The Introduction of Compulsory Independent Assessments to the NDIS
Please note: The NDIA have delayed the implementation of independent assessments and are now seeking community feedback in a consultation process. Read more about the changes and how you can make a submission here. The original blog post is below.
The Minister for the National Disability Insurance Scheme (NDIS), Stuart Robert, recently announced that compulsory independent assessments will be introduced for individuals applying for the NDIS. By early 2021, independent assessments will be part of the access process for the NDIS. The NDIS has stated that the introduction of these independent assessments aims to provide an understanding of functional capacity and the overall impact of a person’s disability, to allow the NDIS to make more consistent decisions.
However, independent assessments mark a major change for people applying for the NDIS and for existing members. This change has brought about a lot of uncertainty and valid concern within the FASD community.
What are Independent assessments?
- Independent assessments aim to provide understanding of the individual’s functional capacity as well as the overall impact of the disability on their lives.
- When accessing the NDIS, individuals will be referred to an independent assessor.
- These independent assessors are funded by the NDIS but are separate from the agency and made up of a range of health professionals.
- Wherever possible, individuals will have a choice of assessor and organisation that can deliver the assessment from a panel of assessors involved with the NDIS.
- A support person or treating health professional may be present.
- For individuals under 18, part of the assessment will be conducted with them and their parent or carer and part solely conducted with the parent or carer.
- Independent assessments will be free.
- The assessments may take 1-4 hours and can span over a number of days.
- Independent assessors will use standardised assessment tools based on the individual’s age and disability.
- The results of the independent assessment will be sent to the NDIS and be used to identify supports and funding.
What concerns have been raised?
A number of concerns have been raised by disability advocates who fear that the roll-out of independent assessments will add another layer of challenges for families applying for NDIS supports and funding.
People with disabilities build trusting relationships with their chosen allied-health and medical staff, developing a mutual relationship and understanding of the disability and the individual’s needs. With independent assessments, individuals are expected to work through standardised tools to capture their circumstances within a 1-4 hour time frame, with an NDIS appointed assessor. This can place pressure on participants who may not feel comfortable disclosing information to individual assessors who they do not know.
In some cases, independent assessments have been as brief as 20 minutes. This is alarming as it is unlikely that a professional could assess and capture an individual’s circumstances and needs accurately within such a short timeframe. For many people who access the NDIS, including individuals impacted by FASD, cognitive impairments and support needs are complex. For someone with FASD, who lives with three or more domains of cognitive impairment, the domains of impairment are interactive. Looked at in isolation, a moderate impairment in a cognitive domain may not look remarkable, but the domains of impairment experienced by those with FASD impact each other, often with an exacerbating effect. Sensory processing difficulties also strongly impact cognitive functioning and daily living.
Concerns have also been raised about the standardised assessment tools. There is worry about whether these tools are appropriate for individuals with disabilities such as FASD. In addition, standardised assessments have been criticised as being unsuitable for individuals who are culturally and linguistically diverse. The NDIS have selected 6 assessment tools through research and testing coined the ‘Assessment toolkit’. As part of the independent assessment, NDIS participants will undertake 3 or 4 of these assessment tools based on their age and life stage. Read details about the assessment tools here.
The NDIS states the tools chosen demonstrate “strong evidence for reliability and validity, are practical to administer, and work together to describe the person’s functioning including capacity, performance and environmental factors in a holistic way” (see NDIS for more). The concern is whether these tools will be accurate at assessing the diverse needs of people with disabilities. Criteria for the assessment toolkit states that “it should be possible to use the assessment tools across all disabilities” and that the toolkit “assesses functioning and not impairment”. This may pose a challenge for individuals impacted by disabilities like FASD. For example, individuals impacted by FASD often experience age dysmaturity, where some skills and abilities develop at a faster rate than others. This means that an individual could have communication skills which make them sound like they have the capacity of a 20-year-old, but their comprehension skills may be at a developmental age of only 6. Factors like this may adversely impact the assessment, producing inaccurate results and creating barriers to accessing appropriate supports and funding.
An example of age dysmaturity – Chronological age vs developmental age
Another concern raised by people in the community is whether or not independent assessors will be informed enough about the disabilities they are assessing. The NDIS has given assurance that independent assessments will not remove or replace treating medical or allied health staff. Moreover, the NDIS emphasises that the assessments are one piece in a collection of supporting evidence that is considered when making decisions. The NDIS has stated that no material will need to be produced at the assessment, rather treating medical or allied health staff will be involved with directly providing important information relating to the disability and diagnosis (See NDIS for more). However, not much information has been given about how knowledgeable the chosen independent assessors will be. The NDIS has stated that an open and competitive tender process will be conducted to source the assessors and that assessors will be extensively trained and may only conduct assessments within their profession. With disabilities like FASD the effects vary considerably and require full assessments from multidisciplinary teams (read more). Thus, how informed the independent assessors are on FASD remains a primary concern for those in the community, including parents and caregivers. Read more about concerns here and here.
What implications does this have for participants who already have NDIS plans?
The NDIS has stated that gradually all participants will be independently assessed. Existing participants will be independently assessed when experiencing major life transitions such as leaving school, starting a new job or moving out. Independent assessments will also occur for existing participants if there is a major change in circumstances or supports needed.
Ultimately, many individuals within the community are concerned about the impacts that independent assessments could have. Community members have major concerns that the implementation of independent assessments will not be in the best interest of the individuals it aims to serve. Every Australian Counts are taking these concerns to MPs in Canberra.
The NDIA has responded to community concerns, delaying the implementation of compulsory independent assessments and seeking community feedback. Click here to read about the consultation papers and how you can make a submission.
At NOFASD, we conducted a survey asking if families are concerned about these changes and how they think they might impact families. The survey results are being compiled into a report to submit to Ministers and other decision makers. Thank you to all those who gave their time to complete the survey.