10387 – Organisation submission

This a brief submission to the NDIS review outlining 3 particular issues that are impeding and even stopping NDIS recipients from engaging with our program. This is happening for both new prospective clients and those who have previously been using the program prior to NDIS establishment. For both groups our program is their chosen service to use and for many the only service in this community that they can see meeting their needs.
We currently have 6 NDIS recipients wanting to use our program that are unable to. This is drastic situation that needs urgent attention
The issues are:
Inconsistency of interpretation of NDIS rules and responses from planners, leading to some being able to access the program and others emphatically refused
AND
Restrictiveness and limitations of qualifications only being considered for provider registration, with now allowance for practice experience.
AND
Length of time for the process of reviewing and changing plans.
About our program
Our program is an XXXX assisted therapy program, operating near XXXX XXXX and has a very strong 15 year track record. It is innovative and outside the square of “usual or typical” counselling program offerings and often not in the mindset of NDIS planners, but very much in the minds of NDIS recipients. While our program is innovative in that it brings together differing aspects of human therapy and XXXX XXXX a new way, it is sound in both theory and practice and is not considered “alternative” as many programs might be described colloquially. It is however a very effective therapy alternative to conventional talking therapies. It was externally evaluated in 2015 with outstanding results.
The program was initially established for high risk adolescents, many of whom have experienced trauma eg in out of home care, who were difficult to engage in traditional talking style models of counseling. It was and still is very successful in engaging and assisting this group. Since that time the client group has expanded to include children and adults with disabilities or mental health issues, many of whom are now considered eligible for the NDIS. We operate on a fee for service basis. This model of operation and administration is ideal for managing clients within the NDIS system.
The program also provided counselling support using the model for Black Saturday bush fire survivors from the XXXX and surrounding effected areas between 2009 and 2017.
The reason that many want to use the program is that it provides opportunities for therapeutic engagement and addressing of issues that don’t exist elsewhere for them. Missing out on the program is likely missing out on an opportunity to engage in any effective therapy. For many, other forms of therapy have not worked and there is need for another way to engage. This is being taken away by the inflexibility of the NDIS which is somewhat ironic given it’s charter.
A one young person said “I know it’s counselling but it doesn’t feel like it.
The program process is a powerful and unique engagement tool, that leads to strong therapeutic relationships that are of the foundation of effective therapy. Clients begin by engaging in the issues of XXXX they are helping and easily make a transition to discussing their own life issues and hopes for the future (goals)
Clients come to the program to contribute to the lives of others. The XXXX in the program are recovering from their own life traumas and clients usually enjoy the experience of being in the role of a helper and this opens opportunities for therapeutic conversations that don’t otherwise exist. It becomes a reciprocal helping position where the person learns about emotional regulation, self control, strength without aggression, production of calmness and that it doesn’t have to be hard to talk about difficult things. All while enjoying connections with and helping XXXX.

Our program and the NDIS
At this stage we are in the process of gaining registration with the NDIS which is both a costly and very time consuming. As such we can provide services as a non registered provider for self managed and plan managed clients but not NDIA managed clients.
For a number of previous clients the transition to the NDIS is cumbersome and difficult and even though they state clearly and emphatically that our program is an important and often the only service that has worked in providing counseling support for them, they have been unable to XXXX accepted as a provider in their plans and have been unable to use the service. .

Issues arising with the NDIS
As stated above from our experience of engaging with the NDIS for the past 12 months or so, 3 prime issues have emerged that are consistently making it difficult and even stopping people from attending who are stating our program as a preferred and at times only service option.
These issues are outlined below and we believe they are symptomatic of the NDIS structure and need to be addressed, as they will surely be impacting other people who are needing to access other possible “outside the square” and innovative services

1. Inconsistency of interpretation of NDIS rules and responses from planners
Inconsistency of interpretation within the client planning process, leading to clients missing out on being able to access our program, a service clients state as being needed by them.
Client are finding it frustrating and difficult as they try to access the service. Many have previously been attending the program and when applications are made, responses across different planners are inconsistent with very different interpretations of the rules by planners. The process is enormously time consuming, with waiting periods of many months for trying to have our program accepted and included in a plan or review and change an existing plan to include our program.
We currently have 4 clients who have previously attended the program who are desperate to return because it has worked so well for them, yet they are unable to because of inflexibility of planners who are rejecting inclusion of our program into plans. We believe this is not in the spirit or intent of the NDIS system.
Some clients have been lucky in that flexibility has been shown by planners in interpreting the intent of the NDIS to provide services that meet the needs identified by the client. These planners have sought ways to enable attendance to happen and have managed to achieve this
However this is rare and the majority have not shown flexibility to the idea regardless of the arguments and pleas of the clients, when clearly some capacity for flexibility exists.
There are issues within the equine assisted therapy field in that there is no consistency in standards. This will come in time as this is a new field and I am not suggesting that there should be a blanket approval provided the counselor/therapist provider is suitably accredited to provide the elements of the NDIS as required.
However we believe there must a be a means of looking at new/innovative service options and having them accredited in some way, independently to the many and varied opinions of planners.
Even once we are fully registered we will still have the problem of a planner looking at the list of service options and dismissing an application to approve the service we offer.

2. Qualifications AND experience considered for provider registration
In the case of our program the lead counselor has 40 years experience in youth and family welfare, has a 3 year youth work diploma form the early eighties, grad dip in XXXX, undertaken a I year certificate in Narrative therapy and along the way done various other training programs focusing on counselling. He has worked in management and team leadership and supervision of staff including counsellors. In the program/counselling delivery he regularly co-works with a registered mental health social worker in the team and is the lead counselor in this arrangement. He also receives regular clinical supervision from another registered mental health social worker.
However he has not sought to update qualifications to meet XXXX or any other qualification that would be accepted by the NDIS for provision of counseling, as such he cannot provide this service within the NDIS framework and people are therefore unable to access the service because of this.
Delivering the program and the counseling within it is a very specific skill set that doesn’t come under any of the accepted qualifications with the NDIS
It is our contention that within the NDIS scheme there should be some means of applying exceptional circumstances for the acknowledgement of experience or specific skills rather than simply relying on qualifications for provision of specific NDIS component services.
This would require flexibility within the system to cater for difference and encourage innovation. It would need careful planning for the assessment of competence outside of pure qualifications, when a person and or provider has value to offer to NDIS clients and doesn’t fit with the stated boundaries of qualifications

3. Length of time for the process of reviewing and changing plans.
I don’t intend to address this issue in any length here because I believe it is a well known and documented problem within the NDIS system, that I believe will be significantly addressed in the review.
Suffice to say that confusion and differing interpretations from planners as to what are and what aren’t acceptable as service options, are becoming tangled in the planning and review processes that can take many months to resolve. This has obvious consequences of people not receiving services when needed.