Have your say on OTA’s submission to NDIS Review’s Interim Report

On 30 June the NDIS Independent Review released its Interim Report, titled “What we have heard”. This paper summarised what they have heard to date, focusing on some key areas.  It’s pleasing they seem to have picked up on OTA’s commentary on a range of matters including:  

• The need for additional services and supports outside of NDIS (i.e. tier 2)  

• The need for improved decision making and support during the access and planning stages so people receive adequate support, and participants receive appropriate and equitable decisions about their supports  

• Issues with accessing supports and services especially in areas with thin markets 

• Issues with the current pricing model, which is affecting sustainability, and ability for providers to innovate 

• The need for better guidance from NDIA on what is ‘reasonable and necessary’.  

• Issues with current approach to regulation which is more about ‘ticking boxes’ than achieving quality services.  

The interim report has identified 10 key areas they want to explore further:  

• Apply for and getting a plan  

• Joined up disability services  

• Defining Reasonable and Necessary  

• Early Childhood supports  

• Improving the support and service marketplace  

• Measuring outcomes and performance  

• Achieving long term outcomes  

• Help accessing supports  

• Supported living and Housing  

• Participant Safeguards  

OTA has provided feedback on many of these topics in four previous submissions, which have covered the overall NDIS scheme, NDIA and its staff, systems and processes, the NDIS workforce,  NDIS Quality and Safeguarding Framework, Participant Safeguarding, and NDIS pricing. Read OTA’s previous submissions here. 

Thank you to the members who have already contributed their feedback to us in our December 2022 Member survey, and in the past few months, through member emails, and the OTA’s NDIS National Reference Group. 

Seeking your feedback 

OTA is seeking members’ feedback on some further key areas where we know that the occupational therapy perspective is vital to consider to ensure that improvements are best practice, are made in the interests of participants, and are workable long term for clinicians.  

We know it is a varied and long list of issues that have been identified by the Review, and we have aimed to reduce our questions and focus to key areas. Feedback is welcome on one, a few, or all of these points. The key questions are italicised.

Please provide this by COB Friday 11 August, to policy@otaus.com.au.  

Supports outside the NDIS 

The NDIS was designed to support people with disability through a range of tiered supports including: 

• Tier 3, or individual support packages for people who meet the NDIS criteria, and receive individualised packages. 

• Tier 2 services for people who don’t qualify for an NDIS package, that are block funded, and can receive capacity building supports  (also called Information, Linkages and Capacity Building). 

We know that tier 2 services have not been set up to meet the current demand (especially in early childhood and psychosocial disability space) but pleasingly the Review team has identified this gap and said they want to look at it in more detail. 

• Where are the gaps you see in your clinical practice for people with disability who fall outside the NDIS? 

• Who should provide these service/supports?  

Defining 'reasonable and necessary' 

OTA has advocated for improvements to NDIA’s processes and additional training for NDIA staff and delegates, and guidance for participants, about what 'reasonable and necessary' means – to improve consistency in decision making and reduce issues for OTA members where they have clinical recommendations refused or disregarded, or encounter issues with participants requesting certain services but these cannot be supported under the ‘reasonable and necessary’ definition.   

We are after ideas and suggestions for what will make your clinical practice easier in this area. 

• How can 'reasonable and necessary' be more clearly defined so that there is a shared understanding between providers, participants and the NDIS/its delegates

• What tools and information would help your clients (and you) to understand how ‘reasonable and necessary’ applies to you? 

Early childhood supports 

• How can early childhood support delivery follow best practice and lead to better outcomes for children? 

• In what settings should early childhood supports be provided, and who else needs to involved (in addition to OTs)? 

• What supports or services do children’s families need to navigate the scheme and support their child’s development? 

Measuring and communicating outcomes and performance  

• How could the NDIA better track the achievement of participant’s goals/outcomes? 

•  How could NDIA and government measure the impact and benefits of the NDIS for the broader Australian community and the economy 

•  How can the NDIS ensure providers are utilising evidence based best practice, and how can NDIA drive these improvements across the sector? 

Community connectedness 

• What can the NDIS do better to help participants form community connections, and gain employment? 

• What can the NDIS do better to bridge the connection between scheme supports, and mainstream education systems? 

Home and Living 

• What improvements need to be made to ensure NDIA makes better decisions about home and living supports, that align with participants needs and preferences? 

The value of OTs under the scheme 

We are looking for examples and case studies to demonstrate the varied ways that OTs deliver value for money and effective services under the NDIS. We know that OTs do this in a myriad of ways and that this can look very different depending on the client, their capacity, needs and goals, and the amount of OT support they can access via the NDIS.   

• Do you have an example of a specific intervention or support you provided that increased client independence, and reduced their need for NDIS service in the longer term? We are looking for deidentified examples that describe the interventions you provided, and the support or services that the participant no longer required as a result. 

The Review is seeking feedback by 25 August via a survey, or individual submissions.  

Read more about the interim report here, and how to make your own submission here.