Policy Submission: NDIS Costs

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Introduction to this submission

JFA Purple Orange welcomes this opportunity to make a submission to the Productivity Commission’s study. The Productivity Commission study into the National Disability Insurance Scheme (NDIS) costs comes at a critical time in the life of the new Scheme.

JFA Purple Orange believes that the NDIS is a major, once-in-many-generations opportunity to invest in the life chances of people living with disability, to achieve a fair go, so that people living with disability take their rightful place as a valued active members of Australian community life and the economy. The NDIS is an opportunity for Australia to become a world leader in social welfare reform. However, many a good idea has been compromised in its implementation.

This submission examines a number of areas that we believe require urgent and strategic attention to help ensure the NDIS delivers on its promise. In contemplation of such matters of design and implementation and the extent to which they advance or undermine the underlying values, this submission focuses on several themes:

• The compromised role of the National Disability Insurance Agency  
• Living the values that underpin the Scheme
• Reframing the approach to planning, to draw on community expertise  
• Reframing the approach to the LAC role, to draw on community expertise
• Reframing the approach to pricing, in support of a demand driven diverse market
• Deeper investments in NDIS participant capacity building
• Reframing the approach to divining Scheme costs
• Psychosocial disability and non-clinical community mental health services
• Challenging a possible assumption about workforce expansion, and the associated implications for choice

Summary of recommendations

Recommendation 1

That the approach to the development of NDIS policy, NDIS sector, and related matters, be consolidated and simplified so there is single-agency accountability, and a framework that can be held properly accountable for ensuring the disability community perspective is engrained in every NDIS policy decision.

Recommendation 2

That auditable system arrangements be put in place to ensure that all NDIS design and implementation decisions (as made by the NDIA and other government bodies including the Disability Reform Council, the Department of Social Services, and others, including the Productivity Commission in the present study), uphold and advance the values of control and choice and authentic valued participation in mainstream community life and the economy.

Recommendation 3

That the NDIS adopt as soon as possible a set of outcome measures that genuinely measure transformational benefits in the lives of NDIS participants.

Recommendation 4

That the NDIS planning methodology be overhauled to include capacity for community-based individualised planning performed by non-service-providing community agencies, with in-house agency planners available by exception, and that this leads to a corresponding reframing of the NDIA planner role and responsibilities, as per the report to NDIA, About pre-planning An advisory report to the National Disability Insurance Agency (NDIA) on how people can best be assisted to prepare for the NDIS.

Recommendation 5

That the NDIS LAC function be redesigned to enable its delivery by local agencies that have deep presence in, and deep knowledge of, specific local communities.

Recommendation 6

That the NDIS approach to market development be reconsidered, in support of the goal of transformational benefits in people's lives.

Recommendation 7

That the fixed prices for NDIS services be removed as soon as possible and prior to full Scheme, in favour of price signals that can influence transactions in the emerging disability services market consistent with the three core reform principles detailed earlier in this submission.

Recommendation 8

That an NDIS eMarket be established without delay, to facilitate NDIS participant informed choices.

Recommendation 9

That the NDIS and the Disability Reform Council develop a long term strategy for investment in the demand sector of the NDIS market – people living with disability and their families – by building momentum for DSO-type activities including, but not limited to, peer networks. And that funding for existing demand side initiatives including the DSO project be continued until the demand side strategy is developed and implemented.

Recommendation 10

That the NDIS review its costing model, to ensure it focuses on the costs of genuinely lifting people’s life chances and take-up of valued roles, as opposed to a narrower focus on the costs of functional deficit.

Recommendation 11

That the state and territory government partners in the NDIS do not divest themselves from involvement in non-clinical mental health services without a comprehensive examination of the implications, and involving consumer stakeholders in those deliberations.

Recommendation 12

That the NDIS review the boundaries it sets on the options available to NDIS participants, to ensure it is maximising the value (control and choice, participation in community life in the economy, and Scheme financial sustainability) of participants having the option to access a broad range of mainstream options. Further, that Treasury assist this process, to help ensure that such deliberations are not thwarted by concerns about whether an NDIS individual budget constitutes taxable income if a participant is using part or all of it for ‘ordinary’ things that most people pay for out of their own disposable income.