foundational supports

Paediatric allied health clinic owners: things are not looking great when it comes to Targeted Foundational Supports

David Kinnane · 14 November 2024 · Leave a Comment

Another week, another consultation paper. And, as an independent speech pathology clinic owner who sees many children with developmental delays and/or disability, this one did not speak to my inner optimist.

1. But, first, a bit of context

Back in late September 2024, we wrote about the first Foundational Supports Consultation, looking at a consultation paper and webinar about General Supports.

A second paper – Foundational Supports for children with developmental concern, delay and/or disability and their families, carers and kin Consultation Paper – has been released. It’s dated October 2024. But I only found out about it last week; and only then by accident while looking for something else.

It’s more ambitious than the General Supports paper, and includes a discussion of “Targeted Foundational Supports” for children with developmental delay and their families who need more assistance than General Supports and mainstream services.

2. For strategy and business planning, paediatric allied healthcare providers need to understand what’s proposed

Targeted Foundational Supports are intended to include some allied health services, and so are of interest to paediatric allied health providers (like me), as we look to evaluate our service-delivery models to adapt to new systems of supports made up of three connected tiers:

mainstream early childhood education and school supports;
Foundational Supports, including Targeted Foundational Supports; and
a (yet-to-be developed) new early intervention pathway in the NDIS for children with the highest level of needs.

The idea seems to be that some families will access a combination of these supports, and perhaps different combinations of these supports at different stages as children’s needs change.

The key challenges for allied health providers are how to work within and across such complex systems to deliver quality, evidence-based services to children while keeping staff satisfied with their work – and staying solvent!

3. Reality check: On the ground, funded supports for children with developmental delay and/or disability through the NDIS are shrinking

On a first read, page 9 of the paper caught my eye:

“The recent ‘Getting the NDIS Back on Track” changes to the NDIS Act do not change a child’s participant status or remove their access…Nothing is changing now.”

These statements are hard to reconcile with recent news stories, like this, with journalist Rick Morton reporting that:

the NDIA is sending out more than 1,000 eligibility reassessment letters each week;
in the last six weeks, almost 7,500 eligibility reassessments have been performed – 78% of which are on children aged up to 8 in the early intervention scheme – with 48% of the total being removed from the NDIS, and 20% being asked to provide more information (so-called “general evidence”) within 28 days if they “think they still meet the NDIS eligibility requirements and wish to continue with the NDIS”; and
the NDIA is completing around 1,250 eligibility reassessments per week, aided by 95 new dedicated staff.

“Nothing is changing now”? Many families and health care providers would disagree.

4. Two predictions, and a comment

A. Allied Health Targeted Foundational Supports will not be provided in clinics

According to the authors of the consultation paper:

the 2023 Independent Review of the NDIS found that, under the current system:
- “supports for children with emerging developmental concerns and disability are too focused on a clinic-centred model of support and not enough on functional and support needs”; and
- there was “not enough focus on supporting children in everyday settings where they live, play and learn” (see page 13);
decisions on how to deliver Targeted Foundation Supports are yet to be made by governments. But the options to be considered:
- will look to use existing services and infrastructure to deliver supports to where children live, learn and play;
- may be provided in group settings (helped by an allied health worker or a multidisciplinary team) or individually in a child’s natural environment;
- mark a change of approach that “shifts away from a mostly one-to-one therapy model in clinical settings, which is not seen as best practice early intervention for most children”; and
a child may have access to allied health:
- through a referral to a group with other children getting similar supports “helped by an allied health worker or a multidisciplinary team”; or
- individually in the child’s natural environment (page 18).

B. Allied Health Targeted Foundational Supports:

a. will be more limited than under the ‘former’ NDIS; and

b. may not always be delivered directly by allied health professionals

The paper’s authors state that some children could be eligible to get one or more of:

low intensity or periodic child and and family-centred allied health supports, including from speech pathologists, physiotherapists, psychologists, occupational therapists or other allied health specialists;
more intensive, one-to-one capacity-building from a (not specified) “suitably qualified and experienced worker” who could provide coordination and help families get appropriate supports. This support may be delivered jointly with allied health supports (page 17);
a one-off, low-cost assistive technology consultation to increase independence at childcare, school or home (page 18); and/or
extra supports if the child is “identified” as having concerns across a number of developmental areas, delivered by a “qualified and experienced person with child development expertise”. It’s not clear who will identify the concerns, or what qualifications, experience or child development expertise will be required (page 18).

C. A closing comment

The consultation period appears to end at midnight on 5 December.

Based on what happened with the NDIS supports consultation, a cynic might suggest that the Federal Government has already decided what it wants from Foundational Supports and will now work with the states to make it happen, regardless of what families or allied health providers think or say.

I don’t know. But it’s hard to justify spending significant time or resources responding to consultation papers when we have so many clients needing help, when so many changes are happening at once, as we approach calendar year-end and have already weathered so much change in such a short period.

But we can’t ignore the changes, either.

Paediatric allied health clinic owners must start to think about whether they want to deliver Targeted Foundational Supports, recognising that:

adding Foundational Supports to service-mixes may:
- increase business risks and complexity;
- take away resources from other services and projects; and
- affect staff satisfaction with our workplaces;
one-to-one or in-clinic models are unlikely to work;
therapy dose constraints may reduce outcomes;
service-delivery constraints may reduce control over service quality; and
cost-effective access to mainstream and other ‘natural’ settings may be difficult in some states and regions for logistical, compliance, or financial reasons.

We must also remember that proposed changes will be hard to navigate and deliver for other stakeholders, too, including educators in childcare settings and schools, and governments.

As the authors of the paper note, effective, early child- and family-centred care, through the delivery of strength- and evidence-based services, can lead to significant improvements for children across developmental domains. We all want systems that deliver good outcomes for children and families.

One other thing we must not forget: the stakes of getting this right are life-changingly high for children with developmental delays and/or disability and their families – particularly for children who are (or become) ineligible for the NDIS, but who need more help than is and will be available through mainstream services.

Allied health providers: get up to speed on the key NDIS reforms that will affect your practice (a free resource)

Allied health providers must review services for young participants to ensure they’re NDIS supports

Will NDIS reforms and foundational supports trigger the end for many paediatric allied health clinics?

Allied health NDIS providers: back yourself to try new things, and help more people: a case study

The 1st Foundational Supports Consultation has kicked-off. 8 things allied health NDIS providers need to know

David Kinnane · 25 September 2024 · Leave a Comment

The Australian Government has kicked-off the consultation on Foundational Supports. As allied health NDIS providers, we’re following these developments closely because they have the potential to change our clients’ NDIS access and funding arrangements and, consequently, our service-delivery and general business models to support NDIS participants and others with disability.

On 20 September 2024, I attended a helpful webinar about one type of Foundational Supports called General Supports. I then reviewed the related General Supports Consultation Paper.

In this article, I’ll explain what the term “General Supports” means, and highlight my key takeaways for allied health providers from both the webinar and the consultation paper.

First, some context (because there is so much going on in the NDIS space!)

In 2023, the Independent Review into the NDIS recommended that governments fund and deliver foundational supports. They recommended that foundational supports would:

be additional supports to those delivered through the National Disability Insurance Scheme (NDIS) or through mainstream services; and
be available to all Australians with disability, whether they are NDIS participants or not; and
interconnect with existing mainstream services, like mainstream childcare and schools.

More specifically, the Review recommended governments deliver foundational supports for people with disability into two areas:

general supports to deliver access to trusted information and advice and build the capacity of all people with disability, including to fully participate in the community, and to make decisions and advocate on issues that impact them. General supports would also include information, advice and supports for families, carers and kin, and community organisations.
targeted supports to operate between inclusive mainstream services (for example in areas like early childhood, schools and community mental health) and the specialist supports accessed through the NDIS. These supports would focus on helping certain groups of people that are not accessing or not eligible for support that is delivered through the NDIS, in areas where the need is greatest.

In December 2023, National Cabinet agreed to design and jointly fund Foundational Supports, where appropriate, through existing services, with a view to phasing them in over time.

On 19 September 2024, the Government released their Disability Reform Roadmap for 2024 and 2025, stating that phased implementation of Foundational Supports will commence in 2025-2026. According to the consultation paper, the Australian Government expects that governments will agree a Foundational Support Strategy later this year (2024).

Key takeaways for allied health providers:

1. Narrow scope

For service delivery and business planning purposes, allied health providers are most focused on what targeted supports may entail in the delivery of our services within mainstream and community settings. However, the consultation paper and webinar cover only general supports, with the consultation paper focusing mainly on information, advice and capacity building supports for people with disability.

2. For many people with disability, the stakes and stress-levels are high

This was made clear when the webinar hosts shared the contact details for Lifeline.

In a vacuum, everyone might think that general supports are a good idea (and they are). But consultation on foundational supports is taking place in parallel with major legislative changes to the NDIS to restore “the original intent of the NDIS to support people with permanent and significant disability within a broader range of supports” (page 21). The reforms are also being carried out to ensure that the NDIS is financially sustainable, with implications for both existing and future NDIS participants.

The webinar hosts were adamant that:

the NDIS is here to stay;
foundational supports (including general supports) are additional supports so that the NDIS isn’t the only lifeboat in the ocean; and
any NDIS rule changes would not take effect until foundational supports are in place.

The consultation paper also makes it clear that accessing General Supports should not preclude someone from accessing the NDIS or other supports in the community (page 6).

But, with the new NDIS Amendment Act due to commence on 3 October 2024, some people are understandably worried that new “sustainability measures” (like the new concept of “NDIS support”) will reduce support for some participants before alternative supports can be put in place.

Time will tell.

3. People with disability should lead the design of General Supports

According to the consultation paper, general supports will include:

trusted information about disability, rights, and services;
supports and tools that build the skills, capacity and independence of individuals to make and sustain social networks and community connections, to make decisions (including supported decisions) and to advocate on issues that impact them;
information, advice and supports that empower and build the capacity of families, carers, and kin in supporting people with disability to participate and exercise choice and control over their own lives;
assistance to find and access mainstream, community or disability-specific services and activities appropriate to needs and goals;
information and advice that assist community organisations and non-government public services/activities to become more inclusive and responsive to the needs of people with disability (page 6).

Once implemented, these supports will be available nationally, will connect with other services, and tap into local community knowledge and networks.

As multiple webinar speakers noted, each person with disability is the expert on what they need, and what works for them. Discussions about accessibility and inclusion often include sweeping generalisations about what we think people with disability need, e.g. “more visual supports”. But, as Jane Britt, senior consultant and advisor of The Social Deck, highlighted, different people need different things. For example, someone who is deaf and blind is not going to be helped by visual supports or maps, and would – obviously – prefer information to be presented in a way they can access and understand. When encountering an obstacle to participation, a person with disability might need information about their rights and who to contact to enforce them.

It’s obvious, but needs to be said: different people have different needs and goals. But, as leading disability advocate Dr George Taleporos noted, common themes underpinning the consultation paper include empowering people to live independently and autonomously, to exercise choice and control, to live with dignity, to understand their rights, to self-advocate, and to participate, and to increase peer and other networks to to reduce isolation, and eliminate abuse and neglect.

Importantly, for allied health providers, people with disability should be able to access our services that are relevant to their needs and goals.

4. The design of General Supports will not start with a blank slate

A wide range of services and supports already exists, including the Information Linkages and Capacity Building (ILC) program, the Partners in the Community program, and the Disability Gateway.

For communities, workplaces, and schools who want to take action to be more inclusive, other resources are also available, e.g. via this helpful list of inclusion resources on the International Day of People with Disability website.

In the consultation paper, there’s not a lot of detail about the perceived deficiencies of the existing systems and resources. But it is apparent from the Independent Review recommendations, that, as things stand, we can do better. For example, the consultation paper writers note that, at present, “there are limited supports focused on early intervention, prevention or low intensity support needs for certain groups of people with disability that are not accessing or not eligible for support through the NDIS” (page 22).

General supports may include reforming some of these existing programs and services. But they are also likely to include additional programs beyond supports delivered through or in partnership with the NDIS.

5. Allied health providers shouldn’t wait to make their services more inclusive and accessible

As providers, we all need to work harder with people with disability (including our clients) to ensure our allied health services are inclusive and accessible to everyone, including people with disability and their families, carers and kin. We also need to understand the rights of people with disability; and to train our staff so that they understand people’s disability rights, too.

If we have knowledge gaps, we need to educate ourselves about the rights of people with disability. We should also share resources and best practices with each other to avoid reinventing wheels.

General supports may help us to do this. But lots of good information and resources exist to improve our understanding of disability rights and to get good ideas to improve the accessibility of our services (including here and here and here).

We all have a role to play in helping people with disability to access the allied health services they need, when they need them, and in a way that:

works for them;
respects their legal rights; and
reflects their goals.

This includes:

providing people with disability and others with accessible information about our team and services. We may need to provide this information in multiple ways, e.g. on our websites, via digital apps, through online chat and phone services, with links to quality information and resources about disability and childhood development relevant to our clients and services (see, e.g., page 9);
increasing our focus on providing services within local community settings to help build the capacity of community organisations like sports groups and arts groups to support people with disability (see, e.g., page 13); and
connecting people with disability to trustworthy information, tools, resources and other services as general supports progressively roll out.

We can all improve accessibility, and we can start work now. As allied health providers, we should lead the way by example.

6. Help your team get up to speed on core concepts

Appendix A of the consultation paper (pages 17-23) includes a very helpful glossary of terms relevant to Foundational Supports and the NDIS. While most allied health providers will be familiar with most terms, it’s a potentially helpful tool for training staff. It’s also a helpful reminder that we all need to be mindful of the language we use, even when fiercely debating the pros and cons of potential reforms.

7. Caveat: everything is subject to intergovernmental agreement

Page 3 of the consultation paper includes an important note for service providers:

“Any future funding opportunities will be promoted via normal procurement/commissioning and grant round mechanisms and will take into account transitional arrangements associated with reforms to existing programs. As the concepts in this paper have not yet been agreed by governments, they have no status within the provider market and should not be relied upon.” (Our emphasis.)

8. Get involved!

The consultation period closes on 30 November 2024. This is the first consultation on Foundational Supports, and may have knock-on effects to consultations for other supports, including Targeted Supports. You can give feedback in lots of ways, including via the DSS Engage website and/or by filling in an online questionnaire.

Key source:

Foundational Supports | engage.dss.gov.au

Our related articles:

Will NDIS reforms and foundational supports trigger the end for many paediatric allied health clinics?

NDIS “ins and outs” for participants seeking “mixed” disability, health and education supports: mind the gaps between NDIS and mainstream services

Paediatric allied health providers: let’s tackle our NDIS worries by improving our services, bit-by-bit, and monitoring general reform trends

Our new and updated NDIS provider resources:

NDIS Provider Human Resource Management System and Registers (HR System) Template

NDIS Worker Screening Policy and Risk Management Plan Template

NDIS Service Agreement Template 2024-25

Will NDIS reforms and foundational supports trigger the end for many paediatric allied health clinics?

David Kinnane · 22 August 2024 · Leave a Comment

Some of our best private allied health clinics have shut down. Others may soon follow suit.

NDIS red tape and frozen price limits are part of the story. So too, are rising fixed costs, wages, and all the uncertainty about future NDIS registration requirements.

But, for allied health professionals operating clinics supporting children, there’s another source of uncertainty: the government’s proposal to create a new “foundational supports” regime for children with developmental concerns, delays or disability, and their families. These will be much-needed supports for children who have significant needs but do not – or will no longer – qualify for access to the NDIS. As yet, little is known about how they will work in practice.

Sounds like a good idea. So why the worry?

Many allied health services operate from small private clinics based in local communities. Many of these clinics are operated by sole traders, families, and small businesses. For many clinics, NDIS participants make up a sizeable part of their current caseloads, enabling owners to invest in improving their services, supervising and training staff, and keeping their lights on.

As proposed, foundational supports will:

sit outside the NDIS and operate as a separate tier of services between mainstream services (like childcare and education) and NDIS disability services; and
be funded jointly by federal and state governments.

Allied health providers who currently offer in-clinic NDIS-funded services to support children with developmental concerns, delays or disability are vulnerable to these regulatory changes because, if implemented, the reforms will see:

fewer children admitted to the NDIS as participants (i.e. fewer NDIS-funded clients); and
at least some in-clinic services replaced by services to be delivered in mainstream settings like childcare centres, preschools or schools.

Recently, Professionals & Researchers in Early Childhood Intervention (PRECI) published an interesting discussion paper on the foundational supports. If you own or work in an allied health clinic, it’s well worth a read.

As a clinic owner, a couple parts of the paper jumped out at me:

“Foundational supports should be embedded in mainstream settings and service systems and not be provided in clinical settings.” (p10.)
“Many service providers will need to refocus their services, retrain their staff and form new partnerships with other services. This will take time and a phased transition may be needed to avoid too much disruption.” (p12.)

My key takeaway: although it seems early, allied health clinic owners who support children with developmental concerns, delays or disability need to start rethinking their service delivery and business models to make sure they can adapt and stay in business.

How did we get here?

As the PRECI authors note,

“the current service system may not be fit for purpose….There are lots of resources and services but they do not form a coherent system that ensures that all families of young children get the support they need in a timely fashion. Services are funded and delivered in silos, not in an integrated way that enables them to respond to the needs of families in a holistic way.” (p10.)

Before the NDIS was a thing, states and territories were responsible for most publicly funded childhood intervention services for young children with developmental delays and disabilities. These services were limited, and some families elected to pay for private services, like speech pathology, occupational therapy and physiotherapy, often with the aid of Medicare and other rebates and schemes, and/or private health insurance.

When the NDIS came in, states and territories withdrew or significantly curtailed their services for children with developmental concerns, delays and disabilities. Understandably, many families of young children sought support for their children from the NDIS, resulting in an unexpected number of child participants. To borrow Bill Shorten’s phrase, for many families the NDIS was “the only lifeboat in the ocean”.

The resulting spike in the number of children admitted to the NDIS, and surge in demand for allied health services, and the atrophy of public sector services, increased the number of allied health professionals entering the private sector workforce to support paediatric NDIS participants, either through services delivered in homes, mainstream preschools and schools, in clinics, or both. The growth of the allied health industry was propelled further by a rapid increase in the number of universities offering allied health degrees to students (with government encouragement). Many allied health students and graduates are now trained and supervised in private sector clinics.

No one thinks the current system is perfect

Truth be told, it’s a bit of a mess. As the authors of the PRECI paper note, at least 10 recent or ongoing government reviews have focused on early childhood and/or disability services, with consistent findings that the market for childhood services is not delivering inclusive, timely, accessible help for children who need it. Silos operate across different government programs, with a lack of communication and coordination within them.

We all want better services and outcomes for children; and we all know NDIS reforms are necessary. Foundational supports are a good idea in theory. But the lack of detail makes it very hard for clinic owners to plan businesses and develop new service delivery models. This uncertainty is a disincentive to invest in clinic facilities, equipment, training, supervision, and teams. It’s easy to see why some clinic owners – already struggling to stay in business – might conclude that it’s just all too hard and exit the sector.

Don’t panic, but prepare for different scenarios

Although clinic owners working with children should start thinking about contingencies, the PRECI authors note that:

“[t]he transition to a service system that provides general and targeted foundational supports is a major undertaking…This will take time and a phased transition may be needed to avoid too much disruption.” (p12.)

“Many service providers will have a vested interest in participating in a new stream of foundational support services and funding. Care needs to be taken to ensure that their legitimate needs for an income stream do not outweigh the need to create a system that works for children, their families and communities.” (p13.)

As the late Charlie Munger once said: “The iron rule of nature is: you get what you reward for.” Incentives go a long way to explaining why we have so many private allied health clinics and so few public service systems; and why disability services and mainstream services (like health and education) operate as separate fiefdoms at state and federal levels, despite being so interconnected.

Governments know they need to move carefully, and that, if they change the incentives in one part of the system, they will change the system. They also know that, in complex adaptive systems, like disability, health and education, a change in one part of a system may have unintended and unpredictable knock-on effects for other parts of the system – and any other systems it interacts with.

State governments, in particular, face two major challenges: budgetary constraints and a service system challenge, e.g. about where the services will sit in early child education and care, health, education and welfare systems. For example, state governments will need to invest significantly in facilities, personnel, and systems to facilitate service delivery in mainstream settings.

The “real world” constraints and barriers to change associated with the current systems and access to mainstream settings should also not be underestimated. Child services and government support and regulation at the state and federal levels are highly interconnected. The predicted effects of major policy change must be assessed across the whole system.

Clinic owners are not alone: connect with others to make sure our voices – and the voices of the clients we serve – are heard

Some allied health peak bodies are on the case. And some terrific private allied health initiatives have been launched to raise awareness of the issues and to ensure our voices are heard. For example, check out – and follow – the important advocacy work of Yellow Ukulele, a consortium of seven allied health businesses across NSW, Victoria and Queensland.

Demand for allied health services from families of children with developmental delays and disability will remain strong because evidence-based allied health services help children to participate and are a good thing in the world. The key questions are whether and how various supports will be funded, how they will be delivered, how accessible they will be to children and their families, and what any new tier of disability services will mean for our service delivery and business models ‘on the ground’.

For those of us who own and work in clinics, it’s not too early to think about rebalancing our service mix to reduce risk, retraining our teams to deliver services in different ways, and forming new partnerships with other services. If we learned one thing from the pandemic, paediatric allied health professionals are adaptable to big changes while working within imperfect systems – with all their cost and time constraints – to deliver quality care to children who need it.

Recommended reading: Professionals & Researchers in Early Childhood Intervention – Foundational Supports for young children with developmental concerns, delays or disability, and their families: Discussion Paper (1 August 2024)