Concerns for Support Coordination after NDIS review announcements.

Undoubtedly, the current iteration of the NDIS has become problematic in some dimension for nearly everyone who intersects with it. The mechanics of maintaining sustainability in the context of an uncapped scheme predicated on reasonable and necessary supports was always going to be complex. However, the proposed changes recently announced by the independent review attempt to address the complexity with blunt tools that may worsen the experience of many scheme users.

Before we get into it, we want to clarify that our perspective is based on 2nd and 3rd order consequences of altering funding mechanisms. We believe that the independent review has good intentions. We’ve met with them, and they understand the scheme thoroughly. We also think their job is extremely difficult, if not impossible, and the public has demanded that they do something. Our perspective is that this “something” will generate perverse outcomes.

Unfortunately, some of the proposed changes to the scheme are akin to burying one’s head in the sand. The participant's requirements are escalating beyond our expectations? Easy, let’s give them a budget without contemplating their required support. Too many children on the scheme? Easy, let’s revert to a state-based block funding model that doesn’t acknowledge individual needs. Is capacity building complicated to quantify? Easy, reasonable and necessary only means accessing the community now.

While the independent review had a fundamentally impossible responsibility, reducing the amount of information or market participation in the scheme in the name of “reducing stress” will likely be the most stress-inducing decision imaginable. Fundamentally, you do not get a more accurate understanding of individuals' needs by reducing the inputs and participants' capacity to detail their experience.

Planning after budgeting

Purported as a mechanism to “reduce stress, " several serious concerns exist with this approach. Firstly, anyone involved with a SIL roster of care understands that the purpose of that arduous process is to derive the exact amount necessary to support the participant adequately. The process is designed this way because of the inaccuracies associated with prior iterations of the SIL funding process. Assuming a normal distribution of packages (which we have typically seen), 50% of participants will be forced to trade off other supports for adequate SIL funding because the “stress” of understanding the quantum of support required was deemed unnecessary. We believe that a lackadaisical approach such as this will result in far greater long-term stress for participants and providers. Consider that participants who receive immutable and arbitrary packages will approach providers, many of whom will be refused precisely because limited thought went into establishing their funding. We’re yet to see a response from the QSC absolving providers of their responsibilities to manage risk, given that the funding decision occurs before understanding what supports are required. One would imagine that regulators would respond that you shouldn't have provided the support if you thought the package was unsafe. This is an exceptionally cruel way to reduce utilisation in SIL and the number of SIL participants. It will also raise the level of risk in SIL tremendously.

Support Coordination

Where plans are determined without reference to the support provided, participants will be forced to make trade-offs they’ve never made before. Rather than acknowledging that a participant requires a specific quantum of SIL and a corresponding amount of support coordination, participants will be assigned a reference range and then required to squeeze their support within this. One would expect when faced with the prospect of having somewhere to live or having support coordination. Many participants will choose the former simply because they have no frame of reference when evaluating the benefits of support coordination. For example, we expect that participants experiencing the benefits of support coordination will have much more difficulty finding SIL placements because the residual of the package is not designed in reference to the actual support required. It is hard to imagine a single intervention that could invite more risk for participants, providers and coordinators.

A focus on undertaking daily activities.

While we agree that the current lens for determining the level of support is skewed, it is important to categorically reject perspectives that reduce the amount of information utilised in the planning decision. Reasonable and necessary support should focus on community participation and functional capacity precisely because capacity building is an important scheme component. The trajectory of capacity is crucial to the planning process because it informs the reasonable and necessary amount of capacity-building support required to give an individual the best trajectory possible. A myopic focus on daily activities is antithetical to an insurance approach and will have disastrous consequences for the scheme and the public. The evidence for this is plain in the NDIS data; you’ll find a -.4 correlation between under-utilised capacity-building markets and the size of the scheme a decade later. Put another way, the less capacity building, the more scheme growth. This should be unsurprising to most readers and likely the NDIA itself.

Who is getting unreasonable support?

There has been much talk about individuals receiving unnecessary support and too many children in the scheme. While this is easy to say in a broad stroke, who exactly are these people receiving unnecessary support? What is the quantum of support currently considered “unnecessary”? Would the parents of these children agree?

A war against individualised supports.

A quick observation about the NDIS is that plans have been produced with an exact service pattern in mind. This means that most children currently in the scheme have received a (somewhat) informed perspective from a planner about the level of support necessary to assist them in their developmental journey. In the case of mainstream therapies, the quantum of support accessed is quantified in hours of support. It is outrageously irresponsible to conclude that rather than give children a quantified level of support in hours; state governments should allocate an utterly arbitrary level of support. While this may be necessary for scheme sustainability, it is reckless to conclude that this can result in outcomes that are beneficial for the participant. Indeed, the entire point of the scheme was to move away from block funding that could not respond to participants' needs and preferences. It appears as soon as the needs and preferences of participants were expressed, there was a decision to eliminate it. Indeed, it seems impossible to reconcile this perspective with the fundamental human rights of people with disability.

Our call to support coordinators.

We’ve seen a lot of excellent outcomes in the NDIS, and we’ve also seen some of the darkest recesses of the scheme. Often, behind a great outcome is a support coordinator with the knowledge to arrange a type and pattern of support that would otherwise never have occurred. When we’ve seen participants escape dire circumstances, it was often because a support coordinator refused to stop advocating for the participant precisely when everyone else had moved on. We are gravely concerned that this essential function will be squeezed out of plans once participants are forced to make trade-offs due to plans arbitrarily constructed from reference ranges.