8.1
During the course of the inquiry, the committee turned its mind not just to the issues raised in evidence and how these should be addressed, but also to other, broader solutions to many of the problems facing the NDIS. These included:
How good policy is created and implemented, in particular the consultation and co-design process;
How functional assessments are carried out in other jurisdictions and in other government programs; and
Whether independent assessments should be carried out in their proposed form, and what alternative methods are available that would achieve similar results.
8.2
This chapter presents some of the committee's preliminary research and findings in each of these three areas to help inform the next steps forward. This discussion is by no means exhaustive, but the committee considers that the issues canvassed below should be taken into account before the Government considers future models to address the challenges facing the scheme. The committee's recommendations are set out in Chapter 9 of this report.
8.3
The chapter also outlines what other measures the Minister and the NDIA, in responses to questions on notice, stated the Government had considered implementing in addition to independent assessments to respond to current challenges (as outlined in Chapter 4).
Concerns about the policy process
8.4
While it is not unusual for there to be some opposition to policy reforms from affected individuals or interested stakeholders, evidence to the inquiry suggested there was widespread opposition to independent assessments in their proposed form. This opposition was almost universal in evidence from state and territory governments, academics and universities, allied health professionals, allied health peak bodies, disability providers, advocacy groups and people with lived experience and their families.
8.5
Some of this evidence flagged concerns about the policy development process that had been carried out for independent assessments. For example, Mr Jeff Smart, a former senior Commonwealth public servant who was an NDIS participant, told the committee at the 20 May 2021 hearing in Canberra that:
To be an example of evidence based policy, there needs to be both evidence collecting and evaluation before making announcements. It made me wonder what the purpose of the trial was.
8.6
Other concerns included whether independent assessments would solve the problems that they were intended to solve without giving rise to new problems. For example, AMIDA argued that 'it is poor government policy to correct identified problem areas without ensuring other issues of inconsistency and inequity do not arise from the implementation of new proposals'. Similarly, Professor Kylie Burns from Griffith University suggested that 'we can take the NDIA at its word, that there are many legitimate reasons' for why it proposed introducing independent assessments, but:
…we're very concerned that we have the selection of a solution—that is, independent assessments—for a problem that is, potentially, very complex. If there is to be a discussion about sustainability and costs, as researchers we would say let us understand what that problem is and then work towards finding out what the solutions are… There are multiple issues involved, but we would say that if cost of the scheme is one of those main issues, we need to understand, fully, the drivers of cost. I think it's fairly clear that independent assessments could not be the solution to cost pressures across the board.
8.7
The failures identified in the policy development process for independent assessments were seen to undermine trust in the process and the overall proposals. As described by the NDIS Independent Advisory Council (Advisory Council), in advice provided to the Board of the NDIA in July 2021:
Major concerns expressed by representatives of the disability community include the contested views of the purpose of the reforms, the experience of participants, and the community’s expectations of co-design and partnership.
The contested view of the purpose of the reforms heightens distrust.
8.8
Similarly, several members of the Centre for Disability Research and Policy (which provided evidence to the inquiry) and the Centre for Disability Studies at the University of Sydney, who co-authored the data evaluation report of the second trial, noted in an article that:
There is a severe lack of trust in the people who matter in government policy making and a disbelief that they are genuinely interested in the experiences and views of people with disability and their supporters.
8.9
The Advisory Council devoted a full section of its report to trust and how the Government could rebuild it with the disability sector.
8.10
Opinion and evidence reviewed by the committee varied in relation to what steps an appropriate policy process should involve, and in what order. However, the committee has significant concerns about the policy process undertaken for the proposed introduction of independent assessments. These views are outlined further in Chapter 9. Below, the committee examines what the evidence and research say about consultation and co-design, two of the key features that the committee considers should have been prioritised in the NDIA's policy development process for independent assessments.
Consultation and co-design
8.11
Underpinning concerns about the policy development process for independent assessments was a significant volume of evidence to the inquiry which questioned how people with disability had been involved in both co-design and the consultation process for independent assessments. For example, Ms Jane Wardlaw, a disability advocate and person with disability, outlined her concerns about consultation on independent assessments at the hearing in Hobart:
The lack of a co-design and consultation process concerns me… I feel that we have been spoken to, we've been spoken about, and I feel that we've just been tokenistically consulted. We're a smart group of people. Our lived experience matters… I feel that, if we had been meaningfully included from the outset, we would be able to build the NDIS in the way that was proposed in the early days…
I feel that we've been totally disregarded when it comes to meaningful consultation…Now there's just no interaction whatsoever. I feel that the consultation process around independent assessments this time was deplorable. It was all written up on their very clunky website… I tried to write a formal submission to the NDIA, but it was just too overwhelming…
I would suggest the CEO leave his office and come and sit in our community and listen to us…
Today's really the first opportunity where I've felt that I'm being listened to, where I might have some influence in putting a halt to this exercise.
8.12
Vision Australia argued that the timing of consultation suggested that the Government was not interested in genuine co-design with people with disability and the sector:
Although people with disability and the organisations that represent them have had opportunities to contribute to submissions since the reforms were announced, they have not been afforded opportunities to contribute to design of the proposed model. Reforms to the scheme of this scope and magnitude should be based on a clear commitment to co-design, involving people with disability, their families, service providers and representative bodies. The engagement that has occurred might also be considered somewhat superficial, given that contracted independent assessment providers were announced in the same week that submissions responding to the NDIA’s independent assessment consultation paper closed. This indicated a clear intention to plough ahead with the proposed model, in spite of the significant concerns raised by participants and the disability sector more broadly.
8.13
Ms Pieta Shakes, a mental health clinician and carer of a person with disability, pointed to the perception from the sector that they had not been consulted adequately or involved in co-design, arguing that:
...the ongoing responses from many disability organisations, including the joint statement with 25 signatory organisations, highlight that the disability community has not been afforded choice, empowerment or flexibility in relation to the introduction of the independent assessments. If the implementation of significant changes within the NDIS do not even adopt a co-design process or recommended consultation process (as per the Tune Review), then it cannot be a change that empowers.
8.14
Associate Professor Kylie Burns from the Law Futures Centre and Hopkins centre at Griffith University expressed concern that the 400 disability profiles, as outlined in the NDIA's Personalised Budgets paper, had involved no co-design:
Our understanding, from reading the information paper, is that the NDIA has internally developed the profiles or boxes. So, obviously, in terms of the process of co-design with people with disability and their organisations, we would have said the peak organisations for allied health, for example, who have expertise in that area, would have been essential to develop any such thing, if you were to assume that that was even an acceptable process.
8.15
The committee notes that, like independent assessments, the Government has stated that it will not be proceeding with the personalised budgets model as outlined in the Personalised Budgets paper.
8.16
Ms Clare Gibellini, the mother of a participant, told the committee that she had taken part in the NDIA's consultation process but 'found the process to be superficial at best and traumatising at worst'. She called for the NDIA to 'work alongside us to develop this scheme'.
8.17
Submitters also raised significant concerns about the appropriateness and effectiveness of the consultation undertaken for Aboriginal and Torres Strait Islander communities. For example, the South Australian West Coast ACCHO Network argued that the process went ‘directly against how engagement should be done the “proper way”’ and did not align with either the NDIA’s own Aboriginal and Torres Strait Islander Engagement Strategy, nor the new National Agreement on Closing the Gap, ‘which highlights the commitment and importance of transparency and shared decision making’.
Principles of co-design
8.18
After reflecting upon this evidence, the committee also reviewed the basic principles of co-design. Co-design has increasingly been used in Australian policy development in recent years. It has been promoted as 'a promising approach to improve public policies and government services' that features 'the active involvement of a diverse range of participants in exploring, developing and testing responses to shared challenges'.
8.19
The Australian Centre for Social Innovation has noted that the term 'co-design'—broadly, not just in the context of policy-development—'has become almost interchangeable with "consultation"'. However, the Australian Centre for Social Innovation argued that co-design is actually about bringing together people with lived experience and 'professionals to jointly make decisions, informed by each others' expertise'.
8.20
Similarly, the WA Council of Social Services, in a toolkit especially designed to guide governments intending to use co-design, described co-design as being about:
…designing and delivering community services in a partnership—an equal and reciprocal relationship—between funders, service providers and the people using services (and often their carers, families and others in their community)… The evidence is strong about Co-Design being an effective means of ensuring the best outcomes, but for this to hold true we need to be confident that we are genuinely engaging in processes that embody the principles and behaviours that have been shown to work.
8.21
The WA Council of Social Services further outlined what it considered to be the key principles of co-design for governments, including:
Design with people, not just for them, with inclusion being at the outset, not later when decisions have been made;
There should be an effective, facilitated process with freedom to speak frankly, which requires a relationship based on trust, respect, openness and transparency;
Co-design processes should commence with the sharing of existing data on community need, population and cohort dynamics, and service evaluations, with agreement reached on service goals and outcomes before moving to design;
The process should involve design, planning and evaluation, as well as, in some cases, implementation or delivery; and
Co-design is an iterative process that develops over time, with participants being able to explore, make mistakes, learn from these and use the process to progressively design better services.
The NDIA's position on co-design
8.22
The committee is aware that the NDIA released a Co-Design Framework paper in 2015. This paper appears to be no longer publicly available. However, the NDIA's Corporate Plan for 2015–19 set out the following eight principles to guide its approach to co-design:
Create a shared understanding of the intent, objectives and goals of the co-design activity;
Take a holistic, user-centred approach, that is based on story-telling to help to illustrate the context;
Follow a structured yet flexible process;
Ensure there is representation of diverse stakeholder groups;
Make it inclusive, taking into account the physical and emotional environment and ensuring co-design methods are accessible to enable meaningful participation;
Manage expectations and clearly communicate constraints, allowing stakeholders to understand why some ideas are not possible; and
Close the loop through clear and timely follow up engagement; and share data, findings and next steps for the project.
8.23
At the time of drafting this report, the 2015–2019 Corporate Plan had been superseded by three subsequent corporate plans, none of which had used the term 'co-design'.
8.24
In a speech on 23 July 2021, the CEO of the NDIA, Mr Martin Hoffman, stated that Commonwealth, state and territory Disability Ministers:
…have made a commitment to work in partnership with people with lived experience of disability through the Independent Advisory Council and disability representatives on the co-design of a new person-centred model.
8.25
Mr Hoffman further revealed that the NDIA was essentially 'co-designing what co-design will look like' by 'progressing work on a framework for consultation and engagement that will see us have more robust co-design principles in place with sector organisations…[and] direct engagement with the community'.
8.26
At an estimates hearing on 3 September 2021, Mr Hoffman provided further details on the NDIA's proposed co-design consultation process, flagging 'the creation of a compact… between the agency and the sector generally in terms of the way we all work together on co-design'.
Functional assessments in other contexts
8.27
The committee examined how similar policies in other jurisdictions have been implemented and the impacts of these policies. The committee also considered examples of functional assessments conducted in the context of the provision of government services in other jurisdictions. Most submitters and witnesses outlined the negative impacts of particular assessment programs; however, some pointed to examples that they suggested could be adapted and used by the NDIA.
What the evidence suggested did not work
8.28
Evidence indicated that Personal Independence Payments (PIP) in the UK, for people with long-term physical or mental health conditions or disability, had resulted in adverse 'mental health outcomes associated with stringent functional assessments, including increased suicide risk'. Further, the PIP 'has cost the government considerably more than anticipated'. Other evidence discussed Work Capability Assessments in the UK, highlighting research that concluded these were associated with an increase in suicide, mental health problems and increased prescribing of antidepressants.
8.29
The New South Wales Government used support needs assessments for all residents of state-operated group homes, before the introduction of the NDIS, to form the basis for building a budget. The New South Wales Government stated in its submission that:
'The process was not effective at predicting costs at an individual service unit level, let alone an individual client level'; and
'Reassessment of individuals was common and, most importantly, budget adjustments were made at the service unit level to meet the needs of individual clients'
8.30
Other examples provided to the committee of negative impacts arising from independent assessments used in public programs included the following:
Administrative Appeals Tribunal appeals;
Applications for Disability Support Pensions;
Centrelink Job Capacity Assessments;
icare: Insurance and Care NSW
8.31
The Centre for Disability Research and Policy at the University of Sydney highlighted the importance of recognising 'the historical, perverse and very negative impact of eligibility assessments of services for people with disabilities', such as the 'historical use of IQ assessments to allow/deny a child's access to educational opportunities'. It further flagged the ‘Clinical Evaluation of Language Functioning’ assessment which it suggested 'misses kids who could really benefit from support' from speech pathology services. The Centre argued that:
Without a strong evaluation, auditing and feedback process, in which the NDIA genuinely listens to and adapts the scheme in relation to the implementation, experiences and concerns of the sector (rather than just [rejecting] criticism) then these problems may occur in relation to the NDIS.
Successful models
8.32
However, some evidence pointed to positive experiences of assessments used in government programs. The committee obtained research from the Parliamentary Library outlining the key features of medical assessments in workers' and motor vehicle compensation schemes in New Zealand, Victoria and Queensland. This research is used below to supplement the evidence that the committee received in the inquiry. The committee has considered these models as examples only, noting that modifications would be necessary to incorporate any of these models into the NDIS. This is particularly the case given the importance of goals to the NDIS, compared to the focus on injury or impairment in other compensation schemes.
Victorian Transport Accident Commission
8.33
Speech Pathology Australia suggested that the Transport Accident Commission in Victoria could be viewed:
…as an alternate assessment process as it not only aligns with the values of the International Classification of Functioning, Disability and Health (ICF), but also allows the person to work with the accredited practitioner of their choice towards improved functional outcomes. Reviews are conducted by an experienced clinical panel to ensure appropriate progress and compensation as necessary.
This would be a much more preferred method of operating for our members, who have concerns about the emotional burden on families…as well as the mental health impacts on people with disability having to tell their story to strangers, as opposed to being able to complete the assessment process with their trusted current providers, who could then be reviewed as needed by a panel.
8.34
Similarly, the Australian Rehabilitation and Assistive Technology Association also called for the NDIA to 'model their approach from other well-established existing state-based injury insurers', including the Transport Accident Commission in Victoria, arguing that:
These schemes have worked closely with scheme participants and allied health professionals, and drawn from existing evidence, to recommend a range of assessment tools that may be used to consider a person's goals and support needs; and
These agencies also allow flexibility for open-ended discussion and decision-making about which published measures are appropriate to use and which are not.
8.35
Persons injured in a transport accident who have made a claim for impairment benefits with the Transport Accident Commission because of a permanent impairment are required to undergo an independent impairment assessment by specially trained medical practitioners. Approved independent medical examiners also carry out independent medical examinations. Independent medical assessments can be carried out by medical practitioners, and psychologists, dentists, occupational therapists, optometrists, physiotherapists, chiropractors, osteopaths or podiatrists, provided these are registered with the Commission.
Disability Support for Older Australians program
8.36
Speech Pathology Australia highlighted another alternative assessment process used in the Commonwealth Government's Disability Support for Older Australians (DSOA) program. This program, it submitted:
…was designed by the Centre for Disability Studies using the I-CAN assessment, based on the World Health Organisation's ICF framework, and is more inclusive of the person with disability and their support networks.
8.37
A fact sheet available online about recent changes to DSOA indicated that the University of Sydney's Centre for Disability Studies will undertake these independent assessments, using a customised I-CAN Assessment, with further information to be made available in 2021. The program does not yet appear to have been rolled out.
National Injury Insurance Scheme Queensland
8.38
Where a functional capacity assessment is needed, Associate Professor Kylie Burns from Griffith University called for 'it to be a multidisciplinary process and it should also be an iterative and dynamic process'. She gave the National Injury Insurance Scheme, Queensland (NIISQ), as an example, telling the committee that:
The scheme certainly doesn't operate in a way that looks anything like what's being proposed for the NDIS. It has a much more multidisciplinary approach… It involves an internal planner building a package. There may well be some functional assessments involved but not in the manner in which has been proposed here.
8.39
The NIISQ website states that to apply to enter the NIISQ, participants need to have a 'qualified medical specialist complete the medical certificate attached to the Application Form—Interim Participation'. A further Functional Independence Measure assessment for brain injuries and burns may be required, and must be undertaken by a credentialed assessor. Once participants are accepted, they are assigned a Support Planner who becomes their main point of contact. This Support Planner may make contact with the participant or their treating team while the participant is in hospital to discuss the NIISQ's services and the support that it provides; coordinate, approve and pay for injury-related services (such as equipment, home modifications, rehabilitation or attendant care) needed for when the participant returns home; and assist the participant to develop their support plan to help them live at home and participate in their community.
8.40
Once a participant is accepted into the NIISQ, the NIISQ Agency undertakes an assessment that must involve consultation with the participant about the following matters:
the treatment, care and support the participant considers necessary and reasonable as a result of the participant’s injury;
the participant’s abilities and limitations; and
the participant’s individual goals.
8.41
The NIISQ Agency can also consult with other persons as it considers appropriate. Assessments are carried out within one year of the last assessment. Following the first assessment, the Agency must make a support plan that sets out the relevant treatment, care or support the NIISQ Agency considers to be necessary and reasonable, how this will be funded and any dates for further assessments.
8.42
Inclusion Australia also suggested that some schemes in other jurisdictions have moved from functional assessments to transdisciplinary assessment teams assessing individuals:
When the Productivity Commission suggested the use of independent assessments, the idea at the time was based on the use of functional assessments by no fault accident compensation schemes. In the decade since this suggestion, injury compensation schemes themselves are now moving to transdisciplinary assessment teams because of challenges with functional assessments.
8.43
The Royal Australian and New Zealand College of Psychiatrists similarly proposed 'a multi-disciplinary meeting' instead of independent assessments, arguing that this 'would encourage a more holistic approach, involving a variety of allied, medical and support staff as well as family and carers', with professionals then remunerated for their attendance.
WorkCover Queensland
8.44
Mr Matt Dunn from the Queensland Law Society also highlighted the Queensland Government's workers compensation scheme (WorkCover Queensland), which he described as 'largely more self-directed in terms of the individual making the choices about how they want to be supported and the types of providers'. He described it as 'by no means perfect. It has its rusty edges and its problems, as every model does, but it's proved to be quite a compelling model'.
8.45
The Queensland Government's WorkSafe website indicates assessments for the degree of permanent impairment for applicants are undertaken by specially trained doctors. If the applicant disagrees with this assessment, they can appeal it at the Medical Assessment Tribunal or ask the insurer to consider a review by a different doctor, who can be nominated by the applicant (from the list of specifically trained doctors).
8.46
When lodging applications, applicants must include a medical certificate from a doctor, nurse or dentist who treated their injury, with their entitlement to compensation beginning on the day when this assessment occurs. An insurer at any time may require an applicant to be personally examined by a registered person at a place reasonably convenient for the applicant, including an assessment of the degree of permanent impairment. If applicants do not agree with the degree of permanent impairment assessment and require a fresh assessment, they must respond to a notice of assessment within 20 days.
Workers compensation schemes in New Zealand
8.47
At the hearing in Brisbane, Mr Matt Dunn from the Queensland Law Society informed the committee that the current 'NDIA model probably looks a little bit closer to the New Zealand accident compensation commission model, and the Productivity Commission was quite smitten with that particular approach'.
8.48
The New Zealand Accident Compensation Corporation (ACC) requires that where a person lodges a claim themselves, they must provide the ACC with a certificate and undergo an assessment by a registered health professional who the ACC specifies. Treatment providers are also able to lodge a claim on the person's behalf.
8.49
Assessors are contracted medical practitioners who have at least general registration with the Medical Council of New Zealand and a minimum of three years' post-registration clinical experience, along with a current Annual Practising Certificate. ACC consults with the applicant to choose a contracted assessor who is qualified to assess their injury. Where possible, the applicant is able to choose which appropriate assessor they would prefer to carry out their assessment. In instances where the person suffers injuries requiring both a physical assessment and a mental and behavioural assessment, and if there is no assessor available and qualified to conduct both assessment types, ACC arranges for two separate independent assessments to be carried out.
8.50
At any time, a person is able to arrange for an additional independent assessment at their own cost. If this assessment has any points of difference, ACC investigates further. Persons are not entitled to have more than one reassessment within 12 months, and are not required to undergo more than one reassessment within 5 years, unless there are reasonable grounds that indicate impairment may have decreased since the last assessment. Assessment tools are taken from The American Medical Association's Guides to the Evaluation of Permanent Impairment 4th Edition, with impairment assessors for behavioural and mental impairments being required to be psychiatrists, or to have experience in completing general assessments for physical injury for ACC with knowledge of psychology and the diagnostic system in psychiatry/psychology. These assessors are also required to undergo additional ACC training.
Veterans' compensation schemes
8.51
The committee also considered how the Department of Veteran’s Affairs (DVA) uses information from a claimant’s treating medical practitioner to assess impairments for schemes that provide support and compensation for veterans and their dependants.
8.52
For most compensation and benefits provided to veterans and their families, the Government needs to accept liability for an injury, illness or death before a claim can be granted. Liability involves linking the veterans’ condition to their military service. Claimants must make a case that their condition is linked to their service and this case is assessed by a DVA claims assessor. DVA claims assessors typically do not have medical training but can request a review of medical records by DVA’s medical advisers.
8.53
The medical diagnosis of a claimed condition is based on a claimant’s medical records provided by their GP or specialist. The claim form for the Military Rehabilitation and Compensation Act 2004 scheme notes that DVA will pay the medical practitioner for the service.
8.54
Where medical records are not provided or are considered insufficient to establish a diagnosis, assessors can ask a claimant to have an appointment with an external medical assessor (paid for by DVA); however, reports from treating specialists are preferred.
8.55
The Productivity Commission (PC) examined the process for establishing liability in its 2019 report, A Better Way to Support Veterans. When examining the process for establishing liability, the PC heard evidence which raised concerns about theuse of external medical assessors. The PC found that external assessors ‘should only be called upon when strictly necessary and staff should be provided with clear guidance to that effect’.
8.56
Once liability for the condition has been accepted, DVA also needs to determine the type and level of benefit, usually through assessment of impairment and the pain and suffering caused by the condition. The PC noted that each Act has its own guide to assess rates of impairment, and that the use of different guides ‘makes comparisons across the Acts more difficult, increases the complexity of assessing claims, and increases the difficulty of offsetting between the Acts’. External assessors can also be used to assess the level of a claimant’s impairment.
8.57
For most claims, the onset or worsening of a condition is also based on information provided by treating medical practitioners or through a discussion with the claimant. Similarly, claims for the Invalidity Service Pension include information from the claimant’s treating medical practitioner. DVA pays medical practitioners for filling out the paperwork based on a fee schedule. The treating doctor also needs to fill out a work test questionnaire detailing the impact of the person’s impairments on their work capacity.
Medicare Benefits Schedule item
8.58
The committee learned that many submitters and witnesses were in favour of the Government fully funding consultations with healthcare professionals for the purposes of evidence for access and planning requests. In particular, some called for a new bulk-billed Medicare Benefits Schedule item to address equity issues that may lead some participants and prospective participants able to afford medical reports while others are unable to do so (see Appendix 3 for further detail). As one participant stated:
…as someone who was diagnosed late at 27 and on a low income, I understand the financial barriers of first gaining a diagnosis (for which there are neither Medicare or NDIS rebates available) and the additional hurdle of gaining enough paperwork to provide as evidence for accessing NDIS.
8.59
In light of this evidence, the committee commissioned the Parliamentary Budget Office (PBO) to investigate the cost of a new Medicare Benefits Schedule item to provide funded assessments for NDIS access and planning purposes. The item would allow participants and prospective participants to be fully bulk-billed for an assessment by a health professional of their choice. The committee was particularly interested to learn how much such an item would cost compared with the costs of a contracted panel of independent assessors ($339 million over three years).
8.60
The committee asked the PBO how much a new, bulk-billed Medicare Benefits Schedule (MBS) item would cost for assessments for three different cohorts:
A one-off assessment for all potential entrants to the NDIS;
Assessments for all NDIS participants to inform planning decisions (adults on average every three years, to take into account both those with stable conditions and those with fluctuating or degenerative conditions; and children under 18 once a year); and
All NDIS participants with a psychosocial disability, every three years. The committee selected this cohort in particular, before the Government's announcement that independent assessments would not proceed in their proposed form, given concerns raised about the stress and anxiety that may arise for people with psychosocial disability who would have been required to meet with an unfamiliar assessor.
8.61
The committee understands that at present, any proposed MBS items are subject to multiple reviews before they are implemented, a process which can take several years and is subject to considerable quality assurance processes. The Medicare Benefits Schedule (MBS) was recently the subject of a review by the MBS Review Taskforce over five years, concluding in 2020. The Taskforce recommended that a new Medicare Advisory Committee 'expedite the addition of new items' and 'draw on a broad range of clinical, health economic and consumer expertise to inform its decisions'. Whether the Government accepts this recommendation or continues using the existing systems in place to review proposed MBS items, the committee was confident that the consultation, oversight and quality assurance processes involved in proposing a new MBS item for assessments would be rigorous, and as such, decided to investigate this option.
8.62
The Parliamentary Budget Office's response to the committee's request is set out in Appendix 4 of this report, including the full assumptions underlying the PBO's costing. The costing, when using the PBO's baseline projection, indicated that:
A one-off bulk-billed assessment for potential entrants to the NDIS, between the 2021–22 and 2024–2025 financial years, would cost between $80.5 million and $450.8 million;
Regular assessments for all NDIS participants for planning purposes, during the same period, would cost between $1.63 billion and $2.04 billion; and
Regular assessments for participants with psychosocial disability, during the same period, would cost between $127.5 million and $150.6 million.
8.63
The schedule fees were set at $320 per session in the first year, and were based on similar MBS health assessment items, including autism, psychological and other physical assessments. Assessments in the costing were assumed to vary from two to eight sessions, with each session lasting at least an hour.
Other proposals from the Government
8.64
In answers to questions on notice concerning other options that the Government had considered to help ensure the financial sustainability of the scheme, the Minister responded that changes considered include:
Improved training and guidance for decision-makers;
Greater awareness by decision-makers of comparable decisions being made by their fellow decision-makers; and
Internal escalation of decisions that on the face of it would depart significantly from similar decisions.
8.65
The Minister stated that other changes already implemented or currently underway include:
Systemic changes to the way in which decisions about supported independent living support are made, meaning a move away from a quote-based system to a maximum price the NDIA is willing to pay for a 'fully loaded' cost of delivering an hour of support in a supported independent living setting;
Better targeted early intervention to address the needs of children with developmental delay, thereby potentially reducing the extent to which they would need to become long-term NDIS participants;
Improved fraud detection and minimised payment errors;
Work to ensure price controls are appropriate and aligned to adjacent sectors; and
Work on the National Disability Strategy to improve the accessibility of government services and raise awareness of these services throughout the community.
8.66
At the hearing on 5 August 2021, the Minister further clarified that assessments in some form will proceed, but that 'independent assessments are dead'.
8.67
The committee's full views on the proposals outlined throughout this chapter and its recommendations to the Government about next steps are outlined in the following chapter.