Communication and business transactions
2.1
The chapter examines two key functions of NDIS ICT systems essential to
the efficient implementation of the Scheme:
-
enabling of the effective communication and provision of
information between the NDIA, participants and providers and within the NDIA;
and
-
facilitation of the business transactions between participants
and service providers through the participant and service provider portals.
How the Agency communicates
2.2
Since its establishment in September 2016, the committee has
consistently received evidence of the NDIA failure to communicate clearly, effectively
and in a timely manner with participants and service providers.[1]
2.3
During this inquiry, participants, their families and carers as well as
service providers have also expressed concerns about the difficulty of contacting
the NDIA when they require assistance.[2]
2.4
Submitters identified the communication tools used by the NDIA as a key
barrier to transparent, timely, accurate and appropriate communication between
the NDIA and its stakeholders.[3]
2.5
Importantly, inquiry participants raised issues about the lack of
clarity, consistency and accuracy of information provided by the NDIA.[4]
Website
2.6
The NDIA principally uses its website to provide information and updates
about Scheme operations and policies to prospective and existing participants
and service providers. Brochures, information sheets, guides, and forms can be
downloaded from the website.
2.7
Inquiry participants described the website as difficult to navigate, not
easily searchable, confusing and lacking easily understandable information.[5]
2.8
For example, a respondent to the Carers NSW 2018 Carer Survey said that
'the website is impossible to navigate: you go round in circles and still can't
get answers'.[6]
2.9
Similarly, The Benevolent Society explained that 'while some information
is available through the NDIS website, it is difficult to navigate the large
amount of content on the website to find relevant and up-to-date information'.[7]
2.10
Children and Young People with Disability Australia (CYDA) also
expressed concerns about the use of 'complex formats and bureaucratic and
arcane language' throughout the website and downloadable materials.[8]
2.11
Issues raised about the website appear to go well beyond design,
navigation and configuration. Accessibility and the quality of website content were
also identified as key issues needing urgent attention.[9]
NDIS Contact Centre
2.12
To contact the NDIS, people can call a toll free number or email
enquiries, which are directed to the NDIS Contact Centre (NCC):
The NDIS Contact Centre (NCC) is responsible for taking phone
and email enquiries from all those wishing to make initial contact with the
NDIS, as well as participants, providers and anyone who requires information
about the Scheme.[10]
2.13
On 20 April 2018, the NDIA announced the engagement of Serco Citizen
Services Pty Ltd (Serco) as its NCC service delivery partner in a two year
contract.[11]
Phone enquiries
2.14
From 1 July to end of September 2018, the NCC answered over 240 000
calls with 84 percent of those calls answered within one minute. According to
the NDIA, NCC Customer Services Officers achieved a 97 percent quality rating.[12]
2.15
Develop Therapy Services acknowledged that the wait time to get a call
answered has significantly reduced since the appointment of Serco. However, it
pointed out that staff employed in the call centres are not always able to
answer specific enquiries as they lack knowledge and experience. This often leads
to a time consuming and convoluted process to get an answer:
They (call centre staff) then send an email to someone more
knowledgeable [...]. The name of this 'someone' is not given, nor their personal
email. This causes waiting times for all issues [...]. There is no way of
directly following this up, instead the process begins again with the call
centre when responses have not been received.[13]
2.16
The lack of knowledge and experience of NCC staff was raised by other
submitters.[14]
For example, a service provider trying to resolve a payment issue on the portal
stated:
It took two phone calls to the NDIS phone line to ascertain
his father needed to ring NDIS and give me permission to see his plan on the
portal – I already had a copy of it in hand. Then, that didn't appear to make
any difference [...] Two more phone calls and no help from inexperienced phone
help staff and two emails to some mythical NDIS support service has not yielded
any assistance so far.[15]
2.17
As described by submitters, the inability to follow-up and continue
progressing the initial query with an assigned person or an assigned case
number creates additional delays and frustration.[16]
Email communication
2.18
According to a submitter, email communication appears to be the NDIA's preferred
method of communication.[17]
2.19
The NDIA has a system of using generic email addresses for external and
internal communications. Issues experienced by service providers and participants
include:
-
after an automatic reply that the email has been received, there
are significant delays in receiving an actual response to the query;
-
emails being lost or not being answered at all beyond the
automatic reply;
-
no mechanism to have urgent emails attended;
-
receiving inconsistent information; and
-
the lack of expertise of staff answering queries. [18]
2.20
Overall, submitters reported that the generic email address and toll
free number are an ineffective means of contacting the NDIA for assistance and
more broadly interacting with the Agency.[19]
Access to ICT support
2.21
Participants and service providers contact NCC to access ICT support
when they have issues with the portal. Inquiry participants expressed concerns
about their inability to contact ICT staff directly.[20]
2.22
According to the Dietitians Association of Australia (DAA), the
difficulties with processes within the NDIS ICT infrastructure and the extended
delays in reaching support staff to resolve ICT issues are key contributing factors
to interruptions in the provision of care to participants, delays in financial
payments to providers and underutilisation of participant plan funds.[21]
2.23
Speech Pathology Australia raised similar views, stressing the issues of
delayed or non-payment of invoices for its members due to their inability to
contact ICT staff.[22]
2.24
DAA recommended the implementation of a direct ICT contact number where
suitably trained staff can be accessed.[23]
2.25
Additionally, submitters recommended the NDIA consider introducing an
online live-chat function on the website and portals as it would likely reduce
the frequency of calls and improve interactive problem solving.[24]
2.26
Illawarra Disability Alliance suggested the NDIA implement a
ticket-based helpdesk system to manage technical enquiries so providers can
easily track and monitor the resolution of technical issues.[25]
2.27
The NDIA informed the committee that technical support for NDIA ICT
services is provided by the Department of Human Services (DHS) and can be
accessed through the DHS ICT support portal – My support. In addition, the NDIA
has an escalation email address to support NDIA users.[26]
Accessibility
2.28
Submitters expressed concerns about the accessibility of some of the
NDIS ICT platforms and information.[27]
2.29
For example, Speech Pathology Australia reported that the participant
portal does not have options to make it more accessible and functional for
participants. For example, it lacks basic accessibility options such as
alternative font sizes, and information in other languages, or Easy English.[28]
2.30
Children and Young People with Disability Australia (CYDA) noted that
Easy English versions of key documents are either not available or hard to
locate on the website. For example, CYDA reported that it could not locate an
Easy English version of the MyPlace Participant Portal: Step by Step Guide
2018.[29]
Appropriateness of communication
tools
2.31
The Centre for Digital Business argued that communication tools used by
the NDIA are simply not fit-for-purpose for many participants:
The NDIA sends letter to people who physically can't open
them, and to people with a cognitive disability who cannot understand the
bureaucratic language. Letters, forms, brochures point to the website which is
not searchable; to the portal which does not meet the communication and
accessibility needs of a great many people; and a call centre which cannot meet
the needs of people who are non-verbal or have cognitive impairment.[30]
2.32
A submitter reported that having to communicate by phone to set up
access to the participant portal is not an appropriate communication tool for
some participants:
Needing to do this by phone presented a significant challenge
and hindered their independence because, due to their disability, they have
difficulties talking on the phone.[31]
2.33
A submitter who helps a family member who is an NDIS participant pointed
out that NDIS ICT 'appears to be designed and built on a social security
architecture model rather than a consumer directed care model'.[32]
Co-design
2.34
The Centre for Digital Business is of the view that a different approach
to providing information is required to meet the demand of NDIS participants.[33]
It stressed the importance of engaging in a co-design:
With approximately 60 percent of the NDIS participants having
some form of intellectual disability or autism, the objective of choice and
control compelled a different approach and one that by necessity had to be
grounded in co-design.[34]
2.35
Similarly, the Public Service Research Group UNSW Canberra is of the
view that participants and their support networks should be involved in
designing their digital interface with the NDIS, drawing on evidence based co-design
principles.[35]
2.36
The Centre for Digital Business recommended that an expert co-design
capability should be established in the NDIA.[36]
2.37
Cara, a service provider, also supported a co-design approach for
improved ICT systems that might allow greater participant choice and control.[37]
Nadia
2.38
Based on evidence suggesting a new approach is needed to provide information
and assist people to navigate the NDIS, the NDIA started to develop the 'Nadia
project', an avatar with human expression that listens to questions and
responds with information about the NDIS.[38]
2.39
The Centre for Digital Business explained how Nadia was developed:
The development of Nadia involved a very deep co-design and
co-creation effort based in market and community research; academic research,
support and engagement with networks of people with intellectual disability;
the development of the operating model within the Agency; and the research and
development activities of strategic partners.[39]
2.40
The Centre for Digital Business stated that a co-designed, working and
tested Nadia conversational cognitive system was delivered by the NDIA in
December 2016. In February 2017, the NDIA announced the introduction of Nadia.[40]
2.41
However, Nadia has not yet been released.
2.42
In an answer to a question on notice, the NDIA informed the committee
that Nadia has been temporarily postponed for two reasons:
Firstly, to allow the completion of the Pathways strategic
program which will redefine key processes of the NDIS. Once these have been
defined, Nadia can be updated with relevant processes. Secondly, the technology
underpinning speech recognition is still maturing.[...] The release of Nadia is
predicated by the maturity of the technology, progress on this is reviewed
regularly.[41]
2.43
The Centre for Digital Business contended that Nadia was technologically
ready and that other factors are responsible for the postponement of its
release.[42]
Quality of information
2.44
Submitters reported that across all platforms the quality of information
provided by the NDIA is generally poor, inconsistent and confusing.[43]
2.45
For example, a submitter contended that 'the billing and pricing
information provided on the website is vague, ambiguous and open to
interpretation' and concluded:
This leaves room for many problems and misconceptions due to
a lack of clarity, consistency and transparency around Agency decision-making.[44]
2.46
This raises questions around the lack of clear policies and funding guidelines
on some types of supports. For example, Greenacres, a provider of School Leaver
Employment Supports (SLES) sought clarification via an email enquiry of weekly
claimable rates for SLES support and received a suboptimal response ending with
an acknowledgement that further information about funding levels for these supports
'will be published shortly'.[45]
2.47
Similarly, an NDIS participant explained that she finds it hard to
exercise choice and control as she has received no clear information about the
supports she could claim under her plan despite asking her planner, NDIS LAC,
and searching the website and NDIA documents. She concluded:
I understand we are all new to this – the government, the
providers and the 'clients'. But at the very least, by now the NDIS could
provide information to us clients, so we can begin to exercise some choice and
control. That choice and control cannot occur in the information vacuum which
currently exists.[46]
Knowledge-management system
2.48
PricewaterhouseCoopers (PwC) and the Australian National Audit Office
(ANAO) have previously identified the need for a knowledge-management system to
manage information and knowledge within the NDIA and ensure consistency and
traceability of decisions.[47]
2.49
Holocentric was engaged by the NDIA from February 2015 until December
2017 to contribute to the development of NDIA Knowledge, a systems-based tool
to integrate NDIS business processes, policies and guidance to staff via a
central repository.[48]
2.50
The scope of the project was to capture all business processes and
associated artefacts that would be used by NDIS staff.[49]
2.51
In October 2017, the NDIA stated that NDIA Knowledge 'will enable
decisions to be tracked and traced to the point of origin e.g. legislation,
policy, operational guidance. The system is being designed to become a
single-source of truth and provide an appropriate audit trail'.[50]
2.52
However, in February 2018, 'the NDIA decided to put implementation of
NDIA Knowledge on hold, and consider other knowledge-management systems, which
may be more fit for purpose'.[51]
Committee view
2.53
The inability of participants and service providers to find adequate
information or to have their queries answered in a satisfactory and timely
manner is significantly impeding the implementation of the Scheme and the
delivery of quality outcomes for participants.
2.54
The committee acknowledges that the NDIA is trying to address some of
these issues through the implementation of the new participant and provider
pathways. Proposed changes should reduce the volume of calls and emails to
access information and resolve planning and plan implementation issues. However,
the information provided by the NDIA about the process and timeframe to
implement the new pathways beyond trial sites is nebulous and vague. There is
no implementation schedule to inform stakeholders what the changes entail and
when and how the changes will occur beyond trial sites.
Recommendation 1
2.55
The committee recommends the NDIA start the national rollout of the new
pathways and make publically available a clear schedule of the changes to be
introduced along with implementation dates.
Website
2.56
The committee has previously made recommendations about the need to
improve the NDIS website design and navigation as well as the quality and
accessibility of its content.[52]
The committee is aware that the NDIA is currently redeveloping the NDIS
website. A test website has recently gone live.[53]
The committee encourages stakeholders to test the new website and send feedback
to the NDIA.
2.57
The development of the new website must go beyond improving
accessibility, design and navigation. The committee is of the view that
improving the quality of its content is of prime importance. It is essential
that all documents are reviewed prior their upload to ensure clarity,
consistency and accuracy of information. The committee will closely monitor and
further report on progress made through the redevelopment of the website.
Recommendation 2
2.58
The committee recommends the NDIA review all documents, including
guidelines, forms and policies, prior to their upload onto the new website to
ensure that they are current, clearly dated, fit-for-purpose and written in
clear language.
NDIS Contact Centre
2.59
The committee is concerned that the NCC is not meeting the needs of
participants and service providers. This resource is failing to provide
end-users with adequate information and support to troubleshoot problems.
2.60
The inability to follow-up a query or a reported issue because of the
absence of a tracking system is creating unnecessary delays, duplication of
efforts and additional administrative burden for both the NDIA and end-users. Additionally,
the committee heard that, too often, queries via email were not being attended
beyond the automatic reply. The inability to directly contact ICT support staff
or other specialised teams is also creating additional delays and
administrative burdens for participants and providers. These poor business
practices must urgently be addressed by the NDIA through the introduction of additional
help desk functions and mechanisms that are commonly used by companies dealing
with large numbers of end-users.
2.61
The need for additional communication channels that are fit-for-purpose
and meet the needs of people with disability should not be underestimated. The
committee noted the potential of the Nadia project to address accessibility
issues and facilitate provision of information in an effective manner to the
majority of participants.
Recommendation 3
2.62
The committee recommends the NDIA:
-
implement a tracking system to enable end-users to track the status
of their queries;
-
create specialised National Contact Centre teams based on the
common types of issue raised by end-users; and
-
co-design with end-users a fit-for-purpose chatbot for the
website and portals.
NDIA Knowledge-management system
2.63
The committee heard that the quality of information provided by NCC
staff is often poor, pointing to a lack of experience and skills among the
staff employed in the NCC. The committee believes that the absence of a
systems-based tool, which would integrate NDIS business processes, policies and
guidance to staff via a central repository is contributing to the current
inability of NCC, NDIA and LAC staff to provide consistent and clear
information to prospective and existing participants and service providers. The
committee is concerned that the NDIA has put on hold the development of its
knowledge-management system.
Recommendation 4
2.64
The committee recommends the NDIA urgently recommence work on the
development and implementation of its knowledge-management system to ensure
consistent decision-making processes and accurate provision of advice across
the agency.
Business transactions
2.65
The MyPlace participant and provider portals enable business
transactions between participants, providers and the NDIA.
2.66
As discussed in Chapter 1, there have been continuous developments and
improvements to the participant and provider portals since their launch in July
2016.
2.67
The NDIA is planning to continue to add new features on the portals. For
example, by early 2019, an Appointment Tool to allow better scheduling for
participants and partners will be released.[54]
2.68
Despite these improvements, inquiry participants raised a number of
issues about the portals, including:
-
the lack of information, training and support to use the portals;
-
increased administrative burden and costs due to portal and NDIS
processes;
-
the lack of key features on the portals to facilitate business
transactions and reporting;
-
limited effectiveness of the Provider Finder tool;
-
the lack of information about portal changes; and
-
the lack of consultation, collaboration and testing with service
providers and participants to find ways to improve the portal.[55]
Information, training and support to use the Portal
Participants
2.69
A key factor contributing to the difficulties associated with the portal
is the lack of accessible information, training and support for participants
and families.[56]
2.70
For example, the Benevolent Society reported that some participants are
frustrated because they struggle to navigate the portal with limited
information and assistance from the NDIA.[57]
2.71
CYDA recently conducted a survey regarding NDIS ICT with young people
and families, which revealed that 83 percent of respondents had not received
any training or support in using the portal.[58]
2.72
CYDA acknowledged the existence of the MyPlace Participant Portal:
Step by Step Guide 2018 but contended that the availability of the guide is
not well known.[59]
2.73
An NDIS participant pointed out that 'even when the information I need
is available, I do not know how to navigate to find it'.[60]
2.74
A submitter suggested that the portal should have an immediate contact
process similar to the 'chat to someone now' function that many websites have
to facilitate resolving issues and answering questions.[61]
Barrier to self-manage plans
2.75
The lack of information and support available to use the portal is a
contributing factor for NDIS participants to choose not to self-manage their
plans.[62]
For example, an NDIS participant explained:
A major factor in choosing not to self-manage in my second
plan is that I do not understand the portal and it is unreliable and difficult
to use.[63]
2.76
LanternPay contended that the portal is not suitably designed for
self-managed participants, which contributes to the slow uptake of self-managing
by participants.[64]
NDIA response
2.77
The NDIA stated that training and support to participants to access and
navigate the portal is available through:
-
the step-by-step guide publically available on the website or
from NDIA and LAC offices;
-
the NDIS Contact Centre
-
the planning process where participants are provided advice and
given direct support to access and use the portal; and
-
the re-designed participant plan which now includes a consistent
point of contact (a LAC or planner) who can provide support to use the portal.[65]
Administrative burden and costs
2.78
Despite investing in new IT infrastructure and systems to facilitate their
business transactions under the NDIS, service providers continue to experience
increased administrative burden.[66]
2.79
The Dietitians Association of Australia provided an example of
additional administrative tasks required to process invoices:
DAA are concerned about the new requirement to separate
invoices for standard dietitian consult, travel, cancellation and report
writing. This will lead to increased administrative burden for APD registered
providers. [...] The Portal functionality and useability results in ineffective
use of APR registered NDIS providers' time.[67]
2.80
Service providers also reported increased transactional costs because of
portal issues ranging from system failures to lack of useful portal features to
facilitate business transactions and reporting.[68]
2.81
For example, The Benevolent Society told the committee that the ongoing
administrative and technical difficulties arising from the portal have created
significant additional costs and barriers to providing services to clients.[69]
2.82
The administrative burden and hidden costs of the NDIS ICT systems are
not restricted to providers.[70]
For example, a submitter who self-manages his child's plan also reported that
he spends hours administering his child's NDIS plan because the setup of the
portal is inadequate.[71]
Unsuccessful payments to providers
2.83
While it is acknowledged there have been changes to the portal to
address the causes of a significant proportion of payment problems, some
inquiry participants argue that it is still difficult and administratively
onerous to receive payments.[72]
2.84
The National Disability Services (NDS) reported that between June and
September 2018, there was a 9 percent unsuccessful payment rate, which equalled
almost 30 000 unsuccessful payment claims per week. It concluded:
Two years on, receiving payment for supports is still more
difficult than it should be (some take many weeks to resolve). An equivalent
payment failure rate in other sectors such as financial services or retail
would be unthinkable.[73]
2.85
The NDS acknowledged that the NDIA responded to the problem by
establishing a national provider payments team to facilitate the payment of
rejected claims. However, the NDS noted that 'a well-functioning portal would
not require this large, dedicated team of people to ensure providers receive
payments' and that 'it is an expensive and cumbersome solution to an ICT
problem'.[74]
2.86
Illawarra Disability Alliance reported that service providers have to
employ staff just to manage portal claim errors, which is financially
unsustainable.[75]
2.87
In an answer to a question on notice, the NDIA informed the committee of
its recent work to address payment issues:
Over the past six months, the National Provider Payment Team
(NPPT) has implemented a number of changes to enable a more efficient process
for resolving payment issues. In October 2018, a further enhancement was made
to the portal [...] The work undertaken has improved payment processing times and
reduction of payment backlogs. [...] The NPPT has also developed a self-help
guide available to assist providers through the payment claim process and hence
reducing instances of payment claim error.[76]
Provider Finder tool
2.88
The portal features a Provider Finder tool to enable participants to
find providers and services in their preferred locations. Participants and
providers can search by different criteria, including by provider name,
profession, support category or near location.[77]
2.89
The website also provides links to lists of NDIS registered providers for
each state and territory.[78]
2.90
Inquiry participants are of the view that the search function to find
providers and services on both the portal and the website requires improvement.[79]
2.91
Inquiry participants reported that the Provider Finder tool on the
portal lacks accurate information about providers.[80]
For example, Occupational Therapy Australia stated:
Despite many attempts to improve the tool, the resource is of
limited value due to the significant number of errors in the listings. For
example one occupational therapy practice is a provider of therapeutic supports
is listed as providing 'Builder Surveyor' and 'Orthoptist' supports.[81]
2.92
However, the NDIA stated that 'providers have the ability to update information
relating to their business operations without requiring manual intervention by
the NDIA. This enables providers to self-serve and update information relating
to contact details or appointment availability online'.[82]
2.93
The NDIA also informed the committee that further enhancements to the
Provider Finder tool will be made in early 2019, including a more intuitive and
usable map function.[83]
Portal changes
2.94
Inquiry participants reported that information about portal changes are
not communicated to service providers and participants and recommended that the
NDIA clearly inform users of upcoming changes to the portal.[84]
2.95
For example, The Benevolent Society pointed out that staff become aware
of changes within the portal when they begin to experience problems.[85]
2.96
Greenacres noted that local NDIA staff are not provided with any support
documentation or advice about portal changes and are unable to respond to basic
questions.[86]
Lack of consultation
2.97
Inquiry participants pointed out that the portal was not designed in
collaboration with users and called for much greater collaboration and
consultation with stakeholders to find ways to make the NDIA portal work more
efficiently and effectively.[87]
2.98
Allied Health Professionals Australia reported that the lack of testing with
users before implementing portal changes has resulted in transaction issues,
additional administrative and accounting burdens and costs to providers.[88]
2.99
Similarly, Occupational Therapy Australia submitted that the NDIA
ongoing failure to consult with users or to properly trial intended changes to
the portal have resulted in implementing changes that have had negative
consequences for providers.[89]
2.100
Illawarra Disability Alliance also noted the lack of consultation with
software vendors who deliver NDIS solutions.[90]
2.101
Inquiry participants overwhelmingly recommended that ICT systems,
including the website and portal changes, be user tested with participants,
carers and service providers to identify and resolve ongoing and emerging
issues.[91]
2.102
However, the Department of Human Services, which developed the NDIS ICT
solutions, says it places a strong focus on the adoption and implementation of
User Centred Design and has established Design Hubs to provide an environment
where designers, service users, partner agencies, third parties and others can
work together to create and test solutions quickly.[92]
2.103
The NDIA also contended that 'it has significantly increased
consultation with participants, providers and peak industry bodies on all
business led ICT change projects'.[93]
Committee view
2.104
The committee acknowledges that the portals are a work in progress. New
functions and features are regularly added to address issues identified by
end-users and enhance the portals' functionality and capabilities.
Training and support
2.105
The committee is concerned that participants are unable to access
training and support to use the participant portal. The committee understands
that the 'new participant experience', when rolled out will assist in providing
better support for participants to implement their plans, including how to use
and navigate the portal. However, the committee is of the view that some
participants will likely need support beyond the initial training provided by
planners and LACs. The committee believes that implementation of Recommendation
3 of this report will ensure participants can access relevant support to use
the portal at all times. In particular, work on co-designing a fit-for-purpose
chatbot for the portal should start immediately.
Portal changes
2.106
The committee urges the NDIA to clearly communicate portal changes to
end-users prior to implementation. Information about upcoming portal changes and
relevant training materials should be posted on the portals.
Recommendation 5
2.107
The committee recommends the NDIA publish on the participant and
provider portals the launch dates of future portal changes along with training
materials.
Consultation with end-users
2.108
The committee is of the view that the NDIA must engage with stakeholders
to design and enhance all aspects of the ICT services that underpin the NDIS
service delivery model. It is clear that a lot of administrative burden and
additional transaction costs would have been avoided if the NDIA had initially
collaborated with end-users to design and improve the portals.
2.109
The development of the 'Provider Finder' tool is still in its infancy. The
committee has previously heard that many participants and their families have
come to rely on online resources to get information about NDIS registered
providers.[94]
Therefore, it is paramount the 'Provider Finder' tool is further developed to
meet the needs of participants, their families and carers.
Recommendation 6
2.110
The committee recommends the NDIA work with service providers and participants
to co-design future enhancements to the portals and 'Provider Finder' tool.
Hon Kevin Andrews MP
Chair
Senator Alex Gallacher
Deputy Chair
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