Delivery of services
This chapter reviews the impediments to delivery of appropriate and
timely services under the NDIS, which have been identified throughout the
inquiry by NDIS Participants, peak bodies, Governments and service providers.
Firstly, it discusses issues associated with the planning process
leading to poor quality of Plans and need for Plan reviews. Then, it explores
the concerns raised by submitters about Plan reviews and outcomes.
The second part of the chapter focuses on the barriers experienced by
service providers to operate and provide quality services in the NDIS
environment. This includes issues with the registration process, NDIS pricing
caps and workforce shortages.
The final part of the chapter explores the rollout of ILC and reported
issues associated with the quantum of funding allocated to ILC activities
during the transition period; the funding model itself; and the emerging gaps
Quality of Plans
Across all jurisdictions, submitters continue to report poor planning
experiences and outcomes for Participants. These include inconsistencies in
Plans; and inadequate levels of support in Plans leading to Participants asking
for plan reviews.
Overall, the committee received significant evidence of inconsistent
packages being granted to NDIS Participants across all jurisdictions, with some
Participants with similar conditions and similar support needs receiving vastly
different Plans. 
The quality of NDIS Plans appears to be dependent on two main factors:
1) the NDIS Planner's knowledge and expertise and; 2) the level of advocacy
families and NDIS Participants can undertake and their knowledge of the
Many submitters reported a general lack of knowledge, expertise and
experience of Planners resulting inconsistent and inadequate plans.
Some plans may be over-funded, whilst others are significantly under-funded.
The NSW Department of Premier and Cabinet noted that 'it appears that
Planner knowledge and capability is highly varied, as is their interpretation
of reasonable and necessary supports'.
Allied Health Professions Australia reported that 'understanding of
allied health professions is poor among Planners, leading these supports to be
absent from Participant packages'.
For example, the committee received evidence that Assistive Technology supports
are often inconsistent and expert recommendations are often ignored by
MJD Foundation (MJDF) reported that 'the variable quality of Planners
has meant that clients of the MJDF have experienced a range of planning
In its submission, Speech Pathology Australia conveyed the view of its
Speech pathologists report that the NDIS Planning process and
the decisions made by the NDIS Planners themselves generally demonstrate a lack
of understanding of the complexity of needs for individuals with disability and
the complexity involved in developing an outcome based plan for supports and
At a public hearing in Melbourne, Ms Rachel Norris, CEO of Occupational
Therapy Australia (OTA), summarised the views of OTA members:
The quality of NDIS Plans varies considerably from person to
person and depends on the planner's level of experience and understanding of
the breadth of services available to Participants. Planners are recruited from
a variety of backgrounds, and it is clear that they frequently underestimate
the hours of therapy required for a participant to achieve their goals, which
subsequently affects the quality of their plan. Nor do they understand
occupational therapy's key role in the prescription and review of assistive technology
and home modifications.
Advocacy and access to pre-planning
Mental Health Australia noted that 'strong anecdotal evidence indicates
that consumers who are well supported by strong advocates (whether they happen
to be carers, support workers, formal advocates or others) continue to receive Plans
which better suit their needs'.
Ms Rachel Norris, CEO of Occupational Therapy Australia, also pointed
out that 'too often the quality of a plan comes down to how effective the
participant or advocate is at stating their needs during plan development
Ms Natalie Siegel-Brown, the Public Guardian (Queensland), explained how
having an advocate during the planning process can make a real difference in
[...]sometimes just having an advocate sitting beside a person
in the NDIS-planning process with a planner will reap a different quantum of
funds compared to a very similarly profiled person who doesn't have an advocate
sitting there and who is in front of the same planner.
Cohealth related the following example, which illustrates the critical
role of advocacy during the planning process:
For example, two consumers of cohealth mental health
community support services, with very similar conditions and circumstances
received very different Plans. The main difference appeared to be that one had
an advocate/support accompany them to the planning meeting.
Importance of pre-planning
According to submitters, pre-planning also plays a fundamental role and
can make a significant difference in quality of outcomes for Participants.
For example, Neurological Alliance Australia reported that the 'lack of
pre-planning can result in ineffective Plans which require an NDIS review and /
or result in negative health impacts for people with a progressive
The Summer Foundation also reported the importance of supporting people
during the pre-planning and planning process and identified funding gaps:
A lack of preparation support for planning means significant
gaps have emerged because individuals are unable to articulate their complete
needs and goals as is required for a good outcome from planning. The important
work of supporting people with NDIS pre-planning and through the planning
process is not being funded in the national rollout, and services such as case
management that could have assisted are being de-funded prematurely as the NDIS
identified a lack of funding available for pre-planning, which is why
organisations such as VCOSS
and Neurological Alliance Australia
are calling for funding comprehensive pre-planning support.
However, some organisations receive funding from state governments to
provide pre-planning support. For example, Mr Kevin Stone, CEO of VALID, told
the committee that VALID is receiving funding from the Victorian Government's
Transition Support Package to provide information and support to people during
That fund allows us to do a number of different things. Our
main strategy is to provide information sessions to people with disability and
to families about the NDIS and its operation. That's what we basically call a
NDIS 101 session. [...] That equips parents or family members in the skills of
person centred planning, goal setting, supporting their sons and daughters to
self-advocate et cetera. Basically, it supports them to negotiate the system.
The evidence that we have is that families who go through that process are much
better equipped to enter into the NDIS process.
The NSW Government is also funding a few organisations to deliver
pre-planning support and information. Ms Serena Ovens, Executive Officer at
Physical Disability Council of NSW, explained:
Currently, we're funded by the New South Wales department of
disability, ageing and home care, and that's just approximately five to six
organisations in New South Wales, to assist in pre-planning. So we do have
limited capacity to assist some people to work with us one on one for a far
greater period of time than they will do in their own planning meeting. We have
the ability to go back and forth and show a pre-plan to them, talk about it,
look at what might be missing and redo and readjust more than once for those
people before they even get to their NDIA or LAC planning meeting.
According to submitters, poor planning has led to an increase in the
number of reviews being requested.
A slow and frustrating process
Feedback received by Family Advocacy through a survey of 100 families
reveals that 'the review process is slow, frustrating and stressful'.
For example, one family related the following experience:
Too long to tell. Three Plans in eight months - none of which
were instigated by us but because planner had stuffed up. Had to appeal but
appeal was dismissed as having 'no grounds'. Received a phone call this week by
NDIS saying there had been a 'programming error' and they would like the
opportunity to have a face to face meeting with them.
Occupational Therapy Australia noted that plan reviews are lengthy and
this can jeopardise Participants' ability to progress toward achieving their
These reviews can take months to complete, resulting in added
frustration for families and potentially affecting the relationship between
participant and provider. In addition, the long wait associated with plan
reviews frequently results in any progress that the participant has made
towards their goals being lost due to lack of continuity. This ultimately
results in increased supports being required to re-establish progress.
At a public hearing in Melbourne, Miss Grace Poland, an NDIS Participant,
told the committee that she requested a review of her NDIS Plan and 'it took 11
weeks to get a response'.
Allied Health Professions Australia also reported that 'reviews are
currently taking weeks and even months to complete, resulting in added
frustration for families and potential service gaps'.
Anglicare Australia raised the issue of people not having access to services
because of reviews taking too long:
With reviews often taking months rather than the stipulated
two weeks the result is people in limbo without access to services critical to
their health and wellbeing.
The Office of the Public Advocate (Victoria) identified a need for the
NDIA to address the long wait time for plan review.
Plan reviews leading to reduced
Submitters told the committee that there are instances where Participants
have sought a Plan review which has resulted in a reduction in funding.
The ACT Government was approached by a number of Participants whose Plans
are being cut after a plan review and reported:
In some occasions Plans are being cut by up to 80%. The ACT
has also been informed that Participants are unwilling to ask for a plan review
as they are concerned their Plans will be cut.
In its submission, Carers NSW said 'there have been widespread reports
in NSW of funding being significantly reduced following a Plan review' and
provided the following examples:
Ariana cares for her daughter Jocelyn and was forced to
participate in a phone based plan review. [...] When the plan came back, the
funding allocation had been reduced by three quarters, placing Ariana’s
employment at risk.
Fatimah’s son Mohamed is nonverbal and exhibits behaviours of
concern. When his plan was reviewed, the funding allocated to Mohamed was
drastically reduced, leaving only around $700 for the year to cover respite,
and no funding at all for vacation care. This loss of funding greatly
distressed Fatimah, who will not be able to work until the matter is resolved.
The committee acknowledges the work undertaken by the NDIA to improve
the planning process and Participants' experiences and outcomes. The new
which is currently being piloted, is a step in the right direction to improve
the pre-planning and planning processes. The pilot is expected to be completed
by the end of April 2018 and then rolled out nationally. The committee
recommends the NDIA ensure that ability for Participants to see, discuss and
potentially amend their draft Plan before it is finalised is rolled out nationally
as soon as possible.
The committee noted the importance and benefits of pre-planning
supports, and is aware that, currently, some state Governments are funding such
activities. The committee recommends the NDIA ensure that across all
jurisdictions people with disability can access pre-planning supports.
The committee understands that the NDIA is continuing to develop tailored
pathways for people with psychosocial disability; children; people from
Aboriginal and Torres Strait Islander communities; those from culturally and
linguistically diverse backgrounds and Participants with more complex needs.
Whilst the committee is pleased to see such work under way, it is concerned
with the long time it is taking for the NDIA to respond and address the
planning issues experienced by these cohorts. The committee urges the NDIA to
ensure these new pathways are piloted as soon as possible and then promptly
rolled out nationally.
The committee recommends the NDIA ensure that across all jurisdictions
people with disability can access pre-planning supports.
The committee recommends the NDIA urgently finalise and start piloting
the tailored pathways it has been developing for people with psychosocial
disability; children; people from Aboriginal and Torres Strait Islander
communities; those from culturally and linguistically diverse backgrounds and Participants
with more complex needs.
The committee believes the number of requests for plan reviews due to
inadequate Plans should drop once the practice of allowing Participants to see and
comment on their draft Plan before it is finalised is implemented. The
committee notes that the NDIA is currently not reporting in a consistent manner
on the number of unscheduled plan reviews. The committee agrees with the
recommendation made by the Productivity Commission that the NDIA publicly
report on the number of unscheduled plan reviews, on reviews of decision,
review timeframes, outcomes of reviews and stakeholder satisfaction with the
The committee is concerned with widespread reports of funding in
Participants' Plans being significantly reduced following a Plan review. Whilst
the committee acknowledges there is no publically available data to determine
the extent of the practice of cutting funding at Plan reviews, the anecdotal
evidence from a number of sources suggests a trend in reduction of funding and
supports in Participants' Plans after a Plan review. More clarity and
transparency around review processes and outcomes are urgently required. The
NDIA must publically and regularly report on the outcomes of reviews and
undertake an analysis as to why funding in Plans may have been reduced in some
The committee recommends the NDIA publish data and analysis on the
following in its Quarterly Reports:
number of plan reviews;
waiting times Participants face for reviews;
outcomes of plan reviews in terms of whether the overall package
has been increased or decreased;
satisfaction rating of Participants following a plan review.
The committee is concerned with the lengthy waiting times experienced by
Participants in getting their Plans approved, activated and reviewed. This is
impeding on Participants' access to initial services and continuity of
The committee recommends the NDIA focus all necessary resources and
efforts on reducing waiting times at all points of the Scheme, specifically for
plan approval, activation and review.
Impediments to deliver services
The following section deals with the impediments to deliver services
identified by service providers during the course of this inquiry. Barriers to
deliver services include the registration and administrative burdens
experienced by providers; the inadequacy of NDIS pricing caps; and disability
Registration processes and costs
At present, during the transition period, ensuring the quality and safeguards
of disability supports remains the responsibility of the Commonwealth, state
and territory Governments. As the quality and safeguards arrangements differ
between jurisdictions, providers must comply with the individual requirements
of each jurisdiction in which they are providing supports.
As a result, the registration requirements and processes to become an NDIS
service provider differ across jurisdictions.
Overall, submitters expressed concerns about the inconsistent provider
registration requirements across jurisdictions, arguing it is a significant
barrier to entry into the NDIS marketplace.
For example, Dietitians Association of Australia described the
registration process as difficult for some providers, 'with some States
requiring compliance with onerous processes'.
Some occupational therapists have reported that 'the registration
process can be quite lengthy, which may deter some people from signing up as
A provider in Victoria reported that to register as a provider for NDIS
Early Childhood Supports is 'overly onerous, particularly for sole traders and
Speech Pathology Australia explained that after receiving 'concerning
feedback' from many of its members seeking to register as NDIS providers, it
examined the requirements in each state and territory and formed the following
[...] it is the view of Speech Pathology Australia that the
requirements have been designed (and are entirely appropriate) for assessment
of larger disability specific organisations. When these requirements are
applied to small or solo allied health businesses, they act as a significant
disincentive for speech pathologists to become NDIS registered providers within
Speech Pathology Australia noted that 'alternative arrangements have now
made for small speech pathology and occupational therapy practices within New
South Wales (NSW) and in Northern Territory (NT)'.
Third Party Verification
According to Allied Health Professions Australia, the requirement for
third party verification in particular has been a frequent issue reported by
small providers, especially in NSW and Victoria.
Similarly, Making Connections Together argued that 'providers have their hands
tied by Third Party Verification which is excessive for small businesses'.
Dietitians Association of Australia also expressed concerns about the
process of verification within registration to be implemented from July 2018,
arguing that 'the proposed process presents considerable burden to providers
compared to the current allied health application for provider with Medicare'
and that 'whereas there is no cost to register with Medicare, it is likely that
the NDIS verification process and components such as police checks and working
with vulnerable person checks will cost some hundreds of dollars'.
Speech Pathology Australia reported that the average estimated cost of
Third Party Verification is around $4,500 and is a reason for not registering,
with one provider saying:
I deliberately have not registered for supports that require
3rd party verification, it is not worth it for a sole trader.
Occupational Therapy Australia recently conducted a survey which
revealed that reasons provided by therapists for not registering included
'negative feedback from colleagues about the NDIS, and the administrative work
and costs involved in registering'.
Submitters raised concerns about the additional administrative burden of
providing services through the NDIS.
This is resulting in additional costs borne by service providers as well as
some providers choosing not to register as NDIS providers.
Speech Pathology Australia members explained the situation:
Members reported the increased administration burden of providing
services through the NDIS (in comparison to other funding streams including
Better Start for Children with Disability, Medicare, Department of Veteran
Affairs and private health insurance). Many practices have resorted to
employing additional administrative staff to work solely on NDIS administration
processes in the transition. The additional excessive administrative burden
cannot continue to be absorbed into the per hour NDIS fee for speech pathology
services for many private practitioners.
This is resulting in speech pathologists 'delaying entering the NDIS
market, reducing the share of their practice case load of NDIS clients and/or
restricting service to self-managed clients to avoid the costs associated with
excessive administrative burden'.
The committee acknowledges that during the transition period and until
the NDIS Quality and Safeguarding Framework (the Framework) is implemented, the
Commonwealth, state and territory Governments remain responsible for quality
and safeguarding arrangements, including registering providers. The current
situation is obviously creating disparities in processes and potentially
deterring some providers, especially sole traders or small organisations to
become NDIS providers. The committee is concerned that some small providers may
not register as NDIS providers due to current onerous processes. This may
restrict choices and availability of providers for Participants.
The committee understands that, as part of the Framework, a risk
responsive registration system for service providers will be established. One
of the responsibilities of the Independent NDIS Quality and Safeguards
Commission to be established in early 2018 will be to register NDIS providers and
oversee provider quality once at full Scheme. The committee suggests that
consideration be made to establish different levels of registration
requirements based on size of the organisations to ensure that sole providers
and small organisations have capacity and resources to go through the
registration process without excessive burdens. Meanwhile, during transition, the
committee encourages state and territory Governments to put strategies in place
to support sole traders and small organisations through the registration
process. The committee will further consider this issue in the context of its
inquiry into market readiness.
The committee recommends state and territory governments put strategies
in place to facilitate and support the registration of providers during the
Submitters raised concerns about the current NDIS price caps and argued
they do not always reflect the real cost of service delivery.
It risks the sustainability and growth of the disability sector as well as
reducing quality and availability of services for Participants.
For example, Catholic Social Services Australia reported that 'the
inadequacy of this transitional pricing methodology has been consistently
raised by the sector' and 'is threatening the viability of providers and safety
of Participants, and risking market failure for particular service types'.
Similarly, Ms Emma King, CEO of VCOSS explained:
NDIS pricing policies directly affect service quality and
coverage. Members report the prices are insufficient to recruit and retain
experienced and qualified workers and the prices do not cover the services of
quality service provision, including professional development, adequate
supervision or administration.
National Disability Services pointed out that service providers are
losing money on delivering one-to-one supports, noting that 'this situation is
not sustainable' and that 'the NDIS maximum price is significantly lower than
the comparable community aged care price'.
MJD Foundation (MJDF) argued that 'the NDIS unit pricing for the
supports that the MJDF expects to deliver under the NDIS are significantly
lower than MJDF's unit costs'.
The Australian Services Union is concerned that the 'NDIS pricing
assumptions do not meet the minimum Award conditions, nor do they reflect the
reality of disability support work' and 'this will only exacerbate the
workforce shortages in the sector, and mean less quality and continuity in
support for people with disability'.
Mr Robbi Williams, CEO of JFA Purple Orange, raised concerns about fixed
pricing and impacts on quality and differentiation of services:
I'm concerned that, in the implementation of the Scheme, this
focus on fixed price for services is causing enormous problems for service providers
who want to differentiate on quality elements but cannot afford to do so with
the fixed price.
Inadequate pricing for psychosocial
Some submitters are concerned about the inadequate pricing for
psychosocial supports, which is impeding on quality of services.
Mental Illness Fellowship of Australia noted:
Since rollout commenced, mental health providers have
repeatedly highlighted that the price of supports is set well below the hourly
rate for psychosocial support work currently delivered by suitably qualified
people. There is no hourly price for psychosocial support services in the NDIS
Price Guide, and mental health providers have had no involvement in the process
to set prices for different support types.
At a public hearing in Hobart, Ms Elinor Heard, Sector Reform Lead at
Mental Health Council of Tasmania, recommended that prices for psychosocial
supports be aligned with the award rate of pay for qualified staff:
We recommend that the NDIS pricing structure be adjusted to
address the well-documented disconnect between line item unit pricing and the
award rate of pay for qualified mental health workers. At the moment we have
members operating at a 50 per cent loss per episode of care as a result of this
discrepancy. We hope that the independent pricing review will endorse action in
Similarly, Anglicare Australia reported that 'there is enough evidence
to show that the current unit pricing is insufficient to purchase services
which can meet the needs of people with higher needs and complex psychosocial
Inadequate pricing for supports for
people with complex needs
Submitters stressed that NDIS pricing is particularly inadequate for
delivering services to people with complex needs, who are likely to require
workers with more specialised skills.
ACT Minister for Disability, Children and Youth, Ms Rachel
Stephen-Smith, reported that 'from the feedback we've had from providers, there
are genuine issues with the appropriate pricing of support for people with high
and complex needs'.
Impacts on the disability sector
A risk identified by submitters is that the inadequacy of prices may
drive skilled workers to stop engaging with the NDIS. For example, the
Victorian Government pointed out that 'current pricing may incentivise existing
skilled workers to seek roles in other sectors (for example the aged care
At a public hearing in Melbourne, Ms Kym Peake, Secretary of the
Department of Health and Human Services, Victorian Government reinforced the
view that adequate pricing is needed to grow the workforce:
[...] Certainly, our stakeholders raise with us that current
price setting do not take into account the real cost of service delivery.
Pricing will also be fundamental to growing a skilled workforce, and it must be
addressed head-on during transition so that there is an appropriate provider
market with a workforce with the right skills and competencies.
National Disability Services warned that 'without resolution of pricing
issues, the market will not grow to meet the increase in demand under the
Similarly, in its submission, the Department of Premier and Cabinet NSW
The market for the provision of supports is developing, but
this will likely be slow if there is uncertainty regarding the ability of
service providers to recover their reasonable costs.
In its NDIS Costs Study Report, the Productivity Commission noted
that the NDIA's approach to setting price caps 'has hindered market
development' and 'it has led to poor participant outcomes, especially for those
with complex needs'.
An independent body for
Overall, submitters suggested that pricing decisions should be the
responsibility of an independent price regulator, not the NDIA.
In its report, the Productivity Commission recommended that an independent body
be responsible for regulating the price of supports under the NDIS.
At a hearing in Canberra, the NDIA explained its position in relation to
the Productivity Commission findings and recommendation on an independent price
I would like to add is that the board and management did also
make a statement about the Productivity Commission report. In that statement
they also drew attention to their view that they didn't agree with one of the
recommendations in the report. That was for the independent pricing regulator
to be established. I think that the board and management would probably want it
stated that their reasons for that is that they believe that at this moment,
while we do want to get to a point of deregulation of the market altogether,
while the market is developing it's in the interests, of Participants
particularly, to have an active oversight of price caps so that Participants
aren't taken advantage of. I'm not suggesting that providers would do this;
simply that there is a risk that that may happen where the market is thin. It's
happened in other markets. There are a range of other reasons. We want to make
sure we can price accordingly to get the outcomes for Participants that we need
and that's the focus that we want to bring to pricing. We want to be
transparent in the way that we do that, but I think they believe that in terms
of their stewardship role of the agency they need to maintain some oversight of
that, particularly in relation to the impact of that on sustainability of the Scheme.
They believe that it's best left at the moment with the NDIA.
Independent Pricing Review
In June 2017, following the outcome of the FY2017-18 pricing review, the
NDIA announced an Independent Pricing Review to be undertaken by McKinsey &
Company and completed by the end of 2017.
The Review was tasked to:
Provide recommendations in relations to improved pricing
effectiveness, including but not limited to:
National versus regional pricing;
Pricing of services with different levels of complexity;
Pricing of short stay support, and for emergency and crisis
Thin and undersupplied markets, particularly in regional and
Relative provider efficiencies (including overheads);
Adequacy of provider returns; and
Effectiveness of the Hourly Return approach used to set prices.
Provide recommendations in relation to the potential early
de-regulation of price in more mature sub-markets and the glide path for the
eventual de-regulation of price more generally.
The committee noted that many service providers are of the view that the
current NDIS pricing caps have potential to negatively impact on the capacity
for providers to deliver quality services. The committee is particularly concerned
that the pricing for supports for psychosocial supports and for people with
complex needs appear to be well below industry standards.
The committee is aware that the NDIA Board is currently considering the
Final Report of the Independent Pricing Review undertaken by McKinsey &
Company with the intent being that the Report and the NDIA's response be
published by mid-March 2018.
The committee will consider the Report, issues of pricing and the establishment
of an independent price regulator in the context of its inquiry into market
Submitters raised the issue of workforce shortages.
As described by the Productivity Commission in its recent NDIS Costs Study
Report, the disability sector workforce will need to double and in some
regions triple or more over the transition period to meet demand.
Allied Health Professions Australia is of the view that it will not be
possible to increase the NDIS workforce without changes that address 'workforce
planning, education and training issues'.
In its submission, the Queensland Government considered that the
workforce constitutes 'one of the biggest risks of the rollout of the NDIS'.
The Australian Services Union identified the need for developing a
There is presently no comprehensive plan that deals with
careers or training for disability support workers under the NDIS. This, along
with pricing that supports decent pay and conditions, is essential to
attracting and retaining a stable and skilled disability support workforce.
Community Mental Health Australia identified a 'need to develop a
National Mental Health Workforce Strategy and conduct regional Communities of
Practice to support NDIS transition'.
National Disability Services stated that 'a clear and coherent national
industry plan is required to support the sector's development and transition to
the NDIS market'.
In its submission, the ANAO reiterated the findings it made in its performance
audit report No. 24 of 2016–17, National Disability Insurance Scheme–Management
of Transition of the Disability Services Market:
The magnitude of the growth and change required to the
disability services market cannot be underestimated, and the transition to full
Scheme elevates an already high risk environment. This requires ongoing
monitoring and active management. Within this context, both DSS and the NDIA
need to invest in their capability to identify and resolve emerging market concerns
for many years to come.
Initiatives to build the NDIS
In April 2015, the Disability Reform Council agreed the NDIS Integrated
Market, Sector and Workforce Strategy in preparation for the full roll out of
the NDIS. The strategy was developed by the Commonwealth, state and territory governments
and the NDIA to provide a clear plan to align market, sector and workforce
In its submission, the Department of Social Services explained 'it has
been working with state governments, the NDIA, and the sector, to support
disability workforce development' and that 'the Boosting the Local Care
Workforce 2017–18 budget measures will invest $33 million over three years, to
boost local job opportunities in care work, particularly in rural, regional and
outer suburban areas'.
Allied Health Professions Australia noted that 'initiatives such as the
Sector Development Fund (SDF) and Innovative Workforce Fund (IWF), which allow
individuals and organisations to apply for grants to support the development of
the disability workforce, are valuable ways to ensure a ready and appropriately
The Victorian Government has developed a plan to build the disability
workforce, recognising that the NDIS is bringing major changes and that the
Victorian disability workforce will need to grow by approximately 76 per cent
over the next three years. As part of the plan, $26 million will be invested in
workforce development, training and skills initiative.
Queensland has invested $2.8 million to establish WorkAbility to drive
the expansion and diversification of the Queensland workforce over the
transition period, by engaging, attracting and connecting people to jobs in the
In its submission, the Australian Government Department of Education and
Training listed its recent initiatives to address workforce shortages. This
included providing funding for the Disability Workforce Innovation Network
Innovative Project (DWIN). Through the DWIN, Workforce Advisers worked to
develop workforce action plans in each state and territory; identify workforce
planning needs and collect workforce data to identify gaps and inconsistencies.
A workforce planning and profiling tool was developed to assist provider
identify workforce needs and is now available on the National Disability
The Productivity Commission made the following recommendation in regard
to roles and responsibilities of different parties to develop the disability
The roles and responsibilities of
different parties to develop the National Disability Insurance Scheme (NDIS)
workforce should be clarified and made public by the beginning of 2018.
State and Territory Governments
should rely on their previous experience in administering disability care and
support services to play a greater role in identifying workforce gaps and
remedies tailored to their jurisdiction.
The Australian Government should
retain oversight of workforce development, including how tertiary education and
aged care policy interact and affect the development of the workforce.
The National Disability Insurance
Agency should provide State and Territory Governments with data and analyses
held by the Agency to enable those jurisdictions to make effective workforce
Providers of disability supports
should have access to a clear and consistent mechanism to alert the National
Disability Insurance Agency, the NDIS Quality and Safeguards Commission, and
the Australian, State and Territory Governments about emerging and persistent
Growing the disability care workforce to meet the needs of NDIS
Participants is a significant challenge, which has been identified by all
stakeholders. In its Study Report, the Productivity Commission found that 'the
disability care workforce will not be sufficient to deliver the supports
expected to be allocated by NDIA by 2020'.
The committee notes the different initiatives undertaken by the
Australian and state governments to address workforce development issues.
However, it appears that, at present, the roles and responsibilities of the
Australian, state and territory governments and the NDIA are not clearly
defined. The committee agrees with the Productivity Commission's recommendation
that the roles and responsibilities of different parties to develop the NDIS
workforce should be clarified and made public by the beginning of 2018.
The committee received evidence that workforce remuneration, training
and professional development issues contribute to current challenges. The
committee believes these important issues warrant further work and analysis, and
will be considered within the context of the committee's inquiry into market
Rollout of the ILC
As described by the NDIA in its submission, the Information, Linkages
and Capacity Building (ILC) Program is designed to provide people with disability
— both inside and outside of the NDIS — with access to appropriate services.
The NDIA further explained the focus of ILC:
The focus of ILC is community inclusion - that is, making
sure that people with disability are connected to their communities and to
appropriate disability, community and mainstream supports. This makes ILC a
critical feature of the insurance approach, given its potential to have a
significant impact on managing and reducing NDIS costs over time.
In November 2016, after extensive consultation with people with
disability, families and carers, as well as organisations working in the
sector, the NDIA released the ILC Commissioning Framework, which identifies the
priority focus areas for ILC investments.
The ILC Policy Framework identified five activity streams for ILC:
Information, Linkages and Referrals
Capacity Building for Mainstream Services
Community awareness and capacity building
Individual capacity building; and
Local Area Coordination (which will also deliver the other streams).
At present, the NDIA is assuming responsibility for funding ILC in each
jurisdiction. The ACT was the first jurisdiction to commence ILC in 2017-18,
with NSW and SA commencing in 2018-19; and Victoria, Queensland, Tasmania and
NT commencing in 2019-20.
To ensure an orderly transition of ILC-type activities funded by state
and territory governments to those funded by the NDIA through ILC, Transition
Plans have been agreed with each jurisdiction. The Transition Plans outline
agreed actions to mitigate risks and to prepare organisations for ILC
The Transition Plans also include funding for jurisdictions to enhance
or expand successful ILC type programs into other areas and to support current
organisations to get ready for outcomes-based funding and ILC grant-based
In its submission, the NDIA pointed out that 'the effectiveness of ILC
funding as an innovative means to increase inclusion of people with disability
in the community is constrained. This is because during the transition years
ILC funding is being provided to jurisdictions to fund legacy programs to
ensure continuity of delivery. As a result, the full innovative benefits of
having a nationally consistent approach to investing in ILC activities are
likely to be delayed'.
Given that the ILC is still in infancy, Carers NSW felt it did not have
enough information to fully comment on the rollout of the ILC.
However, some submitters raised concerns about current level of funding; the
funding approach of ILC activities; the capacity of LACs to perform their role;
scope of ILC activities and capacity of ILC to deliver services to people
ineligible to the NDIS.
Many submitters are concerned that insufficient funding has been
allocated to the ILC Program during the transition period.
For example, Catholic Social Services Australia stated:
The Information, Linkages and Capacity building (ILC) program
is a fundamental component of the Scheme, however there is inadequate funding
for this program, particularly in the transitional years. Funding for ILC
should be increased, recognising these services provide crucial support and
connections especially for Participants not eligible for NDIS individualised
packages, and so promote the overall sustainability of the Scheme.
Submitters supported the recommendation of the Productivity Commission
to increase funding for ILC to the full Scheme amount of $131 million for each
year during the transition. 
VCOSS pointed out that the former chair of the NDIA board had stated 'currently
only $132 million (excluding LAC support) has been has been allocated to the
ILC. This is not sufficient and means that one of the key foundations on which
the NDIS is being built is weak.'
In its response to the Productivity Commission Cost Review Position
Paper, the NDIA welcomed the draft recommendation that the ILC budget be
increased to its full Scheme (2019–20) allocation immediately. However, the
NDIA pointed out that there is no capacity for this to come from its operating
At present, ILC activities are being funded through grants to organisations.
Some inquiry Participants raised concerns about the current competitive grant
model used for ILC commissioning.
For example, the Victorian Government said:
The Victorian Government has concerns regarding the proposed
grants model for commissioning and seeks clarity from the NDIA on the length of
time grants will be allocated. To effectively build capacity in the community
and mainstream services the NDIA will require a longer term view, with
coordinated planning to ensure long term outcomes are realised. Careful
consideration should be given to the efficacy of one-off grants or small
amounts of funding for local information, peer support and capacity building
The ACT Government reported that 'many providers expressed concerns
regarding the bureaucratic impost of the ILC grant program, including the
onerous administrative burden, the process delays and allocation of only one
year agreements to successful providers'.
Mental Illness Fellowship of Australia argued that 'the short funding
period and small amounts available disincentive tendering'.
VCOSS is of the view that year-to-year funding is not suitable for many
existing ILC-types services and recommended that funding for ILC projects be
greater than twelve months in duration.
Autism Spectrum Australia made a similar recommendation.
VCOSS is also concerned that 'grant-based projects may have limited
geographic coverage, introducing uncertainty about equitable coverage within
and between states and territories'.
It also pointed out that 'it is unclear whether ILC funding will be equitable
for people with different disability types and from different population
Direct investment outside grant
National Disability Services (NDS) argued that 'there is no need to have
a competitive grants round for activities that are essential and are being
provided by organisations that are performing well, have strong track-records
and have the confidence of funding departments'. NDS believes 'this type of
organisation should receive funding outside the competitive grants process'.
Similarly, JFA Purple Orange recommended that ILC activities are not
solely funded through competitive grants but also 'include direct investment in
existing community agencies delivering effective ILC services'.
Some submitters argued that ILC should provide block funding for certain
services and activities, including outreach.
For example, Mental Health Australia recommended that ILC provide block funding
for specialist assertive outreach for people with psychosocial disability.
Local Area Coordinators
Through the Partners in the Community Program, Local Area Coordinators
(LACs) perform three key roles:
Link people to the NDIS;
Link people to information and support in the community; and
Work with local community to make sure it is more welcoming and
inclusive for people with disability.
In relation to linking people to the NDIS, LACs are tasked with helping people
from understanding and requesting access, to developing and implementing their
first NDIS Plan. LACs can also help with preparing for a plan review. However,
LACs do not provide case management, act as an advocate for the person with
disability, and they cannot approve an NDIS plan.
The Royal Institute for Deaf and Blind Children observed that 'the
majority of LAC time is spent on planning and that they do not have the
capacity to support plan implementation and connection to community and/or
Similarly, the Victorian Government reported that 'there are widely
acknowledged concerns that LACs do not have sufficient time and capabilities to
perform their role' and that 'a disproportionate focus by LACs on planning will
come at the expense of building community infrastructure and mainstream
Ms Carly Nowell, Policy Adviser at VCOSS pointed out that LACs currently
do not have capacity to undertake outreach work:
[...] the local area coordinators, as we know, are currently
under the pump trying to work through the planning process. Whilst in theory
they have some capacity to do some of that outreach and to engage and do the
pre-engagement support, at the moment we're hearing that they're not.
Mental Health Australia highlighted the importance of assertive outreach
for people with psychosocial disability and is of the view that 'this is an
area where generalist LACs currently simply do not have the right skills and
The Physical Disability Council of NSW shared similar concerns and stressed
that if LACs do not have the resources and capabilities for proactive outreach,
some people will miss out on vital services.
In its submission, the Queensland Government reported that, despite the
terms of Queensland’s bilateral agreement requiring NDIS LACs to commence in
locations six months prior to transition, this has not occurred in the
transition areas in Queensland. It noted that, 'as a result, Participants have
not been well prepared during their pre-planning, and a significant lag in new Participants
entering the Scheme has been experienced'.
Gaps in services
Many inquiry participants expressed the view that ILC is not ensuring
support for individuals not eligible for the NDIS or people at risk of falling
through the disability gaps.
For example, the Australian Blindness Forum stated:
The ILC program as it currently stands is not going to
provide any useful ongoing services and it will not help ensure individuals do
not fall through the cracks.
At a public hearing in Canberra, Ms Jennifer Grimwade, Executive Officer
at the Australian Blindness Forum, further explained:
The original proposal was that the ILC would reflect programs
such as the block funding and early intervention programs, and the goal of this
was to continue to provide disability services to those who were not eligible
for the NDIS. But this is not how it has turned out. We don't think it is going
to provide any useful ongoing services for people who are blind or vision
impaired, and we think those people who are not eligible will fall through the
Mental Health Council of Tasmania is of the view that 'it is unclear how
the ILC will cover gaps, which are emerging as the NDIS is implemented'.
Can:Do Group observed that the ILC is not covering services, which were
Services such as our community Auslan interpreting services,
provide vital community wide support but the current ILC framework does not
support the successful tendering for the delivery of such services, nor does it
acknowledge their importance to the community.
The committee agrees with submitters and the Productivity Commission
that, given the broad scope of the ILC Program and its important role during
the transition period in ensuring that people with disability are adequately
connected with appropriate services, funding for ILC should immediately be
increased to the full Scheme amount of $131 million for each year during the
The committee recommends the Australian Government increase funding for
ILC to the full Scheme amount of $131 million for each year during the
The committee is concerned that the current grant funding approach for
ILC activities may result in service gaps for some essential services and has
potential to disadvantage some cohorts because of their type of disability or
their geographical location. Grants are currently awarded for up to two years.
The committee acknowledges this may restrict the capacity of some organisations
to deliver ongoing services and could lead to some individuals missing out on
services because of potential changes of programs and service providers every
couple of years.
The committee believes that an evidence base needs to be built and used
to inform future decisions on appropriate funding models for ILC activities. The
committee understands that, as part of the ILC program, the NDIA and the
organisations that receive grants are required to collect data on ILC
activities. The committee recommends that the NDIA uses this data to monitor
the effectiveness of the current ILC grant funding model, with the view of
introducing other types of funding, including block funding if required, to
ensure appropriate and quality services are delivered across all jurisdictions.
The committee recommends the NDIA monitor the effectiveness of the
current ILC grant funding model, with the view of introducing other types of
funding, including block funding if required, to ensure appropriate and quality
services are delivered across all jurisdictions.
Local Area Coordinators
The committee is of the view that, because of the need to meet bilateral
estimates, LACs have been focusing too much on planning-related activities. As
a result, LACs have not been able to perform their other key roles. It is also
resulting in emerging gaps in service delivery. The committee believes that increasing
funding for ILC to the full Scheme amount for each year during the transition
will assist in addressing some of the gaps and enable LACs to perform their
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