr Mark Orr AM, CEO of Flourish, expressed concerns about Ms Tebbutt's
report that NDIA staff are too busy to attend training, and stressed the
importance of delivering training, which has been developed by people with
Mental Health Australia also made a number of recommendations aimed at developing
the skills, knowledge and experience of NDIS staff and planners, pointing to
the need to actively involve the sector in the development of a psychosocial
competency framework for NDIA staff.
Adequacy of plans
Roundtable participants were of the view that the way plans are
currently constructed does not meet the needs of participants with a psychosocial
disability. In particular, plans continue to lack the flexibility to respond to
the fluctuating needs of participants with a psychosocial disability.
Ms Robyn Hunter, CEO of Mind Australia reported that around 80 percent
of the plans are inappropriate or inadequate.She
explained to the committee why most plans do not meet participants' needs:
The quantum of funding is generous for people who do get a plan,
but they're constructed with a very inflexible structure. Plans are frontloaded
with 'core' [...], which is exactly what a lot of these people don't need. They
actually need to have flexible supports that are geared towards building their
capacity and independence.
Similarly, Tandem reported that plans are often inadequate and not based
on a recovery model:
Plans loaded up with core supports are keeping people in situ
in a stagnant life, without the level of capacity building supports such as
therapies to build on personal recovery goals in a meaningful way. These plans
are frequently not fit-for-purpose.
Funding in plans
The committee also received evidence that inadequate levels of funding
in plans also remained a live issue:
In terms of immediate priorities, Neil mentioned the dollar
plans or low-value plans. We need to target those in very short order. There is
a practical problem here in that if someone has a plan or has been accepted
into the NDIS [...] they're becoming ineligible for state services, and then
they're left with nothing. We need to action that very quickly.
Continuity of support and funding
of services outside the NDIS
Given that the majority of people who experience mental ill-health will
not access the NDIS, the continued provision of services for people outside the
Scheme is particularly important.
Indeed, according to Mental Health Australia, about 300 000 people with
a severe mental health condition have a need for some form of individualised support. At full Scheme, the NDIS will meet the social support needs of around 64 000 of
this group. As Mr Frank Quinlan pointed out, these figures give an indication
of the scale of the population outside the NDIS that requires access to a range
of support services.
At the time of the inquiry, the committee found that there was
uncertainty about what psychosocial support programs would be available to
people outside the NDIS, especially once the transition period has ended.
The committee recommended Australian, state, and territory governments
clarify and make public how they will provide services for people who are not
participants in the NDIS. The Australian Government supported this recommendation but was not in a
position to provide any details itself, as agreements and negotiations with
states and territories were still in train at the time of its response.
At the roundtable, the issue of continuity of support was central to the
discussions. Roundtable participants stressed the urgency of clarifying how continuity
of support will be provided because some of the Commonwealth funded programs
are due to end on 30 June 2019.
Clients of existing Commonwealth
programs transitioning to the NDIS
During the inquiry, the committee found that a significant number of clients
of Commonwealth programs transitioning to the NDIS would not be accessing the
Scheme and that continuity of support for these clients had become uncertain.
A key reason for the uncertainty of continuity of support put forward
by submitters was the requirement for existing clients of Partners in Recovery
(PIR), Personal Helpers and Mentors (PHAMs) and Day to Day Living (D2DL) to
test their eligibility for the NDIS in order to access continuity of support.
The committee had noted that such requirements would likely result in
some existing clients losing supports. Consequently, the committee recommended that clients currently receiving mental
health services, including services under Commonwealth programs transitioning
to the NDIS, should not have to apply for the NDIS to be guaranteed continuity
of supports and access services.
This recommendation was not supported by the Australian Government. The
rationale for not supporting the recommendation was:
- funding for the PIR, D2DL, PHaMs and MHR:CS programs is
transitioning to the NDIS on the basis of the close program alignment with the
NDIS and the majority of clients are expected to be eligible;
- the Government considers it is in the best interests of existing
clients to have the opportunity to test their eligibility with the assistance
of trusted support workers who are most familiar with their individual
circumstances and needs; and
- NDIS participation will provide guaranteed lifetime support and
better outcomes for former program participants.
At the recent roundtable, Mr Frank Quinlan from Mental Health Australia
commented that he did not understand the government's rationale, as a very
large proportion of those people are not going to be eligible for the NDIS.
Indeed, at the roundtable, the committee received further evidence that
participants in existing Commonwealth mental health programs continue to
experience a high rejection rate despite having a severe and enduring mental
We're experiencing at Mind Australia a 50 percent rejection
rate of people who have been participating in the Partners in Recovery program.
By their very definition, they have severe and enduring mental ill health.
Similarly, Ms Carmel Mary Tebbutt, CEO of Mental Health Coordinating
Council reported that a study by their national peak body and the University of
Sydney is showing so far that more than 50 percent of participants of PHaMs
program who had applied for the NDIS had been found ineligible for NDIS
Mr Frank Quinlan, CEO of Mental Health Australia further explained:
[this] means we're forcing a huge population of people who
are unsuitable and should perhaps never be considered for the NDIS to
nonetheless test their eligibility for the NDIS in order that they qualify for
those continuity of support programs outside the NDIS. [...] I think it's bad for
the system and it's bad for those individuals [...].
Mental Health Australia is of the view that the requirement that people
in existing programs need to test their eligibility for the NDIS in order to
gain continuity of support should be lifted.
Because of the requirement to test eligibility, roundtable participants stressed
the need to extend these programs beyond 30 June 2019 to enable all existing
clients to go through the process:
The priority from our perspective is the looming funding
cliff where all Commonwealth funding to Day to day Living, PHaMs and PIR end on
30 June. [...] There's no way in the world, given the pace that the NDIA is
working at the moment, that those people remaining will be able to go through
the eligibility process and have it tested.
The ongoing lack of certainty and clarity around how continuity of
support will be delivered beyond 30 June 2019 was another reason for
recommending the extension of these programs:
We know that continuity of support commitments have been made
by the government but it is unclear how that is going to play out in practice.
Even the primary health networks don't yet know what sort of funding they're
going to get or how they'll manage that funding.
Roundtable participants indicated to the committee that these Commonwealth
funded programs should be extended for at least two years to ensure that all
people can test their eligibility and have access to continuity of support.
Need for further investment
More broadly, roundtable participants were concerned about the gaps in
programs and funding for those outside the NDIS.
According to Mental Health Australia, the current investments in
'continuity of support' and other measures are not addressing 'the major gaps
that are opening up in psychosocial support and community based mental health
as the NDIS is rolled out, and as related programs are being wound back'.
The Western Australian Association for Mental Health contended that the 'alternative
arrangements currently proposed after program cessation (Continuity of Support
and National Psychosocial Support Measures) are vastly underfunded'.
Similarly MHCC and Mental Health Victoria stated that funding outside
the NDIS was insufficient to cover the needs of people who require supports. For example, MHCC stated:
[...] even with the community of support funding, it's not
going to be enough to support all of the people who need support who are not
going to get a plan through the NDIS, particularly people who are currently not
in any sort of Commonwealth supported program or going to get an NDIS plan. It
is unclear about what source of support there is for that group of people,
because the continuity of support money will not be enough and will not cover
that group. It's that gap.
The committee is concerned by the lack of progress in ensuring that
people with a psychosocial disability can access appropriate support services
under the NDIS or outside the Scheme. Overall, the issues identified during the
inquiry remain unresolved. The recommendations made by the committee, which
were supported by the Australian Government have barely been progressed or
acted on. The committee strongly encourages the NDIA to review these recommendations
and assess how they could be swiftly implemented.
Psychosocial disability stream
The committee welcomes the establishment of a psychosocial disability
stream. In theory, this new stream should address the many issues associated
with access to the NDIS, the planning process, adequacy of plans and
implementation of plans. It is too early to comment on the effectiveness of the
initiative as it appears to be only trialled in a few specific locations.
Secondly, too little information is available on how the stream has been
developed to assess its appropriateness.
The committee is concerned that the NDIA appears not to actively engage with
the sector and build on its experience and expertise to ensure the psychosocial
disability stream is providing an adequate pathway to support people with a psychosocial
disability before it is rolled out nationally. For example, roundtable
participants mentioned the work undertaken by the sector around the Optimising
Psychosocial Support project, which can inform the NDIA's work on how to
optimise the quality and appropriateness of the psychosocial disability stream.
The committee recommends the NDIA immediately commit resources to work
with the mental health sector to refine the psychosocial disability stream before
it is rolled out nationally to ensure it is fit-for-purpose.
The committee is concerned that no timeline has been publically
communicated as to when and how the psychosocial disability stream will be
rolled out nationally. Concrete measures to ameliorate the planning process and
ensure that participants can implement their plans are needed urgently.
Importantly, the skills and expertise of the NDIA staff and planners working in
the psychosocial disability stream will be critical to the success or failure
of this specialised stream.
The committee recommends the NDIA immediately commit resources to
provide additional training in mental health to staff and planners to rollout
the psychosocial disability stream nationally during 2019.
Continuity of support arrangements
for existing clients of Commonwealth programs transitioning to the NDIS
The uncertainty and lack of clarity around how continuity of support arrangements
will be delivered in the near future requires urgent attention from all governments.
Whilst there is a commitment from government to provide continuity of support
and some funding measures were announced as part of the 2018 Budget, it remains
unclear how this funding will be allocated across the different types of disability
support services that were funded through the array of Commonwealth programs
transitioning to the NDIS. This issue is not new and has been repeatedly
flagged by the mental health sector, consumers and several parliamentary
committees operating at federal and state levels.
The committee also received evidence that the imminent closure of these
programs and the uncertainty of future funding arrangements and programs are
resulting in an exodus of a highly skilled workforce. This will negatively impact on the quality of supports that people with
psychosocial disability will receive in the near future. Broader disability
workforce issues are further discussed in another section of this chapter.
In light of the evidence received to date, the committee has deep
concerns that many existing clients of Commonwealth programs such as PIR, PHaMs
and Day to Day Living (D2DL) have yet to test their eligibility to the NDIS in
order to qualify for continuity of supports. At the time of the roundtable in
February 2019, these programs were due to close on 30 June 2019. However, on 21
March 2019, the Minister for Families and Social Services, the Hon Paul
Fletcher, announced a commitment to extend funding to providers to support the
transition of people in Commonwealth funded programs to the NDIS for up to 12
months to 30 June 2020. The committee welcomes this announcement, but is of the view that a longer
extension of funding for these programs will be required to ensure that all
people can test their eligibility and have access to continuity of support.
Furthermore, longer-term arrangements for existing program clients not eligible
for the NDIS should be put in place before closure of existing programs.
The committee recommends the Australian Government extend funding for PIR,
PHaMs and D2DL programs until 30 June 2021 and make public by 30 June 2020
how it intends to deliver longer-term arrangements for existing program clients
not eligible for the NDIS.
More broadly, the committee heard evidence that funding outside the NDIS
was insufficient to cover the needs of people with severe and enduring mental
health conditions. The committee had previously recommended a national audit and
mapping of all Australian, state and territory services, programs and
associated funding available for mental health. The committee is of the view
that such audit should be undertaken as soon as possible as it would provide
some clarity around existing and emerging service gaps and inform priorities
for investment. The Australian Government supported this recommendation but did
not indicate a timeline for undertaking such stocktake.
The committee recommends the Council of Australian Government (COAG)
conduct an audit of all Australian, state and territory services, programs and
associated funding available for mental health.
Provision of services under the NDIS Early Childhood Early
Between June and December 2017, the committee undertook an inquiry into
the provision of services under the NDIS ECEI Approach.
At the time of
the inquiry, the key issues identified were:
- access to the Scheme;
- the planning process and adequacy of the plans;
- underfunded plans for children with ASD;
- delays in accessing services; and
- the costs of delivering services for service providers.
On 7 December 2017, the committee released its report and made 20
recommendations aimed at ensuring that children can be appropriately supported
to reach their full potential. A Government Response was provided in May 2018
agreeing with all the recommendations.
On 26 February 2019, the committee held a roundtable with
representatives of the ECEI sector to gauge the effectiveness of the ECEI
pathway in meeting the needs of children and their families and carers.
The committee was particularly interested in hearing any immediate
concerns that need addressing in the short term.
While some roundtable participants acknowledged that improvements have
occurred since the inquiry, including through the development of the ECEI
all roundtable participants reported that there were still a range of issues
that need to be urgently addressed.
Critical issues raised in evidence included delays in provision of
services, significant challenges in addressing the needs of children with Autism
Spectrum Disorder (ASD), and the lack of a clear, national strategy around the
ECEI approach under the NDIS.
During the inquiry, the committee had heard about delays at various
stages of the ECEI journey, especially at plan approval stage.
In recent submissions received by the committee and at the roundtable
held in February 2019, the committee heard that delays are a pressing issue
that need urgent attention. Indeed, delays continue to be observed at all points
of the ECEI journey, resulting in children not accessing early intervention
support services in a timely manner.
Roundtable participants stressed that long delays tend to occur at
planning and plan approval stages. For example, Ms Stephanie Gotlib, Chief Executive Officer of Children and Young
People with Disability Australia stated:
For us, we're still hearing very strongly of really long
delays in planning – from six to 18 months. It's completely unacceptable.
The committee heard cases of children with ASD waiting to get a planning
meeting for up to 18 months after gaining access to the Scheme.
The Australian Autism Alliance also reported that it was common to hear of
families waiting six to twelve months or sometimes longer to access early
According to Ms Fiona Sharkie, Chief Executive Officer of Amaze,
approximately 2000 children in Melbourne's West are waiting for a planning
meeting or waiting for a plan to be approved.
Dr Jennifer Fitzgerald, CEO of Scope Ltd, provided a snapshot of the
situation in Victoria based on her organisation's experience of servicing
around 4000 children across Victoria,:
In January, we had over 550 children who were deemed eligible
who were awaiting planning, and we had 187 children who had transitioned out of
early childhood intervention services who we believed would be eligible who
were awaiting services [...] and at that time had had no services provided.
Ms Trish Hanna, Chair of Early Childhood Intervention Australia also
pointed out that the ECEI pathway is not just about children getting a funded
plan and that it appears that children who should be supported to access
mainstream and community supports are 'getting pushed to the back of the
Impact of delays on children and
Delays are negatively impacting children's future development outcomes
and the effectiveness of early intervention services:
Every day of delay is a lost opportunity for that child's
development and outcomes.
The Australian Autism Alliance also stressed that 'any delay in
accessing services could have a significant detrimental impact on the short and
long-term outcomes of autistic children'.
A roundtable participant pointed out that the impact of these delays on
families and parents' mental health cannot be underestimated:
We're seeing significant level of stress, and everyday I have
a family member come into our site very distressed because they feel they've
let child down, because they haven't been able to access the supports that
they've been told that they need in order for their child to develop and grow.
Ms Helen Johnson, Parent Support Adviser at the Association for Children
with a Disability (ACD) also described how the delays and administrative
hurdles are affecting families:
[...] I have testimonials here from families about the hell
they have gone through: the mental health effects, the stress, the distraughtness
and the financial cost [...].
Causes of delays
Mr John Forster, Chief Executive Officer of Noah's Ark is of the view
that one of the reasons for delays is that ECEI partners may not be funded
adequately to manage the amount of plans they have to process:
I think there's a question about the adequacy of funding to
the ECEI partners to actually manage the task they're doing, because it's
cumulative in the sense that, if you start off with a thousand children the
next year you've got to do a thousand reviews plus the next thousand
Similarly, Scope Ltd contended that the higher than expected numbers of
children being funded under the Scheme has an impact on the capacity of ECEI
partners to meet the demand for all eligible children.
Dr Jennifer Fitzgerald of Scope Ltd, also explained to the committee that
the system is not working well because of its complexity, which contributes to
So it is a complex system in the early childhood intervention
services, because there's an on boarding process, a review process and a new cohort
coming every year. At the moment, the system is kind of stuck and is not
The Australian Autism Alliance is calling for the Australian Government
'to commit to reducing waiting times (from entering the Scheme to finalising a
plan) to six weeks, and for this to be monitored and publicly reported by the
First Voice is of the view the NDIS 'should establish performance
benchmarks of Early Childhood Partners to ensure these families receive their
initial plan within two months of their eligibility being established'.
The Association for Children with a Disability (ACD) also recommended
that there should be a maximum wait time set for each step of the NDIS process.
Furthermore, it recommended the implementation of a clearer triage process to
prioritise urgent cases.
ECIA is of the view that, in line with Recommendation 13 made by the
committee in the Transitional Arrangements for the NDIS report, 'the
NDIA should focus all necessary resources and efforts on reducing waiting times
at all points of the Scheme, specifically for plan approval, activation and
Children with Autism Spectrum
During the inquiry, the committee heard that children with ASD and their
families were facing significant challenges accessing adequate levels of
support under the NDIS.
At the roundtable held in February 2019, Ms Fiona Sharkie, Chief
Executive Officer of Amaze, reported that the situation for children with ASD
has not improved and, that in fact, 'autistic children were going backwards
under the NDIS'.
She provided an update on the status of the committee's recommendations
to address the issues affecting children with ASD at the time of assessment,
planning and approval of funding for supports.
Access to the Scheme
At the time of the inquiry, the committee identified the need for a
fit-for-purpose assessment tool for children with ASD because using the
PEDI-CAT was ill-suited for assessing the functional capacity of children with
The committee recommended the development of a purpose-built assessment
tool with children with ASD in Australia to ensure consistency in access to the
Scheme, and adequacy of supports in plans.
The Australian Government supported this recommendation and advised that
work was underway with the Autism Cooperative Research Centre to develop a
national guideline for consistent diagnosis of ASD.
On 22 February 2019, the NDIA informed the committee that a trial of the
PEDI-CAT ASD was underway to determine if it was reliable for measuring
functional ability in individuals with autism. The NDIA indicated that the
trial was expected to be completed by the end of June 2019.
Ms Fiona Sharkie, Chief Executive Officer of Amaze, acknowledged that
work on the PEDI-CAT ASD was progressing, but that, on the ground, the
situation remained problematic:
Parents are being asked what level of diagnosis the children
have been diagnosed at, which is completely irrelevant to gaining access to the
Scheme, but also completely irrelevant in determining what services that child
will need. They are being precluded from entering the Scheme through being
asked about the level of their diagnosis.
The Australian Autism Alliance is also of the view that 'a robust and
reliable tool to ascertain eligibility for autistic people is urgently needed
and should continue to be pursued'.
At the time of the inquiry, the committee received compelling evidence
in relation to recurring funding shortfalls in plans for children with ASD. The
committee heard that the level of funding granted in many plans did not meet
participants' needs and did not align with recommended evidence-based practice
guidelines. The committee also heard that NDIS funding levels were often lower
than previous national funding models, such as Helping Children With Autism.
The committee recommended the NDIA urgently address issues of scope and
level of funding in plans for children with ASD. The Australian Government noted the recommendation and advised the committee
that the NDIA was working with the Autism Cooperative Research Centre to
develop evidence-based guidance for ensuring appropriate, individualised
Ms Fiona Sharkie of Amaze explained to the committee that, in addition
to unacceptable delays to accessing support services, children were not getting
The committee also made a recommendation about the scope of
adequate supports against the evidence of 20 hours.[...] looking at the data
published by the NDIS that the zero to six year old children are receiving an
average of around $15,000, that would not indicate that the evidence of 20
hours is really being provided for.
Other submitters reported that a lack of knowledge and expertise among
planners, including ECEI partner staff, is continuing to affect the quality of
children's plans. For example, the Australian Autism Alliance stated:
A lack of autism understanding among NDIA staff, LACs and
ECEI staff has negatively impacted on the rights of autistic people to
participate and have their support needs understood and met during the planning
process (including planning meetings) to ensure they receive an appropriate and
ECEI approach under the NDIS
Roundtable participants expressed concerns regarding the ECEI approach
under the NDIS, citing issues around a move away from best practice models
because of inadequate pricing, a lack of clear NDIS guidelines on practice
models, and an overall lack of strategy around the delivery of Early Childhood
Intervention (ECI) services under the NDIS.
Shift in practices due to
According to experts, best practice for ECEI services is to deliver them
in natural settings. However, due to the current NDIS pricing structure,
service providers have to shift from delivering services in natural settings to
Dr Jennifer Fitzgerald, CEO of Scope, explained that the delivery of
services in natural settings is unviable for service providers under current
NDIS pricing, and concluded:
That concerns me, given there are two systematic reviews that
clearly evidence that it is best to deliver those services in a child's natural
Ms Trish Hanna, Chair of Early Childhood Intervention Australia (ECIA)
also pointed out that current NDIS pricing is impeding the ability of service providers
to adhere to best practice models. She recommended a pricing adjustment for
travel, as well as allocation of funding in children's plans that allows support
in the places where families are comfortable.
Ms Sharon Fragomeni, Customer and Service Delivery Manager at Scope,
also stressed that inadequate pricing for travel continues to be a significant
issue in rural areas, making it difficult to support families within their
Need for a national strategy
Mr John Forster, CEO of Noah's Ark Inc., is of the view that service
providers and ECEI partners have had 'a very mixed and confused approach' to
the provision of Early Childhood Intervention (ECI) services because of a lack
of strategy or guidelines for the delivery of ECI under the NDIS. He concluded
that, despite being a challenging task, the NDIA must develop a national
approach to the delivery of ECI services:
It's a major challenge for the NDIA to develop a national conversation
where there wasn't one before, but I think that's essential. If we're going to
make it work for families then we've really got to go back and get those
fundamentals in place
Ms Trish Hanna, Chair of ECIA, called for the development of an Early Childhood
Intervention blueprint that 'is aligned and can work with the NDIS so that
there is a strategy beyond just transition phase, but into the future, of what
ECI can achieve for families and young children in Australia'.
Her colleague, Ms Yvonne Keane, explained that such national blueprint
is urgently required because of the massive disruption that had occurred in the
service delivery model of early intervention services with the transition to
Historically, as we know, early intervention was delivered by
state or territory governments through previous funded systems, and, as the
NDIS is implemented, we're seeing state and territory governments exiting the
market and leaving the NDIS implementation with significant issues that need to
be addressed. So we think it's critical that government invests in the first of
its kind national early childhood intervention blueprint [...] so we can ensure
that every child has every possibility to enter early childhood intervention as
quickly as possible and make those incredible and significant gains.
She also noted that developing such a blueprint was particularly
important to ensure the NDIS delivers on its promise of being an insurance
The committee is gravely concerned by the recent reports of long delays
in accessing early intervention support services under the ECEI pathway. Whilst
delay was raised as an issue during the initial inquiry into the provision of
ECEI services under the NDIS, it appears that the situation may have worsened
with the ramp up to full Scheme. The committee was alarmed to hear that some
families are waiting for well over a year to access services, at a time when
every day of delay can have a negative impact on their child's future
The committee understands that the delays mostly occur after access to
the NDIS has been granted, suggesting that the problems are occurring at plan
development and plan approval stages. Submitters described the ECEI pathway as
complex and not working effectively. Outsourcing all aspects of the ECEI
pathway to ECEI partners may have potentially added a level of complexity to
the system. The causes for these delays need to be further examined to be fully
understood. However, based on the information received by the committee, it
appears that the volume of work of the ECEI partners may be greater than
originally anticipated, resulting in ECEI partners being unable to manage the
growing amount of plans they have to develop or review with participants. As the
value of ECEI partners' grants is based on phasing numbers set out in bilateral
agreements and estimates of participant volumes, the NDIA should closely
monitor actual participant volumes and ensure ECEI partners' funding can be
adjusted if necessary. The NDIA must urgently address these delays and commit
the necessary resources to ensure children and their families can access the
supports they need in a timely manner.
The committee recommends the NDIA immediately commit the necessary
resources to address the delays experienced by families to access services
under the ECEI pathway.
Importantly, there is a need for a clear, transparent and accountable
process, which sets a maximum wait time at each step of the ECEI journey.
Families must be able to rely on a system that ensures eligible children can
have an approved plan within a reasonable timeframe. ECEI partners should have,
as part of their KPIs, a maximum time to complete each step of the process to
get a plan approved under the ECEI pathway. The committee is aware that since
the establishment of the hearing service stream, most children with hearing
impairment have obtained an approved plan within a few weeks. Based on this
information and other evidence, the committee considers that all eligible
children should have an approved plan within three months of families
contacting their local ECEI partner.
The committee recommends the NDIA introduce Key Performance Indicators
for its ECEI partners that stipulate a maximum time to complete each step of
the access, planning and plan approval processes to ensure all eligible
children have an approved plan ready for implementation within three months of
being in contact with an ECEI partner.
The committee recommends the NDIA report on how long it takes for
eligible children to get a plan under the ECEI pathway as part of its Quarterly
ECEI approach under the NDIS
The committee has heard on many occasions that best practice is to
deliver Early Childhood Intervention (ECI) services in natural settings.
However, it appears that, under the current NDIS pricing structure, it has
become unviable for service providers to do so. As a result, the committee
heard that many service providers have changed their service delivery model to
centre-based delivery. The committee is of the view that early childhood
service delivery models under the NDIS should not be determined on the basis of
cost drivers but on maximising outcomes for children so they can reach their
full potential. The NDIA must ensure the NDIS pricing structure for the
delivery of ECI services is not precluding the delivery of services in natural
settings when this approach is considered the best option for a child.
The committee recommends that an evaluation of the pricing of Early
Childhood Intervention services is undertaken as part of the next annual NDIS
Importantly, the evidence received by the committee also suggests that
there is no nationally consistent approach to the delivery of ECEI services
under the NDIS. The committee agrees with submitters that a national Early
Childhood Intervention plan should be developed to ensure the provision of ECEI
services under the NDIS can achieve the best possible outcomes for children and
their families. This plan should be in place by the end of transition to full
The committee recommends the NDIA develop, in collaboration with the
Early Childhood Intervention sector, an Early Childhood Intervention strategy
that sets a national and consistent approach to the delivery of Early Childhood
Intervention services under the NDIS.
Transitional arrangements for the NDIS
Between June 2017 and February 2018, the committee undertook an inquiry
into transitional arrangements for the NDIS.
At the time of the inquiry, the key issues were:
- interface between the NDIS and mainstream services, especially in
the areas of health, aged care, education, transport, crisis accommodation and
- delays in accessing the Scheme, plan approvals, plan activations
and access to services;
- ILC funding levels, and its funding approach potentially leading
to service gaps;
- no clarity on how the NDIA intends to intervene in areas of thin
- no Provider of Last Resort arrangements;
- service gaps in advocacy, assertive outreach and support
- a lack of culturally appropriate services for people from CALD
backgrounds and for Aboriginal and Torres Strait Islander communities to engage
with the NDIS.
On 15 February 2018, the committee tabled its report and made 26
recommendations aimed at ensuring that improved and appropriate arrangements can
be put in place to provide necessary and reasonable supports for all NDIS
participants. A government response was provided in June 2018, indicating
support or support in-principle for each of the 26 recommendations.
On 26 February 2019, the committee held a roundtable with peak body
organisations representing service providers and people with disabilities,
families and carers to gauge progress since the release of the report.
Roundtable participants focused on highlighting the critical issues that
are impeding the access and delivery of services to NDIS participants. In
particular, they discussed the lack of progress to address key issues that had
been identified at the time of the inquiry, including:
- the interface between the NDIS and mainstream services;
- the persisting or worsening of areas of thin markets; and
- the absence of clear Provider of Last Resort arrangements.
Interface between the NDIS and
At the time of the inquiry, the committee found that the Principles
to determine the responsibilities of the NDIS and other service systems agreed
by COAG were subject to interpretation and lacked clarity. Additionally, the
transition of Commonwealth, state and territory programs to the NDIS was
contributing to emerging service gaps and the lack of delineation of funding
responsibility between the NDIS and state and territory services.
This has resulted in boundary issues and funding disputes, which impact
on access to services for NDIS participants and people with a disability not eligible
for the NDIS, especially in the areas of health, education, transport and
Progress to date
In its 30 April 2018 communique, the Disability Reform Council (DRC)
advised that 'the NDIA and jurisdictions have established working groups for
the priority interface areas of health, mental health, justice and child
In its 10 December 2018 communique, the DRC stated:
Since the Council met in April 2018, work has progressed to
improve the experience and interactions of NDIS participants with mainstream
service systems of health, mental health, child protection, personal car in
schools and specialist school support.[...] The Council noted that states and
territories, the Commonwealth and the NDIA are undertaking further work to
clarify roles and responsibilities for the NDIS and health systems where health
and disability supports are required concurrently.
At its December 2018 meeting, the DRC also agreed that as an interim
solution, states and territories will continue to deliver services for
specialist school transport and Personal Care in School (PCIS) until 31
December 2023, while development work is undertaken.
In relation to the interface with the health system, on 9 January 2019,
the Minister for Social Services announced interim arrangements for dysphagia
and mainstream health supports until a final decision on roles and
responsibilities of the NDIA and health systems is made by the Australian
Governments in early 2019.
According to the NDIS website, planners and Partners will escalate
urgent issues raised by participants, carers or providers relating to accessing
immediate and vital supports. In response, the NDIA and state and territory
governments will work together to resolve any issues on a case-by-case basis.
However, during the roundtable, participants continued to express grave
concerns around the lack of progress on clarifying the delineation between the
NDIS and mainstream services, pointing that it leads to funding disputes
resulting in some people with disabilities not being able to get out of
hospitals or jails.
Mr Patrick McGee, National Manager, Policy Advocacy Research at the
Australian Federation of Disability Organisations (AFDO) bluntly described the
We've got hospitals fighting with the NDIS, we've got justice
systems fighting with the NDIS and no one's talking to each other about how to
best resolve those issues.
The Victorian Healthcare Association also pointed out that the lack of
clarity and effective interface between the NDIS and health systems have
'created artificial barriers between health and disability needs, which
actively work against the provision of integrated and holistic care'.
At the roundtable, Mr Tom Symondson, Chief Executive Officer of the Victorian
Healthcare Association furthered explained how this has led to a fragmented
approach to care, which is detrimental to the health and wellbeing outcomes of
people who need health and disability supports.
The issue of thin markets has been raised in most inquiries undertaken
by the committee. The committee found that whilst the lack of services and
providers operating in rural and remote areas is not new or unique to the NDIS,
the transition to a market based system has brought new challenges for delivering
services in areas of thin markets. Fee for service pricing is creating complex
challenges in thin markets for providers to achieve sustainability and
viability. As a result, the committee heard that on many occasions service
providers were considering or had already opted out of delivering services
under the NDIS.
Importantly, this has devastating consequences for NDIS participants
who have plans but have no services and nowhere to spend their NDIS funding.
In its report, the committee had recommended the NDIA develop and
publically release a strategy to address thin markets. The Australian Government supported this recommendation and advised the
committee that the NDIA's market stewardship approach was characterised by
monitoring and assessing markets and taking actions where necessary to improve
the functioning of the markets.
On 26 November 2018, the Assistant Minister for Social Services
announced the release of a new NDIS Market Enablement Framework. The new
framework provides guidance on how the NDIA will monitor the market and
determine what, if any, strategies should be adopted to encourage market growth
The NDIA advised the committee it 'is undertaking a range of work
through the Market Enablement Framework to support growth of an innovative
disability services market as the Scheme rolls out'. The NDIA also indicated
that 'a project is being finalised to pilot interventions for ineffective and
under-developed markets, including thin markets and regional and remote
NDIA lack of progress to address
Mr Tom Symondson, CEO of the Victorian Healthcare Association pointed
out at the roundtable that the issues on how to intervene in areas of thin
markets and Provider of Last Resort situations had been the subject of
discussions with the NDIA for a very long time but is yet to be progressed:
We were talking about this five years ago, and it feels like
we haven't really moved very far since then, which is pretty tragic, in my
Mr David Moody, Acting Chief Executive Officer of National Disability
Services, reported that not much has progressed to develop a strategy to
address thin markets, let alone implement it, at both the Disability Reform
Council and the NDIA level, concluding that 'I don't think anyone could
seriously point to any objective examples of where intervention has been
undertaken to address the problems'.
Ms Kirsten Deane, Executive Director of the National Disability and
Carer Alliance, reported that families and people with disabilities expressed
frustration that the NDIA appeared to be working in isolation and not building
on existing service delivery models to address the issue of market failure in
The issue of service delivery in remote communities is not a
new one for government. But they felt like the NDIA was coming along and
looking for solutions when in actual fact joined-up government might be one of
the solutions. If health services are already finding a way to service remote
communities, why isn't the NDIA working with them to have a more joined-up
approach to that?
Mr Llewellyn Reynders, Policy Manager at the Victorian Council of Social
Services (VCOSS), is of the view that this lack of progress is directly related
to the NDIA's reluctance to consider any service delivery model that is not
based on an individualised fee-for-service funding model:
We find that, every time we start having a conversation or
produce evidence or research that starts steering the conversation to an
alternate commissioning model, suddenly that work seems to disappear. [...] we
have a very difficult time convincing the NDIA to even consider in any detail
models that use other forms of commissioning.
Roundtable participants reminded the committee that inadequate pricing
of supports is contributing to shortages and lack of choices of services.
For example, according to Ms Philippa Angley, Head of Policy at National
Disability Services, the pricing of allied health assistance under the NDIS
remains a 'fundamental issue' resulting in the inability to attract allied
health assistance workers to fill positions.
Mrs Andrea Douglas from Occupational Therapy Australia, also noted that
the markets may become even thinner if no action is taken to address pricing
issues related to travel delivering services:
There are providers that are travelling vastly more
extensively than what they're being paid for. [...] So travel is creating big
In its submission, Vision Australia explained that service providers
often travel long distances to deliver services in rural and remote areas and
bear the costs of doing so.
Mr Tom Symondson, CEO of the Victorian Healthcare Association, also
pointed out that travel costs in rural and remote areas were not covered under
the current pricing. He reminded the committee that his organisation has
repeatedly called for the NDIA to develop and implement 'a thin market strategy
that actually recognises the costs of doing business in a rural or remote
Roundtable participants stressed to the committee that the lack of
available trained workforce to work in disability support services was
contributing to the worsening of areas of thin markets.
Maintaining Critical Supports
(Provider of Last Resort)
At the time of the inquiry, the Provider of Last Resort arrangements remained
unclear and incomplete, which prompted the committee to recommend the NDIA
publically release its Provider of Last Resort policy as a matter of urgency.
The Australian Government supported the recommendations and informed the
committee that the NDIA was working on the 'Maintaining Critical Supports'
project and would publish the agreed outcomes following the Disability Reform
Council in the first half of 2018.
At the time of writing, the Maintaining Critical Supports project is
still in development. The NDIA advised the committee that it is working closely
with state and territory governments on a new approach to Maintaining Critical
Supports that is participant-centric. The NDIA is also working on a number of
initiatives to ensure participants can access the following supports:
- After-hours crisis support arrangements – the NDIA has been
piloting after-hours crisis response arrangements in three states to determine
the best way to meet the needs of participants. Providers have been sourced to
provide varying levels of support, depending on the level of escalation
- Critical Service Issues Response – the NDIA has worked with each
State and Territory Government to establish clear mechanisms for escalation and
resolution of individual and thematic issues that affect participants.
Roundtable participants reiterated the need to have clear Provider of
Last Resort arrangements in place as the absence of such arrangements are
putting people at risk of not accessing any supports, resulting in admission to
hospital, aged care facilities or jail.
Similarly, Victoria Legal Aid contended that the absence of a PLR
framework contributed to its 'clients falling through gaps, including
offending, imprisonment, inability to be discharged from secure mental health
facilities and child removal'.
Lack of progress
Mr Tom Symondson, CEO of the Victorian Healthcare Association, reminded
the committee that providers were told 'as early as 2016 that each jurisdiction
was having a separate bilateral conversation with the federal government and
the NDIA around a provider of last resort approach'.
However, no tangible progress has been made on a process to ensure
provision of services in both crisis situations and where there is simply no
market. In fact, Mr Symondson is of the view that the provider of last resort
conversation is still 'very immature' and that, to date, no one has taken
ownership of the problem.
Drawing on his experience in Victoria, he stated that, at present, the
system relies on state government services to step in, which is not sustainable:
Certainly in Victoria, its feels very much like there's an
assumption that the public providers will fill that gap. Ideologically, they
will do that. They will not turn people away. But it's not what the design
intention was. It's certainly not in line with the principles of the NDIS, and
eventually the state government will probably say 'we're not funding this
anymore' and it will be providers in our membership that end up being the bad
guys saying 'we don't have enough money to provide that for you, and we know
nobody else who will'.
At the roundtable on mental health services, Mr Glen Tobias, Acting Chief
Executive Officer of Neami National told the committee that 'the provider of
last resort is actually the emergency department'.
As previously discussed in the Transitional arrangements for the NDIS and the Market readiness for provision of services under the NDIS reports,
there are grave concerns that existing state and territory government processes
for emergencies will cease despite the absence of new formal arrangements under
For example, at present, in Victoria, the Department of Health and Human
Services has an intensive support unit, which deals with extreme and urgent
cases. As described by Mr David Moody, Acting CEO of National Disability
Services, this unit has enabled a number of crises to be averted. However, this
service is due to close at the end of June 2019.
Mr Patrick McGee, from the Australian Federation of Disability
Organisations, warned the committee that without a service that can respond to
emergency situations and linking people to providers and services, there will
be disastrous consequences for people with very complex needs:
They'll all go to jail, they'll go to hospital, they'll stay
in their homes, they'll be cared by their elderly parents, they'll commit
crimes, they'll get into trouble, they'll get given the wrong medication – all
those things are going to happen.
Similarly, Prader-Willi Syndrome Australia is of the view that, without
appropriate arrangements in place in case of crisis, people with Prader-Willi
Syndrome who have very complex needs and challenging behaviours 'may be forced
into homelessness, dangerous accommodation or being held unnecessarily in a
prison or mental health facility'.
According to Ms Kirsten Deane from National Disability and Carer
Alliance the NDIA has still not the systems in place to deal with urgent
[...] the NDIA has not developed triage systems to prioritise
people who need more urgent assistance.
Ms Philippa Angley, from National Disability Services, also expressed
doubts that the current NDIS system would be able to respond to emergency
situations in the same way as state services used to, because of its funding
structure, and concluded:
There is a need to create a response for emergencies where
the negotiation happens afterwards.
Mr David Moody, of National Disability Services, acknowledged the
current pilot of the Complex Needs pathway in Victoria but clarified to the
committee that 'it does not make provision for a provider of last resort'.
Interface with mainstream services
The committee acknowledges that the issue of the interface between the
NDIS and mainstream services is complex. The committee is aware that working
groups reporting to the DRC have been established to work on clearly defining
the roles and responsibilities of the NDIA and mainstream services. However,
the committee noted that this work is progressing very slowly. At the same
time, there is growing evidence that NDIS participants are being denied
services and care because of funding disputes between the NDIA and other
government services. In extreme cases, this is resulting in people being unable
to leave hospitals for months. This situation is untenable and requires
immediate action, regardless of the state of progress of discussions with state
and territory governments and ad-hoc arrangements to delineate the roles and
responsibilities of the NDIA and mainstream services. There should be an
immediate introduction of a formal mechanism to ensure that a person-first
approach is taken in the delivery of services in the event of funding disputes.
Such a mechanism would see the party of first contact providing the services
without delay or disruption. The party of first contact would then refer the
matter to a jurisdictional dispute mechanism, where costs incurred by the party
of first contact can be, if deemed appropriate, be reimbursed through budget
transfers, or direct invoicing.
The committee recommends the Council of Australian Governments (COAG)
Disability Reform Council agree to put in place a formal mechanism that ensures
a person-first principle is applied in the delivery of services in the event of
funding disputes between the NDIA and mainstream services.
The issue of thin markets is not new and has been discussed at length in
previous committee reports. The committee is frustrated by the NDIA's ongoing reluctance to consider
alternatives to a fee-for-service model to address thin markets. As previously
identified by the committee, other service delivery models that could be
considered include the introduction of direct commissioning, block funding,
seed funding or developing a multipurpose service model similar to the one used
in the aged care sector.
The committee is of the view that the NDIA must work with government and
non-government service providers operating in rural and remote areas to trial
alternative service delivery models.
The committee recommends NDIA start trialling alternatives to a fee-for-service
delivery model to address thin markets in rural and remote areas by the end of
Provider of Last Resort
As discussed in previous reports by this committee, the NDIA is
responsible for the Provider of Last Resort (PLR) arrangements but is yet to
publicly release its policy and operational plan on the matter. On several
occasions, the committee has recommended the NDIA accelerate its work to
progress future PLR arrangements and publicly release its PLR policy as a
matter of urgency.
The committee agrees with the Victorian Healthcare Association that
within the PLR conversation there were two issues conflated: one around putting
a provider in place when there is an absence of services because of market
failure and the other around how to respond to crisis and emergency situations. As the market steward, the NDIA has responsibility to develop a funding model
for continued provision of disability services in areas of thin markets,
including in rural and remote areas.
The committee recommends the NDIA make public how it will ensure
provision of services in case of market failure in rural and remote areas.
The committee has repeatedly expressed its deep concerns about the lack
of progress in relation to Provider of Last Resort arrangements in the event of
a crisis, especially when it involves crisis accommodation. The committee
understands that the Maintaining Critical Supports project will define policies
and processes for such situations. The Maintaining Critical Supports policy
must commit to provide services according to participant needs, including for
crisis and respite accommodation.
The committee understands the NDIA is piloting after-hours crisis
response arrangements but lacks information to comment on the effectiveness of
the approach. Importantly, it is a pilot, not a systemic response. The
committee is of the view that the NDIA should establish within the Complex
Needs pathway a unit in each jurisdiction, which would be responsible for
coordinating crisis service provision, including crisis and respite
accommodation. In situations involving boundary issues with mainstream
services, the person-first principle outlined in Recommendation 5 of this
report should apply.
The committee recommends the NDIA establish within the Complex Needs
pathway a unit in each jurisdiction responsible for coordinating and ensuring crisis
Provision of hearing services under the NDIS
Between November 2016 and June 2018, the committee commenced an inquiry
into the provision of hearing services under the NDIS.
At the time of
the inquiry, the key issues identified were:
- a lack of guided pathways for children;
- considerable delays in accessing services;
- shortfalls in funding; and
- the lack of a child-first approach.
The committee made six recommendations in its interim report tabled
September 2017, which were all supported, or partially supported, by the
Government. In its final report tabled June 2018, the committee made three
recommendations, which were all partially supported by the Government.
The ECEI roundtable held on 26 February 2019 provided an opportunity to
gauge progress since the release of the final report.
Referral pathway for children
The committee expressed, in both its interim and final reports, its
concern that the transition to the NDIS has disrupted a world class system that
had worked very well. Guided pathways were previously available, but have been
lost with the move to the NDIS. This has resulted in considerable delays in the
start of funded therapies, which are critical, though early interventions, to
ensuring that children can be taught to communicate as well as any other child
and become active participants in the social and economic life of their
In September 2017, the committee sought to address these issues by
recommending that Australian Hearing be formally appointed as the independent
referral pathway for access to early intervention services under the NDIS.
For a long time, the NDIA was reluctant to carve a preferred pathway for
families of deaf and hard of hearing children. It took the NDIA until August
2018 to finally establish a hearing service stream for newly diagnosed
This pathway is for children aged nought to six years who have just been
diagnosed with a hearing loss. The new pathway involves Australian Hearing initiating
access to the NDIS for eligible applicants. This ensures that NDIS funding is
received faster, and access to early intervention supports can occur quickly.
Australian Hearing also links the family to an Early Childhood Partner, to
support implementation of the plan.
According to the hearing services sector, this new, rapid, referral
pathway for children is generally working well, and resulting in a first plan
for the child within the next three weeks or up to six weeks.
At the February 2019 roundtable, Dr Jim Hungerford, Chief Executive
Officer of The Shepherd Centre described the establishment of the new rapid
referral pathway as a 'mammoth improvement', and pointed out that it has
significantly reduced delays.
However, First Voice pointed out that this new system only applies to
children aged nought to six years who attend Australian Hearing for the first
time. As a result, according to First Voice, a significant proportion of
children who have already been engaged with Australian Hearing prior the
implementation of this new system still do not have a plan despite eligibility
to the Scheme. Furthermore, this process does not apply to children aged seven
As the a result, First Voice recommended that the NDIA commission
Australian Hearing to check, and if required, initiate the NDIS process for
Uncertain future of Australian Hearing
On 21 June 2018, the Minister for Social Services announced that
Australian Hearing's in-kind support would be extended until 30 June 2020.
The referral pathway relies on Australian Hearing being the sole
provider of paediatric audiology services. Currently, this exclusive role is
only secured until 30 June 2020.
As described by First Voice, the future of Australian Hearing beyond
this time remains uncertain and, if the role of Australian Hearing changes,
this new pathway will cease to function.
At the roundtable, Dr Jim Hungerford stressed the importance of urgently
clarifying and securing the future of Australian Hearing:
We really implore the government [...] to resolve the situation
for Australian Hearing, otherwise all of the advances could be destroyed.
Funding in plans
During the inquiry, the committee received compelling evidence from
specialist service providers about shortfalls in funding between the costs of
providing early intervention hearing services and the funding provided in
First Voice reported significant improvements with the NDIA interim
approach of two standard tiers to determine funding for children's first plans.
This interim approach is now being replaced by a four-tier system, which is
much more closely aligned to the service costs incurred by children that
require, low, medium, high or intense support.
The new four-tier system for initial plans is expected to be implemented
from 1 March 2019.
However, First Voice is concerned that the audiological diagnosis is the
only factor considered for determining the appropriate funding for the initial
plan. For example, it does not take into account other factors, such as
diagnosed communication delay or a complex family context needing additional
support to implement the therapies.
A reliance on audiological diagnosis alone can result in some cases in
underfunding of plans:
An example of this is a particular case of a child aged 4
years 8 months who was granted a funding package through the rapid referral
pathway. The child has moderate sensorineural hearing loss but this was only
diagnosed at 3 ½ years of age which resulted in a severe language delay. The
initial $16,000 package is not sufficient for the intense specialised
intervention for hearing required in preparation for commencing school in 2020.
The committee acknowledges the significant work the NDIA has recently
undertaken to develop referral and funding approaches that will appropriately
support children with hearing loss, their families and carers.
The establishment of the referral pathway through Australian Hearing for
newly diagnosed children aged nought to six years is encouraging. However, the
committee noted the concerns expressed by the sector around the limited remit
of this referral pathway. The committee is of the view that Australian Hearing
should be able to refer, at any time, a child to the NDIS, as it is best placed
to provide expert advice on the needs of children who have hearing loss.
The committee recommends the NDIA ensure that the hearing referral
pathway delivered by Australian Hearing is available to all children.
The committee is concerned that this referral pathway has an uncertain
future and is, in essence, an interim measure. Indeed, the in-kind arrangements
with Australian Hearing are only secured until 30 June 2020.
The committee recommends Australian Hearing be formally appointed as the
independent referral pathway for access to early intervention services under
the NDIS on an ongoing basis, and funded appropriately for this role.
Funding in plans
The committee is satisfied with the scaled funding model being
introduced by the NDIA to fund hearing services supports. The committee notes
the concerns expressed by the sector around the underfunding of plans for
children with additional disabilities or more complex needs. The committee is of
the view that it is the responsibility of the Early Childhood Partner to ensure
that additional funding is factored in plans for other appropriate support
needs that may be required for a child.
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