NDIS

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

Allied health providers: prepare for NDIS reforms with an updated Incident Management System

David Kinnane · 31 October 2024 · Leave a Comment

The challenge:

To increase safety and quality, NDIS providers should have clear incident management systems to record and manage incidents that happen while providing supports and services to people with disability.
But the rules are complicated, and the guidance is very detailed.

Why it matters:

The NDIS (Incident Management and Reportable Incidents) Rules 2018 require registered NDIS providers to have incident management systems.
The NDIS Quality and Safeguards Commission says that:
- it is good practice for unregistered-providers to have an appropriate and effective incident management system for all participants; and
- having policies and procedures about incident management is a feature of quality practices providing support for children in the NDIS.
NDIS reforms may mean that many unregistered providers will have to implement incident management systems in the near future, and it’s a good idea to prepare.

Yes, but:

Translating the rules and guidance into plain English is time-consuming.
A blank page can be paralysing, and lead to procrastination.
It’s hard to tailor a system to the needs of your participants and operations without a solid base.

Get started:

Check out our updated, plain English Incident Management and Reportable Incidents System Policy and Procedures Template.
Written for small and medium-sized providers who are determined to improve support quality and safety.
Fully editable, so you can tailor it for your needs, and the needs of participants, and workers.

Coming soon:

On-demand worker training for incident management to ensure key personnel and all workers understand the system and their key obligations.

NDIS Incident Management and Reportable Incidents System Policy and Procedures

National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018

NDIS Commission Guidance on Incident Management Systems Guidance

Quality support for children in the NDIS

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

David Kinnane · 10 October 2024 · Leave a Comment

The big picture:

Under new rules, allied health providers cannot be paid by the NDIA for services that are not ‘NDIS supports’.

Context:

‘NDIS supports’, as defined in the new section 10 of the NDIS Act 2013 and Schedule 1 of the NDIS (Getting the NDIS Back on Track No.1) (NDIS Supports) Transitional Rules 2024, include:

early intervention supports for early childhood (0-9 years) (Item 17); and
therapeutic supports (Item 34).

What to watch:

Allied health services must (of course) be evidence-based. In addition:

early intervention supports must help the child and their family achieve better long-term outcomes for the child (item 17); and
therapeutic supports must help participants improve or maintain their functional capacity (item 34).

What we’re doing:

We’re working with clients and families to review assessment, reporting, goal-setting, and therapy workflows to ensure our services are NDIS supports. To structure our review, we’re using the following frameworks:

Go deeper:

For more information about NDIS reforms, check out our free webinar.

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

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

David Kinnane · 20 September 2024 · Leave a Comment

Experts tell us that constraints are good for innovation. If this is true, all the constraints imposed on allied health providers during 2024 should trigger an earthquake of innovation in our sector.

Although painful, this could be a good thing for providers, participants, other clients, and families. But…

Innovation is such a terrible buzzword!

Even typing the word made me cringe, with flashbacks to my corporate law days. And innovation in healthcare is poorly understood. As John Glaser taught me many years ago:

innovation doesn’t require us to invent stuff: Most allied health providers lack the time, money, and energy to create a pipeline of inventions. But that’s OK: there are plenty of other people’s inventions waiting for allied health providers to adapt them for our purposes;
innovation doesn’t require radical changes: Continuous, incremental service tweaks make more sense in uncertain times like now. Over time, they can compound to deliver big improvements for participant care; and
innovation isn’t a goal in itself. Innovation only makes sense if it contributes to our purpose.

So, how should we go about doing it in the real world?

Here’s a little case study to show you how we’re trying to do it in our practice:

1. Go back to the mission

Sometimes, as I pore over government press releases, consultation papers, expert reports, white papers, guides, and social media think pieces, I forget that navigating NDIS reforms isn’t actually my job.

I’m a speech pathologist running a single-site, independent clinic in Sydney. I started Banter Speech & Language more than 10 years ago to help children and adults with neurodevelopmental disorders and disabilities.

My special interest is helping people with significant communication challenges to speak, read, and write for themselves. My practice exists because I want to support clients to pursue their interests; and to participate fully at school, work, and out in the community – just like everyone else.

Six days a week, my wonderful team works hard to deliver quality, evidence-based support to clients in the clinic and by telehealth, including NDIS participants.

But we have a problem.

2. Identify something specific that’s getting in the way of the mission

Every workday, we field queries from all over Australia and overseas from families with children with disabilities who are struggling to access the help they need when they need it.

Many obstacles to access aren’t new. Mainstream education and health support for children with neurodevelopmental disorders and disability remains patchy. Too often, the NDIS is the only way for children to access help. In the real world, NDIS access and funding rules favour some children over others. (Different diagnoses, postcodes, and abilities to navigate “the system” mean that different children with similar functional needs get very different levels of support.) Because of disability, many children have health, education, and disability needs; but health, education and disability systems operate independently, with uneven levels of support depending on where they live. (This is one of the main problems underpinning the government’s decision to move forward on Foundational Supports.)

As a small provider, these systemic problems seem insurmountable, and far too abstract to do anything about. To avoid paralysis, we need to:

3. Get more specific until we find a concrete problem

Here’s an example. For privately-funded families, we deliver evidence-informed writing interventions for students with neurodevelopmental disorders, including autism, developmental speech sound disorders, developmental language disorder, specific learning disorders in reading and writing (better known as dyslexia and dysgraphia), and ADHD.

Writing instruction is considered a “mainstream educational service”, and thus outside the NDIS (including under the proposed transitional rules). But, for students with disabilities, an inability to write is also a health and disability issue that interacts with their primary speech, oral language and social communication difficulties to reduce participation.

Literacy improves work, health, and life outcomes. And writing is an essential part of literacy. Learning to write gives children a big boost at school, and later at work and in life. Writing helps children to remember things; to connect their day-to-day thoughts to their goals and plans; to communicate what’s going on to their friends, family, teachers and employers; to share and develop their ideas with others; and to think and advocate for themselves independently.

So, writing interventions create many challenges for our families and team. They are:

in high demand by many families, including families of children with disability;
unfunded by the NDIS, meaning many children across the country simply can’t access any help;
time-consuming: most of our clients have lots of other challenges, too, including with their speech, oral language, and social communication skills;
expensive to deliver: many clients with disability need lots of direct teaching, modelling, repetition, scaffolding and spaced practice to master foundational writing skills; and
not carried out in the child’s “real-world”, e.g. at home or school.

To complicate matters, post-COVID, we started to be approached by lots of parents who were keen to help their reluctant writers overcome their writing challenges, including children in mainstream education settings; and children who were not in a mainstream school system (including home-schooled students). We wanted to help. But this spike in demand created havoc with our waiting lists.

But, despite all these challenges, we know that early writing interventions can make a big difference for short-term academic and social participation and longer-term work, health and life outcomes.

4. Be brave. Try and test new ideas

All these events and observations gave us the idea and motivation to launch Rally Writers.

It’s an online project to increase access to writing help for children. It’s for school-aged children – with and without disability – who need extra support with their writing for any reason. It’s self-paced, and can be worked through in natural settings like home or at school, one-to-one or in small groups, with or without an adult in the room.

Rally Writers is a labour of love that I work on during weekends and evenings. It’s designed to be affordable, not dependent on NDIS-funding, and suitable for children and teenagers.

To date, we’ve released three modules (or “Cups”): for simple, compound and complex sentence writing. (We see far too many children and teens who can’t write complete sentences.)

Start Your Engines: How to Write Simple Sentences

I’ve written five additional modules: for writing paragraphs, information reports, narratives, persuasive writing foundations, and advanced persuasive texts, which will be released progressively over the next year or so (when I find time to record them!).

For existing clients with disability, we can now spend our time in sessions on speech, oral language and social communication goals, and provide free access to our Rally Writers resources so they can work on writing at home.

If you are interested in the project, you can check it out here:

Rally Writers: we help reluctant writers

5. Stay open to feedback (including from other colleagues and other providers!)

Rally Writers is an example of a small, controlled experiment, adapting existing technologies to increase access and decrease costs in pursuit of our mission.

As part of the project, we’re actively seeking client and other feedback to make it better as we go. We expect it will undergo several iterations as we incorporate suggestions and get better at using technology.

If you have thoughts about Rally Writers, or this little case study, please get in touch!