Interaction is a highly regarded disability service provider, particularly well recognised within the North Western Sydney area of NSW.  Proudly, Interaction’s CEO – Craig Moore – was asked to be one of a limited number of speakers representing disability service providers, at the Joint Standing Committee held in May this year.  This Committee was established by the NSW Government to inquire into, and report on, the provision of services under the NDIS.  Here’s a written version of the address to the Committee made by Craig Moore:

“Thank you for the opportunity to address the Committee. The maturity of a society is often gauged by how well it cares for its most vulnerable, disenfranchised and disadvantaged citizens, and the NDIS demonstrates Australia’s commitment to all its citizens. Interaction fully supports the NDIS.

Interaction is a generalist and specialist disability provider, predominantly covering northwestern Sydney.  Interaction’s specialist support is for people with Prader-Willi syndrome and is internationally recognised, and we are currently expanding interstate. We are a registered NDIS provider and are well prepared for the NDIS. Our governance and systemic processes were ready, and Interaction has now transitioned 95 per cent of its existing clients into the NDIS whilst increasing its market share through supporting new participants into the scheme.

Our most significant concern is that the NDIA has developed non-contextual pricing. In our view, this has happened because of what we believe is a failure to engage wholly with service providers on planning and pricing. This is a misplaced philosophical position based on assumptions that service providers will inflate prices.  These assumptions have never been tested. An example of non-contextual pricing is the significant restriction in what is claimable under the NDIS for a psychologist. The funding gap has been borne by providers, which is not sustainable for all parties.

Interaction has a large team of psychologists. They provide assessment, behaviour intervention support plans, skills training and therapeutic support to people who experience challenging and/or other behaviours, their families and our staff. The breadth of their services is needed to enable the participant to interact with the community without significant support. Well planned and funded intervention of these support services facilitates the NDIS’s intended insurance outcomes of reducing funded supports in the longer term.

Interaction has a number of clients with very complex needs. The number of hours provided for in plans is now significantly less than needed. For example, a teenage boy that was receiving 300 hours per year is now reduced to 22 hours per year. In addition, the pricing is confusing and mainly limited to face-to-face hours. This limitation means that essential and required tasks—such as report writing, service formatting of behaviour intervention support plans, individualised pre-reading and research, coaching of staff, coaching of families and so on—is not covered. Interaction’s psychologists require 44 claimable hours per fortnight to support their role within the organisation. That 44 hours requires another hour or two besides that to actually do the task, which means they do not have enough time per fortnight to actually do the job that they are supposed to do.

I would also submit that non-contextual pricing has other, unintended consequences. For example, the NDIS pricing structure reduces the ability of organisations to attract and induct the expected injection of new staff into the sector. In that regard, skills atrophy has been observed in overseas jurisdictions that have implemented initiatives similar to the NDIS. Investing early and establishing a system where people can access appropriate training reduces participant risk, staff risk and organisational risk.

Finally, Interaction is investing in its Prader-Willi expertise by bringing out international experts Dr Hodebeck-Stuntebeck, chair of the international Prader-Willi carers board, and Dr Hubert Soyer to train key people in bestpracticesupports and outcomes for people with Prader-Willi syndrome. These doctors provide training throughout Europe. This is unfunded, and only made possible by the long-term investment of Interaction in the future of the Prader-Willi syndrome community. Solely funded under the NDIS, this would not be possible.

The NDIA must reassess its approach to training and the inclusion of this in pricing and scheme design in future rollouts, for the sustainability and longevity of the NDIS. Thank you.”