Chapter 2

Communication and business transactions

2.1        The chapter examines two key functions of NDIS ICT systems essential to the efficient implementation of the Scheme:

How the Agency communicates

2.2        Since its establishment in September 2016, the committee has consistently received evidence of the NDIA failure to communicate clearly, effectively and in a timely manner with participants and service providers.[1]

2.3        During this inquiry, participants, their families and carers as well as service providers have also expressed concerns about the difficulty of contacting the NDIA when they require assistance.[2]

2.4        Submitters identified the communication tools used by the NDIA as a key barrier to transparent, timely, accurate and appropriate communication between the NDIA and its stakeholders.[3]

2.5        Importantly, inquiry participants raised issues about the lack of clarity, consistency and accuracy of information provided by the NDIA.[4]

Website

2.6        The NDIA principally uses its website to provide information and updates about Scheme operations and policies to prospective and existing participants and service providers. Brochures, information sheets, guides, and forms can be downloaded from the website.

2.7        Inquiry participants described the website as difficult to navigate, not easily searchable, confusing and lacking easily understandable information.[5]

2.8        For example, a respondent to the Carers NSW 2018 Carer Survey said that 'the website is impossible to navigate: you go round in circles and still can't get answers'.[6]

2.9        Similarly, The Benevolent Society explained that 'while some information is available through the NDIS website, it is difficult to navigate the large amount of content on the website to find relevant and up-to-date information'.[7]

2.10      Children and Young People with Disability Australia (CYDA) also expressed concerns about the use of 'complex formats and bureaucratic and arcane language' throughout the website and downloadable materials.[8]

2.11      Issues raised about the website appear to go well beyond design, navigation and configuration. Accessibility and the quality of website content were also identified as key issues needing urgent attention.[9]

NDIS Contact Centre

2.12      To contact the NDIS, people can call a toll free number or email enquiries, which are directed to the NDIS Contact Centre (NCC):

The NDIS Contact Centre (NCC) is responsible for taking phone and email enquiries from all those wishing to make initial contact with the NDIS, as well as participants, providers and anyone who requires information about the Scheme.[10]

2.13      On 20 April 2018, the NDIA announced the engagement of Serco Citizen Services Pty Ltd (Serco) as its NCC service delivery partner in a two year contract.[11]

Phone enquiries

2.14      From 1 July to end of September 2018, the NCC answered over 240 000 calls with 84 percent of those calls answered within one minute. According to the NDIA, NCC Customer Services Officers achieved a 97 percent quality rating.[12]

2.15      Develop Therapy Services acknowledged that the wait time to get a call answered has significantly reduced since the appointment of Serco. However, it pointed out that staff employed in the call centres are not always able to answer specific enquiries as they lack knowledge and experience. This often leads to a time consuming and convoluted process to get an answer:

They (call centre staff) then send an email to someone more knowledgeable [...]. The name of this 'someone' is not given, nor their personal email. This causes waiting times for all issues [...]. There is no way of directly following this up, instead the process begins again with the call centre when responses have not been received.[13]

2.16      The lack of knowledge and experience of NCC staff was raised by other submitters.[14] For example, a service provider trying to resolve a payment issue on the portal stated:

It took two phone calls to the NDIS phone line to ascertain his father needed to ring NDIS and give me permission to see his plan on the portal – I already had a copy of it in hand. Then, that didn't appear to make any difference [...] Two more phone calls and no help from inexperienced phone help staff and two emails to some mythical NDIS support service has not yielded any assistance so far.[15]

2.17      As described by submitters, the inability to follow-up and continue progressing the initial query with an assigned person or an assigned case number creates additional delays and frustration.[16]

Email communication

2.18      According to a submitter, email communication appears to be the NDIA's preferred method of communication.[17]

2.19      The NDIA has a system of using generic email addresses for external and internal communications. Issues experienced by service providers and participants include:

2.20      Overall, submitters reported that the generic email address and toll free number are an ineffective means of contacting the NDIA for assistance and more broadly interacting with the Agency.[19]

Access to ICT support

2.21      Participants and service providers contact NCC to access ICT support when they have issues with the portal. Inquiry participants expressed concerns about their inability to contact ICT staff directly.[20]

2.22      According to the Dietitians Association of Australia (DAA), the difficulties with processes within the NDIS ICT infrastructure and the extended delays in reaching support staff to resolve ICT issues are key contributing factors to interruptions in the provision of care to participants, delays in financial payments to providers and underutilisation of participant plan funds.[21]

2.23      Speech Pathology Australia raised similar views, stressing the issues of delayed or non-payment of invoices for its members due to their inability to contact ICT staff.[22]

2.24      DAA recommended the implementation of a direct ICT contact number where suitably trained staff can be accessed.[23]

2.25      Additionally, submitters recommended the NDIA consider introducing an online live-chat function on the website and portals as it would likely reduce the frequency of calls and improve interactive problem solving.[24]

2.26      Illawarra Disability Alliance suggested the NDIA implement a ticket-based helpdesk system to manage technical enquiries so providers can easily track and monitor the resolution of technical issues.[25]

2.27      The NDIA informed the committee that technical support for NDIA ICT services is provided by the Department of Human Services (DHS) and can be accessed through the DHS ICT support portal – My support. In addition, the NDIA has an escalation email address to support NDIA users.[26]

Accessibility

2.28      Submitters expressed concerns about the accessibility of some of the NDIS ICT platforms and information.[27]

2.29      For example, Speech Pathology Australia reported that the participant portal does not have options to make it more accessible and functional for participants. For example, it lacks basic accessibility options such as alternative font sizes, and information in other languages, or Easy English.[28]

2.30      Children and Young People with Disability Australia (CYDA) noted that Easy English versions of key documents are either not available or hard to locate on the website. For example, CYDA reported that it could not locate an Easy English version of the MyPlace Participant Portal: Step by Step Guide 2018.[29]

Appropriateness of communication tools

2.31      The Centre for Digital Business argued that communication tools used by the NDIA are simply not fit-for-purpose for many participants:

The NDIA sends letter to people who physically can't open them, and to people with a cognitive disability who cannot understand the bureaucratic language. Letters, forms, brochures point to the website which is not searchable; to the portal which does not meet the communication and accessibility needs of a great many people; and a call centre which cannot meet the needs of people who are non-verbal or have cognitive impairment.[30]

2.32      A submitter reported that having to communicate by phone to set up access to the participant portal is not an appropriate communication tool for some participants:

Needing to do this by phone presented a significant challenge and hindered their independence because, due to their disability, they have difficulties talking on the phone.[31]

2.33      A submitter who helps a family member who is an NDIS participant pointed out that NDIS ICT 'appears to be designed and built on a social security architecture model rather than a consumer directed care model'.[32]

Co-design

2.34      The Centre for Digital Business is of the view that a different approach to providing information is required to meet the demand of NDIS participants.[33] It ┬ástressed the importance of engaging in a co-design:

With approximately 60 percent of the NDIS participants having some form of intellectual disability or autism, the objective of choice and control compelled a different approach and one that by necessity had to be grounded in co-design.[34]

2.35      Similarly, the Public Service Research Group UNSW Canberra is of the view that participants and their support networks should be involved in designing their digital interface with the NDIS, drawing on evidence based co-design principles.[35]

2.36      The Centre for Digital Business recommended that an expert co-design capability should be established in the NDIA.[36]

2.37      Cara, a service provider, also supported a co-design approach for improved ICT systems that might allow greater participant choice and control.[37]

Nadia

2.38      Based on evidence suggesting a new approach is needed to provide information and assist people to navigate the NDIS, the NDIA started to develop the 'Nadia project', an avatar with human expression that listens to questions and responds with information about the NDIS.[38]

2.39      The Centre for Digital Business explained how Nadia was developed:

The development of Nadia involved a very deep co-design and co-creation effort based in market and community research; academic research, support and engagement with networks of people with intellectual disability; the development of the operating model within the Agency; and the research and development activities of strategic partners.[39]

2.40      The Centre for Digital Business stated that a co-designed, working and tested Nadia conversational cognitive system was delivered by the NDIA in December 2016. In February 2017, the NDIA announced the introduction of Nadia.[40]

2.41      However, Nadia has not yet been released.

2.42      In an answer to a question on notice, the NDIA informed the committee that Nadia has been temporarily postponed for two reasons:

Firstly, to allow the completion of the Pathways strategic program which will redefine key processes of the NDIS. Once these have been defined, Nadia can be updated with relevant processes. Secondly, the technology underpinning speech recognition is still maturing.[...] The release of Nadia is predicated by the maturity of the technology, progress on this is reviewed regularly.[41]

2.43      The Centre for Digital Business contended that Nadia was technologically ready and that other factors are responsible for the postponement of its release.[42]

Quality of information

2.44      Submitters reported that across all platforms the quality of information provided by the NDIA is generally poor, inconsistent and confusing.[43]

2.45      For example, a submitter contended that 'the billing and pricing information provided on the website is vague, ambiguous and open to interpretation' and concluded:

This leaves room for many problems and misconceptions due to a lack of clarity, consistency and transparency around Agency decision-making.[44]

2.46      This raises questions around the lack of clear policies and funding guidelines on some types of supports. For example, Greenacres, a provider of School Leaver Employment Supports (SLES) sought clarification via an email enquiry of weekly claimable rates for SLES support and received a suboptimal response ending with an acknowledgement that further information about funding levels for these supports 'will be published shortly'.[45]

2.47      Similarly, an NDIS participant explained that she finds it hard to exercise choice and control as she has received no clear information about the supports she could claim under her plan despite asking her planner, NDIS LAC, and searching the website and NDIA documents. She concluded:

I understand we are all new to this – the government, the providers and the 'clients'. But at the very least, by now the NDIS could provide information to us clients, so we can begin to exercise some choice and control. That choice and control cannot occur in the information vacuum which currently exists.[46]

Knowledge-management system

2.48      PricewaterhouseCoopers (PwC) and the Australian National Audit Office (ANAO) have previously identified the need for a knowledge-management system to manage information and knowledge within the NDIA and ensure consistency and traceability of decisions.[47]

2.49      Holocentric was engaged by the NDIA from February 2015 until December 2017 to contribute to the development of NDIA Knowledge, a systems-based tool to integrate NDIS business processes, policies and guidance to staff via a central repository.[48]

2.50      The scope of the project was to capture all business processes and associated artefacts that would be used by NDIS staff.[49]

2.51      In October 2017, the NDIA stated that NDIA Knowledge 'will enable decisions to be tracked and traced to the point of origin e.g. legislation, policy, operational guidance. The system is being designed to become a single-source of truth and provide an appropriate audit trail'.[50]

2.52      However, in February 2018, 'the NDIA decided to put implementation of NDIA Knowledge on hold, and consider other knowledge-management systems, which may be more fit for purpose'.[51]

Committee view

2.53      The inability of participants and service providers to find adequate information or to have their queries answered in a satisfactory and timely manner is significantly impeding the implementation of the Scheme and the delivery of quality outcomes for participants.

2.54      The committee acknowledges that the NDIA is trying to address some of these issues through the implementation of the new participant and provider pathways. Proposed changes should reduce the volume of calls and emails to access information and resolve planning and plan implementation issues. However, the information provided by the NDIA about the process and timeframe to implement the new pathways beyond trial sites is nebulous and vague. There is no implementation schedule to inform stakeholders what the changes entail and when and how the changes will occur beyond trial sites.

Recommendation 1

2.55      The committee recommends the NDIA start the national rollout of the new pathways and make publically available a clear schedule of the changes to be introduced along with implementation dates.

Website

2.56      The committee has previously made recommendations about the need to improve the NDIS website design and navigation as well as the quality and accessibility of its content.[52] The committee is aware that the NDIA is currently redeveloping the NDIS website. A test website has recently gone live.[53] The committee encourages stakeholders to test the new website and send feedback to the NDIA.

2.57      The development of the new website must go beyond improving accessibility, design and navigation. The committee is of the view that improving the quality of its content is of prime importance. It is essential that all documents are reviewed prior their upload to ensure clarity, consistency and accuracy of information. The committee will closely monitor and further report on progress made through the redevelopment of the website.

Recommendation 2

2.58      The committee recommends the NDIA review all documents, including guidelines, forms and policies, prior to their upload onto the new website to ensure that they are current, clearly dated, fit-for-purpose and written in clear language.

NDIS Contact Centre

2.59      The committee is concerned that the NCC is not meeting the needs of participants and service providers. This resource is failing to provide end-users with adequate information and support to troubleshoot problems.

2.60      The inability to follow-up a query or a reported issue because of the absence of a tracking system is creating unnecessary delays, duplication of efforts and additional administrative burden for both the NDIA and end-users. Additionally, the committee heard that, too often, queries via email were not being attended beyond the automatic reply. The inability to directly contact ICT support staff or other specialised teams is also creating additional delays and administrative burdens for participants and providers. These poor business practices must urgently be addressed by the NDIA through the introduction of additional help desk functions and mechanisms that are commonly used by companies dealing with large numbers of end-users.

2.61      The need for additional communication channels that are fit-for-purpose and meet the needs of people with disability should not be underestimated. The committee noted the potential of the Nadia project to address accessibility issues and facilitate provision of information in an effective manner to the majority of participants.

Recommendation 3

2.62      The committee recommends the NDIA:

NDIA Knowledge-management system

2.63      The committee heard that the quality of information provided by NCC staff is often poor, pointing to a lack of experience and skills among the staff employed in the NCC. The committee believes that the absence of a systems-based tool, which would integrate NDIS business processes, policies and guidance to staff via a central repository is contributing to the current inability of NCC, NDIA and LAC staff to provide consistent and clear information to prospective and existing participants and service providers. The committee is concerned that the NDIA has put on hold the development of its knowledge-management system.

Recommendation 4

2.64      The committee recommends the NDIA urgently recommence work on the development and implementation of its knowledge-management system to ensure consistent decision-making processes and accurate provision of advice across the agency.

Business transactions

2.65      The MyPlace participant and provider portals enable business transactions between participants, providers and the NDIA.

2.66      As discussed in Chapter 1, there have been continuous developments and improvements to the participant and provider portals since their launch in July 2016.

2.67      The NDIA is planning to continue to add new features on the portals. For example, by early 2019, an Appointment Tool to allow better scheduling for participants and partners will be released.[54]

2.68      Despite these improvements, inquiry participants raised a number of issues about the portals, including:

Information, training and support to use the Portal

Participants

2.69      A key factor contributing to the difficulties associated with the portal is the lack of accessible information, training and support for participants and families.[56]

2.70      For example, the Benevolent Society reported that some participants are frustrated because they struggle to navigate the portal with limited information and assistance from the NDIA.[57]

2.71      CYDA recently conducted a survey regarding NDIS ICT with young people and families, which revealed that 83 percent of respondents had not received any training or support in using the portal.[58]

2.72      CYDA acknowledged the existence of the MyPlace Participant Portal: Step by Step Guide 2018 but contended that the availability of the guide is not well known.[59]

2.73      An NDIS participant pointed out that 'even when the information I need is available, I do not know how to navigate to find it'.[60]

2.74      A submitter suggested that the portal should have an immediate contact process similar to the 'chat to someone now' function that many websites have to facilitate resolving issues and answering questions.[61]

Barrier to self-manage plans

2.75      The lack of information and support available to use the portal is a contributing factor for NDIS participants to choose not to self-manage their plans.[62] For example, an NDIS participant explained:

A major factor in choosing not to self-manage in my second plan is that I do not understand the portal and it is unreliable and difficult to use.[63]

2.76      LanternPay contended that the portal is not suitably designed for self-managed participants, which contributes to the slow uptake of self-managing by participants.[64]

NDIA response

2.77      The NDIA stated that training and support to participants to access and navigate the portal is available through:

Administrative burden and costs

2.78      Despite investing in new IT infrastructure and systems to facilitate their business transactions under the NDIS, service providers continue to experience increased administrative burden.[66]

2.79      ┬áThe Dietitians Association of Australia provided an example of additional administrative tasks required to process invoices:

DAA are concerned about the new requirement to separate invoices for standard dietitian consult, travel, cancellation and report writing. This will lead to increased administrative burden for APD registered providers. [...] The Portal functionality and useability results in ineffective use of APR registered NDIS providers' time.[67]

2.80      Service providers also reported increased transactional costs because of portal issues ranging from system failures to lack of useful portal features to facilitate business transactions and reporting.[68]

2.81      For example, The Benevolent Society told the committee that the ongoing administrative and technical difficulties arising from the portal have created significant additional costs and barriers to providing services to clients.[69]

2.82      The administrative burden and hidden costs of the NDIS ICT systems are not restricted to providers.[70] For example, a submitter who self-manages his child's plan also reported that he spends hours administering his child's NDIS plan because the setup of the portal is inadequate.[71]

Unsuccessful payments to providers

2.83      While it is acknowledged there have been changes to the portal to address the causes of a significant proportion of payment problems, some inquiry participants argue that it is still difficult and administratively onerous to receive payments.[72]

2.84      The National Disability Services (NDS) reported that between June and September 2018, there was a 9 percent unsuccessful payment rate, which equalled almost 30 000 unsuccessful payment claims per week. It concluded:

Two years on, receiving payment for supports is still more difficult than it should be (some take many weeks to resolve). An equivalent payment failure rate in other sectors such as financial services or retail would be unthinkable.[73]

2.85      The NDS acknowledged that the NDIA responded to the problem by establishing a national provider payments team to facilitate the payment of rejected claims. However, the NDS noted that 'a well-functioning portal would not require this large, dedicated team of people to ensure providers receive payments' and that 'it is an expensive and cumbersome solution to an ICT problem'.[74]

2.86      Illawarra Disability Alliance reported that service providers have to employ staff just to manage portal claim errors, which is financially unsustainable.[75]

2.87      In an answer to a question on notice, the NDIA informed the committee of its recent work to address payment issues:

Over the past six months, the National Provider Payment Team (NPPT) has implemented a number of changes to enable a more efficient process for resolving payment issues. In October 2018, a further enhancement was made to the portal [...] The work undertaken has improved payment processing times and reduction of payment backlogs. [...] The NPPT has also developed a self-help guide available to assist providers through the payment claim process and hence reducing instances of payment claim error.[76]

Provider Finder tool

2.88      The portal features a Provider Finder tool to enable participants to find providers and services in their preferred locations. Participants and providers can search by different criteria, including by provider name, profession, support category or near location.[77]

2.89      The website also provides links to lists of NDIS registered providers for each state and territory.[78]

2.90      Inquiry participants are of the view that the search function to find providers and services on both the portal and the website requires improvement.[79]

2.91      Inquiry participants reported that the Provider Finder tool on the portal lacks accurate information about providers.[80] For example, Occupational Therapy Australia stated:

Despite many attempts to improve the tool, the resource is of limited value due to the significant number of errors in the listings. For example one occupational therapy practice is a provider of therapeutic supports is listed as providing 'Builder Surveyor' and 'Orthoptist' supports.[81]

2.92      However, the NDIA stated that 'providers have the ability to update information relating to their business operations without requiring manual intervention by the NDIA. This enables providers to self-serve and update information relating to contact details or appointment availability online'.[82]

2.93      The NDIA also informed the committee that further enhancements to the Provider Finder tool will be made in early 2019, including a more intuitive and usable map function.[83]

Portal changes

2.94      Inquiry participants reported that information about portal changes are not communicated to service providers and participants and recommended that the NDIA clearly inform users of upcoming changes to the portal.[84]

2.95      For example, The Benevolent Society pointed out that staff become aware of changes within the portal when they begin to experience problems.[85]

2.96      Greenacres noted that local NDIA staff are not provided with any support documentation or advice about portal changes and are unable to respond to basic questions.[86]

Lack of consultation

2.97      Inquiry participants pointed out that the portal was not designed in collaboration with users and called for much greater collaboration and consultation with stakeholders to find ways to make the NDIA portal work more efficiently and effectively.[87]

2.98      Allied Health Professionals Australia reported that the lack of testing with users before implementing portal changes has resulted in transaction issues, additional administrative and accounting burdens and costs to providers.[88]

2.99      Similarly, Occupational Therapy Australia submitted that the NDIA ongoing failure to consult with users or to properly trial intended changes to the portal have resulted in implementing changes that have had negative consequences for providers.[89]

2.100         Illawarra Disability Alliance also noted the lack of consultation with software vendors who deliver NDIS solutions.[90]

2.101         Inquiry participants overwhelmingly recommended that ICT systems, including the website and portal changes, be user tested with participants, carers and service providers to identify and resolve ongoing and emerging issues.[91]

2.102         However, the Department of Human Services, which developed the NDIS ICT solutions, says it places a strong focus on the adoption and implementation of User Centred Design and has established Design Hubs to provide an environment where designers, service users, partner agencies, third parties and others can work together to create and test solutions quickly.[92]

2.103         The NDIA also contended that 'it has significantly increased consultation with participants, providers and peak industry bodies on all business led ICT change projects'.[93]

Committee view

2.104         The committee acknowledges that the portals are a work in progress. New functions and features are regularly added to address issues identified by end-users and enhance the portals' functionality and capabilities.

Training and support

2.105         The committee is concerned that participants are unable to access training and support to use the participant portal. The committee understands that the 'new participant experience', when rolled out will assist in providing better support for participants to implement their plans, including how to use and navigate the portal. However, the committee is of the view that some participants will likely need support beyond the initial training provided by planners and LACs. The committee believes that implementation of Recommendation 3 of this report will ensure participants can access relevant support to use the portal at all times. In particular, work on co-designing a fit-for-purpose chatbot for the portal should start immediately.

Portal changes

2.106         The committee urges the NDIA to clearly communicate portal changes to end-users prior to implementation. Information about upcoming portal changes and relevant training materials should be posted on the portals.

Recommendation 5

2.107         The committee recommends the NDIA publish on the participant and provider portals the launch dates of future portal changes along with training materials.

Consultation with end-users

2.108         The committee is of the view that the NDIA must engage with stakeholders to design and enhance all aspects of the ICT services that underpin the NDIS service delivery model. It is clear that a lot of administrative burden and additional transaction costs would have been avoided if the NDIA had initially collaborated with end-users to design and improve the portals.

2.109         The development of the 'Provider Finder' tool is still in its infancy. The committee has previously heard that many participants and their families have come to rely on online resources to get information about NDIS registered providers.[94] ┬áTherefore, it is paramount the 'Provider Finder' tool is further developed to meet the needs of participants, their families and carers.

Recommendation 6

2.110         The committee recommends the NDIA work with service providers and participants to co-design future enhancements to the portals and 'Provider Finder' tool.

Hon Kevin Andrews MP
Chair

Senator Alex Gallacher
Deputy Chair

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