Independent Assessments and Changes to Plan Budgets

Introduction – NDIA Release Discussion Paper

On 3rd of June, the National Disability Insurance Agency (NDIA) released a discussion paper titled “Personalised Budgets: Proposal for a new NDIS budget model”.  The discussion paper was released partly in response to the ongoing concern that the disability community have with the proposed introduction of Independent Assessments and the use of 400 model persona’s in determining participant funding levels. 

The NDIA believe that the proposed approach will address three main issues the Scheme currently faces, being: 

  1. Participant Experience – we want to lower the effort, cost and anxiety currently being reported by participants, their families and carers. 
  2. Fairness and Consistency – we want to make the NDIS fair for all participants and our decisions more consistent. 
  3. Flexibility – we want participants to have more control over the supports and services they purchase.   

Disability Intermediaries Australia (DIA) shares the concerns of the wider disability community regarding the proposed changes and finds the reasoning of the NDIA to be more than just a little perplexing. 

In our article summarising the key points of the latest NDIS Quarterly Report, DIA Summary of NDIS Q3 20-21 Report, we highlight the obvious inconsistency in the NDIA messaging around function and outcomes. This leads to a review of the planning process and how participants rate their experiences which then logically requires a closer look at the socio-economic influence on budget outcomes. 


DIA believes that a significant body of work is required to be undertaken by the NDIA via committing to genuine consultation, co-design and communication with the wider disability sector as, whilst we all appreciate the NDIA’s attempt with this release, it follows the recent pattern of NDIA communication releases by raising more questions than answers. 

For those still scratching their heads over all of this, DIA has worked through the key topic areas raised in the NDIA paper below.

The Planning Process    

The current planning process is not without its faults and can be stressful for participants, nominees and advocates. What is not clear from these proposed changes is how Independent Assessments will ease this stress.

The overwhelming feeling from our members and the participants they support is that the prospect of being assessed by someone who has no historical context of a participant is likely to be even a more stressful process, with everything riding on how this complete stranger views their functional capability and capacity. 

The NDIA’s participant experience statistics from their own survey, published in the latest quarterly report, are interesting reading in the current context. The NDIA reported that in the March 2021 quarter that:

So, we have over 80% of participants who rated the Pre-Planning and Planning processes as “Very Good/Good” with Access and, not surprisingly, Plan Review recording a lower level of “Very Good/Good” responses but still at circa 75%. 

The NDIA also published statistics from 2018-19 through to Q3 2020-21 showing the trend in the satisfaction of the planning process.  The Planning Process rated consistently at 85% of participants responding “Very Good/Good”. 

Disability Intermediaries Australia does tread carefully in taking the NDIA data as the absolute truth, but it is hard not to question why the NDIA would continually highlight the perceived inadequacies of their current planning process when three years of their own data would suggest that 85% of participants find the process as “Very Good/Good”. 

DIA won’t go as far as saying “if it isn’t broken don’t fix it”, but what we would say is that rather than totally changing the planning process pay attention to the areas that don’t seem to be working, namely the plan review process and understanding of individual personal circumstances, the history of their disability and how NDIS supports can support and enrich their life. 

Socio-Economic Factors Driving Budget Outcomes

The NDIA have raised the significant cost borne by participants in sourcing information for their planning meetings, estimated to be between $130 million to $170 million per year across the Scheme or up to $1,000 per participant, as a major flaw in the current planning process. 

This, according to the NDIA, leads to inconsistent outcomes depending on the participants ability to source and pay for this information. It is interesting that the NDIA’s proposal includes that the cost of Independent Assessments will be paid for by the NDIA and not the participant. 

If the NDIA are prepared to fund Independent Assessments, why would they not consider using those funds to offset participants out-of-pocket costs under the current model of assessment? This could not only reduce the financial barriers participants face but also ease the level of anxiety associated with being assessed by a stranger.

However, what does the NDIA published data say about the “average” budget across socio-economic bands? If you believe the rhetoric from the Personalised Budget discussion paper, you would naturally think that the differences are huge and widespread across the socio-economic bands. The data from the quarterly report would suggest otherwise:

From the bottom 10% (decile 1) through to the bottom 80% (decile 8) the average budget levels are quite uniform (about 2% difference) with a small jump in top 20% and 10% (decile 9 and 10 of between 4.4% to 8.4%). Again, like the planning process, why would the NDIA propose to introduce blanket blunt instruments and change when any inequities should be levelled via targeted reform?   

There has also been no discussion about location of a participants home and associated access to supports. There has been many studies that indicate specialist health and allied health services are more redilly abailiable in more traditionaly affulent areas. This would again likely result in some smaller variabilities in plan package size. I.e. you dont know what you dont know and the same is true for supports. DIA has heard from many participants who have said
“if you dont have a support in reasonable distance from your home why ask the NDIA to fund it as you will not be able to buy it and it will just get cut at the next plan review anyway! If you dont spend it it just gets cut.”

Function, Outcomes and Persona’s  

The second issue highlighted by the NDIA is one of fairness and consistency in planning outcomes. The NDIA believes that participants with similar functional capacity should receive the same amount of funding no matter differing personal goals, situation or location. 

The standardised Independent Assessment process is designed to remove the subjectivity that LAC’s and Planners currently have and therefore equalising funding across similar participants. 

The NDIA points to data that they have collected indicating that participant functionality has decreased over the period from 2017 to 2021. The NDIA links this decrease to the provision of inconsistent information and a lack of a consistent approach to planning. 

On the surface this would be an alarming trend, participants entering the Scheme and experiencing a decrease in functionality is akin to saying the Scheme has failed! If we look a little deeper and look at another set of published data from the NDIA the picture is not quite so bleak.   

Once again looking at the 2020-2021 Q3 Quarterly Report, the NDIA reports that participant outcomes have increased across four broad age cohorts (0yrs to school, school to 14yrs, 15yrs to 24yrs and 25yrs plus) over a four-year period. This seems to be at odds with the function data that is being used to justify the introduction of the Personalised Budget process. So, if we are to believe the NDIA without question, participants are experiencing a decrease in functionality and are happy about it? Something just does not add up here. 

The second plank of building Personalised Budgets is for participants to be mapped to one of 400 “persona’s” that have been developed by NDIA “experts” from selected participant data. Essentially, participants would be assessed by a stranger and then mapped to a pre-existing profile when their funding is being determined, hardly what would be described as “Personalised”. 

In the discussion paper, the NDIA provided five example profiles that range across age and disability. Taking just one of these, Example 1, highlights an apparent lack of individualisation that this process represents. 

What struck DIA in this profile is that although “Tilly’s’”  Communication and Learning needs are Moderate, and Self-Care and Self-Management and Mobility are Mild, she requires no Social Interaction supports! 

DIA stands with the broader disability community in condemning the use of “persona’s” that effectively place individuals into predetermined boxes that can not represent the individual needs of a person living with a disability or their individual circumstance. 

True Flexibility Welcomed, But….

The one element of the discussion paper we would applaud is the commitment to genuine flexibility for participants over their funding.  The NDIA are correct in saying “participants are the experts in the supports they need and should have as much control as possible over their NDIS funding”.

The elephant in the room and the massive “however” is the fact it is hard to escape the significant tone of the desire to control the overall funding levels: “we will have fewer rules but more consistent overall total budgets to support participants to pursue their goals”. Does this mean you can spend your package wherever you like but your package will only cover the basics? How will this help to level the divide between the lower and socio economic cohorts?

We also find it curios that the NDIA is publicly stating that they want to provide greater flexibility for participants to spend their plans, however in recent times the NDIA continue to reduce flexibility in where and how a participant can spend their plan funds:

The theme of “Scheme sustainability” is prominent throughout the discussion paper with the NDIA claiming that the current subjective approach is driving the “total cost of the NDIS could exceed expectations through high plan inflation.” 

It is hard to think anything but an intention to reduce plan funding when the NDIA make statements such as: “Personalised Budgets will also help us to better manage the total cost of the NDIS. They will allow participants to get a fair amount of funding, while making sure the NDIS is affordable for the future.” As we have shown from the NDIA’s own published data, there appears to be little justification for the proposed changes from a participant experience and outcome perspective. True plan flexibility is welcomed but how effective will this be with reduced, limited or more tightly controlled funding? 

You Say Consultation? We Say….

Possibly the most disappointing element of the discussion paper is the notion that the NDIA have “consulted” during the development of the Independent Assessment and Personalised Budget model, with the CEO stating in the introduction of the paper “… deeply regret our genuine attempts to share information about the changes, and consult on them have not met expectations”. 

Although the recognition that previous communication was below expectations is welcomed, DIA would disagree that the NDIA made ‘genuine attempts to consult and share information as evidenced by the broad outcry that has resulted.  

The CEO also recognised that “I know the proposed NDIS reforms have caused real fear and concern in the community.” This recognition of fear and concern has not yet translated to any significant changes to the proposed budgeting process, so what does this statement mean? 

The NDIA, in the discussion paper, has committed to an “ongoing consultation process” with the proposed model being subject to a review and validation process. What is disappointing however, is the apparent lack of genuine consultation with the broader disability sector. The NDIA have outlined the following consultation approach:

  • Independent and external sector review with members of the Independent Advisory Council, and other members of the disability sector where appropriate.
  • Review by experienced NDIA staff, who have specific and thorough knowledge of disability types and needs such as psychosocial disability, autism and intellectual disability. 
  • External actuarial peer review of the technical actuarial modelling used to develop the model, to ensure technical accuracy.

DIA calls on the NDIA to undertake a broad and genuine consultation process in regard to the proposed changes and current challenges faced by the Scheme and would welcome the opportunity to represent our Members’ concerns on these matters. 

It is the Law…

The significance of the proposed changes is reflected in the fact that for them to be implemented the NDIS Act must be amended. Any change of Legislation is required to be passed by both Houses of Parliament and would require bi-partisan or crossbench support in the Senate to be successful. 

There is currently significant opposition to these changes from the opposition and crossbench members of the Senate and therefore it would be highly unlikely that the current changes would be passed successfully. 

There are also divided opinions amongst the members of the Government. DIA will continue to directly advocate across the political spectrum on behalf of our Members reflecting their concerns with these proposed changes.