The Australian Psychological Society (APS) provided a submission to the Department of Health, Disability and Ageing's consultation on NDIS Access Changes. The APS provided a set of ten Psychologically Informed Principles for NDIS Reform, intended to apply across the concurrent NDIS reform consultations, and any that follow during this period of change.
Our submission made the following key points:
- A consistent, cross-consultation approach is needed. Although NDIS reform is being progressed through several concurrent consultations, a core of psychologically-informed principles applies across all of them. Our principles are intended to guide policymakers in designing and testing rules and exposure drafts, and give the APS and others a consistent basis for assessing the design and lived impact of reform, individually and cumulatively.
- The Department's draft guiding principles are a sound foundation. They align with our principles and previous submissions which highlight the importance of meaningful co-design, equity and cultural safety, psychological safety, and adaptive design. Our principles on functional understanding and evidence integrity bear directly on the consultation's questions about assessment design and the evidence required to determine permanence and the effect of treatment.
- Standardised tools must be paired with professional judgement. Approaches to the assessment of functional capacity should capture both what can be observed and how the person experiences their own capabilities, including the effect of fatigue, distress, trauma and fluctuating or less visible impairments. There must be opportunities for the the open and supported development of the evidence base in relation to standardised tools, and the limits of both the tools and evidence must be acknowledged transparently.
- Some important considerations are not yet addressed. The APS encourages the Department to consider relational continuity, agency and control, supported decision-making, and workforce sustainability when finalising the access principles. These are especially relevant as current participants are reassessed over the transition period.
We welcome opportunities to work with the Department and the Technical Advisory Group on Functional Capacity as NDIS access reforms continue to be developed.
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