Chapter 9

Planning in rural and remote areas

9.1
Evidence suggested that many of the issues facing participants in metropolitan areas may be exacerbated for participants in regional and rural areas.1 However, during the course of the inquiry, the committee learned that some issues in the planning process may arise especially for participants in rural and remote areas. These issues include:
Lack of service providers.
Shortage of planners.
Planning meetings taking place via telephone rather than face-to-face
Transport.
Plans including insufficient funding for the cost of services in rural and remote areas.
9.2
Chapter 8 outlines issues raised about the planning process for Aboriginal and Torres Strait Islander participants, including those in rural and remote areas, in greater detail.
9.3
The National Disability Insurance Agency (NDIA) Rural and Remote Strategy (2016–2019) was published in February 2016. The Strategy includes the full range of supports available through the National Disability Insurance Scheme (NDIS), including access, planning, implementation and the delivery of specialist services. The Strategy’s goals were as follows:
Easy access and contact with the NDIA.
Effective, appropriate supports available wherever people live.
Creative approaches for individuals within their communities.
Harnessing collaborative partnerships to achieve results.
Support and strengthen local capacity of rural and remote communities.2
9.4
Some submitters called for the NDIS to be delivered and structured differently in rural and remote areas to take into account the distinct conditions in these areas. For example, Every Australian Counts argued that ‘people in regional, rural and remote areas want a fundamental rethink of the way the NDIS model works’. It called for ‘much more flexibility’, and for the NDIA to ‘redesign how the scheme works outside metropolitan areas, particularly in remote communities’.3

Lack of service providers

9.5
An issue for participants in rural and remote areas is a lack of service providers to provide the supports that participants are funded for in their plans, leading to low plan utilisation rates and the possibility of a decrease in funding in participants’ subsequent plans.4 As a result, service providers that do exist in rural and remote areas may feature long wait times and long waiting lists for services.5
9.6
Leadership Plus suggested that the ‘largest issues for regional clients that we are aware of are in implementation, rather than planning’.6 The broader issue of plan implementation is discussed further in Chapter 12.
9.7
Services for Australian Rural and Remote Allied Health (SARRAH) noted that some of its members suggested that almost all participants in rural and remote areas were ‘complex’ because of the additional challenges arising through reduced access to specialist service and fewer resources available to help them manage their conditions. SARRAH also suggested that participants in these regions may be unaware of services that could help them because of a long history of limited service provision:
Many people with disability in rural and remote Australia have done without supports due to previous absence of such services. This may pre-dispose against recognising potential supports to increase participant engagement. For instance, many adults have been unable to access physiotherapy or exercise physiology services and have settled on the idea that their physical abilities will inevitably deteriorate over time. They are unaware a program of activities/exercises may decrease their pain and maintain or even increase their level of movement and strength.7
9.8
SARRAH argued that poor ‘access to allied health services in rural and remote Australia is a chronic issue’, pre-dating the rollout of the NDIS. It suggested that many participants in rural and remote Australia may have limited or no knowledge of allied health services of allied health services, and so may not identify or consider these services when undertaking planning.8 Further, local area coordinators (LACs) may face considerable challenges in being aware of local services and how to access external support, while planners may be unaware of rural issues such as ‘thin markets’ and travel costs’. SARRAH emphasised the importance of planners covering rural and remote areas to have rural experience and knowledge.9
9.9
The Public Service Research Group UNSW Canberra argued that if an aim of the NDIS is to provide people with disabilities more control ‘through choice and competition, the planning process must acknowledge that not all individuals have access to robust or functioning markets in which to exercise this control’.10
9.10
SARRAH highlighted ‘anecdotal reports’ of planners deliberately creating plans to include only services that are available in rural and remote areas, rather than what a participant needs, ‘thereby undermining broader planning and demand management/supply considerations’.11 Likewise, Allied Health Professions Australia also suggested that ‘planning processes for rural and regional participants are sometimes based on available services rather than participants’ needs and goals’.12
9.11
The Deafness Forum of Australia, Deafblind Australia, Audiology Australia, Able Australia, Senses Australia and Neurosensory proposed that NDIS funding cover telepractice models of service delivery for populations who cannot access face-to-face services because of geographical or other reasons, to help these participants gain faster access to more hearing services.13 Similarly, Audiology Australia suggested that participants unable to access face-to-face services, especially in remote areas, would benefit if the NDIS were to fund teleaudiology through increased and more timely access to audiological services.14
9.12
Somerville Community Services, which operates in the Northern Territory, observed that planning ‘for participants in rural and regional areas is compromised by the lack of services available’. It argued that ‘this becomes more problematic in remoter regions with many participants being unable to fully utilise the supports in their plans’. It proposed that the NDIA consider ‘alternative funding models for areas where services are limited or
non-existent’, such as temporary ‘hybrid models’ that would fund
‘non-government organisations or Aboriginal Community Controlled Organisations to underpin individual packages for NDIS participants’.15
9.13
SARRAH made the following proposals to improve allied health service availability, in particular, in rural and remote areas:
Supplementary funding.
Infrastructure grants.
Loading of fee schedules based on rurality.
Practice incentive payments to ensure that rural and remote participants can access allied health interventions to an equivalent level as participants in metropolitan areas.
Enable participants to use local service providers who may not be registered with the NDIS.16
9.14
Several other submitters proposed that plans take into account the limited services and thin markets in rural and remote areas.17 Queensland Advocacy Incorporated called for plan reviews to allow for any difficulties participants may have experienced in sourcing service providers before making decisions about funds that have not been spent.18

The Australian Government’s position

9.15
The Disability Reform Council in December 2013 ‘agreed to use a more flexible approach to address market challenges in the NDIS’, with initial projects to address thin markets in all jurisdictions. These projects were due to happen in late 2019, with a comprehensive roll-out plan to be brought to the Disability Reform Council in 2020.19
9.16
In 2019, the Department of Social Services (DSS) and the NDIA commissioned the Thin Markets Project, with thin markets being defined as ‘inadequate service availability resulting in participants’ needs not being met’.20 Consultation was open between April and August 2019, with the project’s discussion paper asking stakeholders to agree on how to identify thin markets, their causes, where they are particularly acute, and to identify ways in which the government should respond to thin markets.21
9.17
The NDIA reported in its June 2020 Quarterly Report that it is ‘developing a Market Commissioning Strategy and comprehensive roll out plan in consultation with state, territory and Commonwealth governments to support a flexible approach to addressing market challenges’. This strategy will involve trial projects in all jurisdictions in the second half of 2020 to collect ‘evidential insights’ and test ‘the NDIA approach to market challenges’.22
9.18
The NDIA outlined the following options that NDIS planners and support coordinators may consider if specific supports are not available in a particular area:
Encouraging providers from adjacent sectors (for example health, local government and aged care) already working in the area to register to provide NDIS supports.
When a participant is self-managing or using a plan management provider, and in exceptional circumstances, the participant’s plan can be utilised to facilitate family members to provide supports.23
9.19
The NDIA also reported in November 2019 that it was ‘working closely with State and Territory governments to consider more innovative options to market commissioning in thin markets’, with areas chosen to trial ‘new
place-based commissioning approaches’.24
9.20
In the October 2020 hearing, Mr Martin Hoffman, the CEO of the NDIA, outlined that as a result of COVID-19, participants are now receiving ‘more services in teleconference and video-conference formats’. Mr Hoffman outlined that the NDIA was undertaking the following further initiatives to address market issues in rural and remote areas:
[N]ot everything can be done via screen, so one of our market development actions is increasingly to make more information available to the provider sector as to where potential demand is. We’re increasing the detail of information about where participants are and the sorts of requirements that they have, thereby encouraging the market to respond—which, again, was part of the underlying philosophy of the scheme...That will enable, through information, the market to work better and, hopefully, encourage the provision of services, including in rural and remote areas.25
9.21
Mr Hoffman informed the committee that in the ‘really remote areas’, the NDIA and DSS are:
…working on a series of trials of aggregated service provision where, effectively, the agency steps in, aggregates demand among the number of participants, and sources the provider services required. That’s a more direct, hands-on engagement in truly remote markets, where you might say there is market failure or that it’s difficult for there to be a competitive market given the thinness of the population density.26
9.22
The NDIA also advised in answers to questions on notice received in
October 2020 that it has implemented the Community Connectors Program, which ‘provides improved support for Australians with disability in rural and urban locations’, focusing on, among other groups, Aboriginal and Torres Strait Islander communities. It stated that Community Connectors:
…are trusted local community members who enable better linkages between people, communities and services. People with disability, their families and carers rely on the responsiveness of Community Connectors to access information and supports required to engage, access and benefit from the NDIS including planning activity.27

Shortage of planners

9.23
A further issue raised in the inquiry concerned a limited number or lack of LACs and planners in some locations, including those with expertise in particular disability types.28
9.24
The committee learned that small teams of planners may be working across large locations, meaning planners may have less capacity to develop expertise in particular areas of disability or to mentor other, less experienced planners.29 Further, submitters also reported that planners in some instances were not aware of rural and remote locations services available in an area and the distances required for participants to access services.30
9.25
Multiple Sclerosis Australia provided an example of the length of time that participants in rural and regional areas may have to wait for a planning meeting:
…a person living in the Great Southern Region of WA was found to be eligible for the NDIS in October 2018. Our last contact with the person was in May [2019] and at this stage they had not received any further information from the NDIA as to when arrangements for a planning meeting might be made. The person felt that a home visit for planning was required so that her living situation and needs could be better considered. At this stage they have been waiting for almost seven months for a planning meeting.31
9.26
Noah’s Ark Inc suggested that ‘there is currently a severe shortage of planners in rural and regional areas’, with long wait times, families being more likely to be offered a telephone meeting, difficulties contacting planners, and difficulties recruiting professionals for planning and Key Worker roles. It proposed the following solutions, among others:
Incentives for experienced workers to move to rural and remote areas, and for those already in those areas, to remain.
Incentives for universities to promote careers in early childhood intervention.
Incentives for allied health professionals to focus on careers in early child intervention.
Initiatives to enable student placements without creating financial disadvantage to providers.
Subsidies to enable adequate training of the workforce.32
9.27
The parent of a participant reported that he had been ‘happy with the expertise and knowledge of the two planners’ who he had worked with, after the NDIA assigned planners from outside the participant’s rural region because of the need for the planners to have more expertise than was locally available.33
9.28
As noted in Chapter 7, the Australian Government’s 2020–21 Budget, handed down in October 2020, accounted for NDIA average staffing levels for 2020–21 to be 4,000, an increase of 770 from the previous budget.34 DSS informed the committee:
The Australian Government is committed to ensuring the NDIS is fully funded both for participant supports and for the NDIA’s operating expenses. The appropriation bills the Government puts to the parliament ensure that, together with the funds paid to the NDIA by states and territories, the funds the NDIA receives and holds are sufficient to meet all the expenditure incurred.35

Planning meetings taking place via phone

9.29
The committee was informed that some planning meetings were taking place via phone because an area has no local planners, despite many participants being unwilling to have planning meetings via telephone, in some instances because it may be culturally inappropriate.36
9.30
Vision Australia suggested that phone reviews had been occurring where participants were not aware that phone conversations were actually planning meetings, an issue especially in regional and remote areas that may lead to ‘participants being severely underfunded as a result’.37
9.31
As noted above, the NDIA advised that because of COVID-19, ‘participants now receive more services in tele- and video-conference formats, and are more willing to engage with the Agency in these formats as well’.38 Chapter 12 outlines the issue of planning meetings taking place via telephone in greater detail.

Travel and transport

9.32
A further issue raised in evidence concerned lack of funding for travel and transport and lack of transparency in how it is funded.39
9.33
The NDIA has three levels of support for transport assistance which are indexed on an annual basis. The level for which participants are eligible depends on whether they are working or studying.40 This is separate to the funding for travel caps for providers outlined in the NDIS Price Guide, which is published every year.41
9.34
SARRAH suggested that some planners had limited understanding of issues surrounding travel for allied health providers, such as cost and availability. It further argued that current funding models are not sufficient to incorporate the significant ‘travel time and expenses associated with regional, rural and remote services’. It noted that populations living in rural and remote areas may have lower incomes and higher burdens of chronic disease and disability, especially among Aboriginal and Torres Strait Islander peoples.42
9.35
Vision Australia argued that recent increases to travel caps in the NDIS Price Guide still were not sufficient to recoup costs for travel to regional and remote areas in some instances, with the ‘costs of providing services considerably [outweighing] the expenses we incur in delivering them’.43
9.36
Occupational Therapy Australia recommended that the NDIA improve its transparency, consistency and fairness in its decisions on the number of hours of support funded in a plan, particularly where a participant’s geographical location may affect how much they can utilise these hours. It suggested that a participant who has access to a local therapist may be able to utilise more hours of therapy than someone who lives further away and may lose therapist time in travel expenses.44
9.37
In 2017, the Federal Court, in McGarrigle v National Disability Insurance Agency ruled that the NDIA cannot only partially fund transport costs for travel where these are reasonable and necessary. Carers NSW argued that this decision should impact transport funding for participants living in regional, rural and remote areas. However, it contended that ‘delays in updating NDIS transport guidelines to reflect this decision have resulted in ongoing challenges for participants…with ongoing reports’ that funding for transport remains inadequate in participant plans.45
9.38
The Minister for the NDIS, the Hon Stuart Robert MP, in February 2020 announced that participants would ‘be able to flexibly use their plan’s core support funding to claim service provider costs associated with transporting participants to and from NDIS community-based activities’.46 The NDIA further advised the committee in October 2020 that participants will have ‘flexible, personalised plan budgets’, with funds no longer being split into 15 categories but, rather, two budgets—with most funds being ‘completely flexible’.47

Insufficient funding for services

9.39
Some submitters expressed concern that the actual costs of services in rural and remote areas vary compared with how much is funded in a plan.48
9.40
Autism Spectrum Australia outlined an example of participants in remote settings ‘receiving exactly the same funding amount for service implementation, despite having very different needs and goals’. It also noted that in some areas, there may be difficulties engaging providers, and suggested that planners or coordinators ‘work with identified providers to create cohorts…[to] ensure sustainability for providers, and ensure access to quality supports for participants in these regions’.49
9.41
Occupational Therapy Australia reported that funding for participants in rural and remote areas did not always provide for additional demands faced by providers in these areas, despite it being intended to. This additional work may involve researching what assistive technology is available in a region, liaising with equipment providers and arranging equipment trials, complicated by the limited number of local products and services.50
9.42
The NDIA informed the committee in January 2020 that the NDIS Price Guide allows for higher prices for some supports in remote and very remote areas, with remote and very remote loadings ‘increased from 20 per cent and
25 per cent to 40 per cent and 50 per cent respectively’.51 As noted above, the NDIA also informed the committee in October 2020 that participants will be able to use most funds in their budgets flexibly ‘for participants to use on the supports they need, when they need them’.52

Other issues raised about planning in rural and remote areas

9.43
The committee was informed of a number of other issues related to planning in rural and remote areas, including the following:
Plans not indicating that the participant is in a rural location.53
Community service providers, health professionals and organisations providing advice to potential and current NDIS participants in the absence of a local NDIA presence, with these groups rarely compensated for their work.54
Limited notice given to support people and organisations that a planning meeting is occurring, despite some of these individuals needing to make travel arrangements.55
Planners being unaware that deaf participants living in rural and remote areas may only be able to access interpreters through Video Remote Interpreting, and not including communication devices with 4G/5G capacity or data in plans.56
Limited or unreliable internet access, meaning the LAC is unable to access the NDIS planning program during planning meetings.57
Greater wear and tear on equipment, meaning rural and remote participants may need better quality assistive technology to withstand harsher environment and other forms of back-up for some equipment.58

Committee view

9.44
The committee notes that the NDIA’s Rural and Remote Strategy was published in February 2016. Despite implementation of this strategy, major issues remained outstanding when this inquiry took evidence in 2019 and in 2020, more than three years after the Strategy was first published. This suggests that the Strategy needs a complete rethink.
9.45
The committee recognises that the NDIA is developing a Market Commissioning Strategy with trial projects to be rolled out in all jurisdictions in the second half of 2020 to test the NDIA’s approach to market challenges. However, the committee considers that the NDIA should review the Rural and Remote Strategy and create a new strategy to take into account the issues raised in this chapter about planning for participants in rural and remote areas, including, where relevant, the findings of the NDIS Thin Markets Project and the Market Commissioning Strategy.

Recommendation 31

9.46
The committee recommends that the National Disability Insurance Agency review its Rural and Remote Strategy 2016–19 and, as part of this process, examine practical solutions to the issues outlined in this report regarding planning for participants in rural and remote areas.
9.47
Many of the issues raised in relation to planning in rural and remote areas are symptoms of broader, structural problems with how the NDIS is working in rural and remote areas in general. The committee will maintain a watching brief on the broader question of the effectiveness of the NDIS in rural and remote areas in its inquiries into General Issues around the Implementation and Performance of the NDIS, including thin markets and the progress of the review into the Rural and Remote Strategy, and make further recommendations as it sees fit.

  • 1
    Scope (Aust) Ltd, Submission 85, p. 6.
  • 2
    National Disability Insurance Agency, Rural and Remote Strategy 2016–2019, February 2016, pp. 2–3.
  • 3
    Every Australian Counts, Submission 83, p. 7.
  • 4
    See, for example, Public Service Research Group UNSW Canberra, Submission 16, p. 4; Novita, Submission 64, p. [2]; Australian Lawyers Alliance, Submission 78, p. 10; Scope (Aust) Ltd, Submission 85, p. 6; Office of the Public Guardian (Qld), Submission 114, p. 12; Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, p. 8; roundsquared, Submission 103, p. 23; The Royal Australasian College of Physicians, Submission 105, p. 8; Tasmanian Government, Submission 117, p. 9
  • 5
    Children and Young People with Disability Australia, Submission 90, p. 17; Scope (Aust) Ltd, Submission 85, p. 6. See also Ms Elise Jeffery, Private Capacity, Committee Hansard, 28 October 2019, p. 47.
  • 6
    Leadership Plus Inc, Submission 25, p. 13.
  • 7
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, p. 10.
  • 8
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, p. 3.
  • 9
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, pp. 2–5.
  • 10
    Public Service Research Group UNSW Canberra, Submission 16, p. 4.
  • 11
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, p. 5.
  • 12
    Allied Health Professions Australia, Submission 74, p. [11].
  • 13
    Deafness Forum of Australia, Deafblind Australia, Audiology Australia, Able Australia, Senses Australia and Neurosensory, Submission 10, p. 8.
  • 14
    Audiology Australia, Submission 92, p. 5.
  • 15
    Somerville Community Services, Submission 68, p. 5. This model is outlined in Northern Territory Department of Health (PwC’s Indigenous Consulting), NDIS Community of Practice: The NDIS in Remote Northern Territory, October 2018, pp. 27–29.
  • 16
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, pp. 8–9.
  • 17
    Family Advocacy, Submission 108, p. 22; Office of the Public Guardian (Qld), Submission 114, p. 12.
  • 18
    Queensland Advocacy Incorporated, Submission 87, p. 13.
  • 19
  • 20
    Department of Social Services, NDIS Thin Markets Project, https://engage.dss.gov.au/ndis-thin-markets-project/ (accessed 12 October 2020).
  • 21
    EY, NDIS Thin Markets Project: Discussion Paper to Inform Consultation, April 2019, p. 7.
  • 22
    NDIA, NDIS Quarterly Report to Disability Ministers, June 2020, p. 75.
  • 23
    NDIA, answers to question on notice, 19 November 2019 and 21 November 2019 (received
    7 January 2020), p. [17].
  • 24
    NDIA, answers to question on notice, 19 November 2019 and 21 November 2019 (received
    7 January 2020), pp. [17–18].
  • 25
    Mr Martin Hoffman, Chief Executive Officer, NDIA, Proof Committee Hansard, 12 October 2020,
    pp. 1, 9.
  • 26
    Mr Martin Hoffman, Chief Executive Officer, NDIA, Proof Committee Hansard, 12 October 2020,
    pp. 1, 9.
  • 27
    National Disability Insurance Scheme, answers to questions on notice, 3 September 2020 (received 6 October 2020), p. [27].
  • 28
    Integra, Submission 50, p. 8; MND Australia, Submission 44, p. 5; Noah’s Ark Inc, Submission 76,
    pp. 17–18; roundsquared, Submission 103, p. 10; National Rural Health Alliance, Submission 91,
    p. [5]; Office of the Public Guardian (Qld), Submission 114, p. 12.
  • 29
    Allied Health Professions Australia, Submission 74, p. [4].
  • 30
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, p. 10; People with Disabilities (WA), Submission 93, p. 17.
  • 31
    Multiple Sclerosis Australia, Submission 3, p. 7.
  • 32
    Noah’s Ark Inc, Submission 76, p. 18.
  • 33
    Name Withheld, Submission 132, p. [1].
  • 34
    Commonwealth of Australia, Budget 2020–21: Agency Resourcing, Budget Paper No. 4, 6 October 2020, p. 168; Commonwealth of Australia, Budget 2019–20: Agency Resourcing, Budget Paper No. 4, 2 April 2019, p. 177.
  • 35
    Department of Social Services, answers to questions on notice, 3 September 2020 (received 2 October 2020), p. [1].
  • 36
    See, for example, Services for Australian Rural and Remote Allied Health (SARRAH),
    Submission 72, p. 10; Allied Health Professions Australia, Submission 74, p. [11]; Exercise and Sports Science Australia, Submission 46, p. 11; St Vincent’s Hospital Melbourne, Submission 56, p. 8.
  • 37
    Vision Australia, Submission 27, p. [9].
  • 38
    Mr Martin Hoffman, Chief Executive Officer, NDIA, Proof Committee Hansard, 12 October 2020,
    p. 1.
  • 39
    See, for example, Blind Citizens Australia, Submission 6, pp. 2, 7; Illawarra Disability Alliance, Submission 11 (inquiry into general issues), p. 4; Australian Lawyers Alliance, Submission 78, p. 10; Family Advocacy, Submission 108, p. 22; Rights Information and Advocacy Centre, Submission 31, p. [7]; Vision Australia, Submission 27, p. [3].
  • 40
  • 41
    The latest version is the NDIS Price Guide 2020–21, published in October 2020, available from https://www.ndis.gov.au/providers/price-guides-and-pricing (accessed 12 October 2020).
  • 42
    Services for Australian Rural and Remote Allied Health (SARRAH), Submission 72, pp. 4, 10.
  • 43
    Vision Australia, Submission 27, p. [10].
  • 44
    Occupational Therapy Australia, Submission 23, p. 12.
  • 45
    McGarrigle v National Disability Insurance Agency [2017] FCA 308; Carers NSW, Submission 89, p. 13.
  • 46
    The Hon Stuart Robert MP, Minister for the NDIS, ‘The NDIS Plan’, speech delivered at the National Press Club, 14 November 2019, https://ministers.dss.gov.au/speeches/5266
    (accessed 3 February 2020).
  • 47
    Mr Martin Hoffman, Chief Executive Officer, NDIA, Proof Committee Hansard, 12 October 2020,
    p. 2.
  • 48
    See, for example, Maurice Blackburn Lawyers, Submission 11, p. 13; Children and Young People with Disability Australia, Submission 90, p. 17.
  • 49
    Autism Spectrum Australia, Submission 5, p. 6.
  • 50
    Occupational Therapy Australia, Submission 23, p. 11.
  • 51
    NDIA, Answers to question on notice, 19 November 2019 and 21 November 2019 (received
    7 January 2020), p. [17].
  • 52
    Mr Martin Hoffman, Chief Executive Officer, NDIA, Proof Committee Hansard, 12 October 2020,
    p. 2.
  • 53
    Queensland Advocacy Incorporated, Submission 87, p. 13.
  • 54
    Exercise and Sports Science Australia, Submission 46, p. 11.
  • 55
    Northern Territory Office of the Public Guardian, Submission 116, p. [8].
  • 56
    Deaf Services, Submission 60, pp. [10, 11].
  • 57
    roundsquared, Submission 103, p. 20.
  • 58
    National Rural Health Alliance, Submission 91, p. [6].

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