Ability First Australia strongly endorses the 2019 review of the NDIS Act and the new NDIS Participants Service Guarantee undertaken by Mr David Tune AO PSM, published in January 2020, which advocates for more transparency for how the NDIA make decisions, better access to NDIS supports, and more flexibility in using NDIS funding. We acknowledge the progress that the Australian Government and NDIA have made in protecting, supporting, and empowering people with disability, and we look forward to continuing to work collaboratively on meeting these objectives.
We have developed a list of Policy Priorities which we believe are critical in achieving this:
You can now download the Plain Language and Accessible versions of our Policy Priorities for 2022. These documents include our recommendations for disability sector policy priorities for this year, to:
- the NDIA
- the NDIS Quality and Safeguards Commission
- disability service providers
Download our Plain Language Policy Priorities for 2022
Download our Accessible Policy Priorities for 2022
Ensuring a consistent and positive customer experience across the NDIS to improve outcomes
The National Disability Insurance Scheme requires active market stewardship for all stakeholders to support the development of a marketplace that is sustainable, fair, and effective.
Customer experience is foundational to the design of the Scheme; despite this, the experience of participants entering the NDIS is variable and inconsistent, particularly for those with complex disabilities.
It is imperative that policy makers, agencies and providers actively engage with, and ensure that all government policy is informed by, the voice of the disability community.
- The Agency should work with selected participants and service providers to map their respective journeys through the NDIS and identify points in the process for improvement.
- Development of a logical roadmap for reform (including clearly defined business processes and commercial trading terms), to facilitate clear communication, and consistent and timely decision-making, mitigating any unintended consequences for providers and participants.
- The Agency should publish this roadmap and progressively implement, supported by appropriate communication and reporting.
Participants should have access to genuine choice through the presence of as many service providers as a market can sustain. In order to achieve that, system pricing must recognise and support the ability of providers to make a return that allows for investment into innovation, continuous service improvement processes, capital investment into service infrastructure and staff training and development.
Unless pricing is amended and then regularly reviewed to reflect the complex nature of disability, deregulation and price pose an ongoing risk of thin markets or areas of market failure (as we have seen with Disability Services Australia). This is particularly relevant in the provision of services for people with higher complexity/intensity needs.
The constant policy shifts across all agencies and associated additional administrative overlays are having a significant impact on the viability of providers who require certainty and consistency in relation to pricing to make investment decisions.
- The Agency needs to have a greater focus on streamlining business processes and minimising transaction costs within the scheme (across both the NDIA and NDIS Commission).
- The Agency needs to work with service providers to understand the true cost of service delivery.
Quality and Safeguards
5 years on from the establishment of the NDIS Commission, there is an opportunity to step back and ensure the issues that are being focussed on are the ones that truly matter; to audit and improve the current systems and reduce the administrative load, and to ensure that reporting requirements are aligned with the areas of peoples’ lives that keep them safe and brings about an improved quality of life.
One of the primary issues of concern for Ability First Australia members is the complex reporting. While we acknowledge the Commission’s valid reasons behind this extra reporting, it has resulted in additional and ongoing costs to service providers and had significant impacts on compliance efforts that must be recognised. Without any changes in pricing structure, this poses a risk to the viability of all providers.
We are concerned by the Agency’s mandate for more plan/self-managed services which have a low barrier to entry. While we support market growth and diversification, these services are largely unregulated and non-compliant with the NDIS Quality and Safeguards and pose a risk to the outcomes, safety, and quality of supports to participants.
- We need to ensure that quality and safety are aligned with, and enabled by, sufficient funding and policy development from government agencies, particularly for those participants with higher needs that are most vulnerable in the Scheme.
- NDIS pricing should be dynamic and responsive to reflect the obligations related to participants’ safety.
- We believe there should be universal regulation across the sector and that compliance monitoring should be appropriate and proportionate and take into account the maturity and nature of providers.
- The Commission should share data and benchmarking with the sector to identifying areas of improvement and best practice.
The development and supply of a quality, well-trained workforce is critical to support economic recovery. A major part of a participant’s experience of the NDIS is a result of their interaction with the workforce; the demand for quality, well-trained staff is therefore paramount.
We believe strategic investment by policy makers in these areas is imperative and will ultimately benefit the wider community socially and economically.
- The Government needs to facilitate and coordinate the growth of the workforce across all states and territories.
- There is an opportunity to align training, qualifications, pay, compliance requirements and quality of Aged Care and Disability sectors, to facilitate individuals to work across both sectors.
- We encourage the Government to work closely with the Sector to develop adequate training and education pathways that address workforce supply and retention.
Investing in the capacity of individuals and empowering them to become productive and contributing members of the community is not only critical to the success of the scheme, but a key driver for economic recovery.
A strategy that builds and sustains participation in the workforce for people with disability also aligns exceptionally well with the Government’s mandate for job creation.
- We need government to work with all employers to address regulatory, financial, cultural, and physical barriers to employing people with a disability.
- We would encourage the Government to commit to working closely with the Sector to develop adequate training and education pathways, as well as career opportunities of open employment to support these positions, and by doing so, achieve the objectives of the NDIS and outcomes for participants.