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5 Questions We Wish They Asked: The NDIA Planning Discussion Paper

Submissions to the NDIS Planning Discussion Paper are due in just 2 weeks. The NDIA say they "welcome any feedback" on the paper and, well, Sara's got some feedback.

By Sara Gingold

Updated 15 Apr 20248 Feb 2021

Late last year, the NDIA released their vision for a complete transformation of the NDIS planning process and asked us all for feedback. The proposed changes are outlined in the Planning Policy for Personalised Budgets and Plan Flexibility community consultation paper, which we covered in a previous article. At the risk of sounding overly dramatic, if these proposals become policy, they could fundamentally alter the NDIS as we know it. *Cue climactic music* 

The deadline for submissions, 10 am on the 23rd of February, is fast approaching. With past discussion papers, DSC has tried to contribute to the public discourse with articles that address the questions the NDIA put to the community. The problem this time is that the questions are, well, pretty cringeworthy. For the most part, they completely side-step the integral issues at the heart of the paper. Instead of asking us the rather obvious question of whether we think what they are proposing is a good idea, we are treated to gems like this: 

“How can we best support participants to transition to this new planning model?”

Kind of manipulative, right? 

However, submissions do NOT have to stick to these questions. The NDIA says they “welcome any feedback on the policy as it is outlined in this paper.” Therefore, it is officially open season. 

To help fuel your thoughts, we jotted down some questions we wish they had asked. 



Call me naïve, but if you want to re-design the planning process, this seems like a good question to kick things off. 

The paper proposes the following process: people will receive a draft plan before their meetings. Drafts can only be altered for supports like SDA, home modifications or assistive technology or if the participant has complex support needs. Consequently, under the proposed model, the planning meeting itself would usually have no bearing on the overall plan budget. Instead, meetings would more closely resemble what we now consider plan implementation meetings, an opportunity for participants to discuss how they can spend their funds and what mainstream supports they can access. 

Plan implementation discussions can be incredibly useful, particularly for participants new to the Scheme. But is this what participants primarily want out of planning meetings? If you don’t ask, you won’t know, but here’s an educated guess: people value planning meetings as an opportunity to argue their case, explain their circumstances and connect on a human level with the person who is about to make decisions which will seriously impact their life. Very often, battles do not arise because everybody enters the meeting in a spirit of collaboration. Just in case something does go wrong, however, we have to give people the opportunity to stand up for what they are entitled to. And let’s be real; we don’t actually need to choose between a plan implementation meeting and a funding negotiation. As the famous saying goes: 



We’ve discussed the potential benefits and pitfalls of IAs to death on DSC’s Resource Hub, so there is probably no point in covering old ground. However, a crucial piece of information that’s missing from the consultation papers is how the NDIA plans to transform standardised test results into individualised plans, especially plans that take into account individual contexts, goals and all the complexities that come along with everyday life. 

The bleakest proposition is that assessment scores will numerically correlate to specific levels of funding. We want to be absolutely clear: we have no evidence that this is what the NDIA has in mind. However, the Agency has also failed to present an alternative model that connects the assessments to funding. 

When IAs were first announced, I imagined they would be just one piece of evidence that informs planning outcomes in the same way that practitioner and provider reports currently are. However, this model would still rely on planners interpreting the evidence and using it to make a subjective decision. It seems like subjectivity is exactly the thing that the NDIA would rather avoid. One of the key justifications for implementing IAs is the inconsistent decision making that has been a hallmark of the current planning model. And – no shit – it’s a problem. But is a touch of inconsistency simply the price we have to pay for individualisation and leaving decisions in the hands of humans? Perhaps inconsistency is something the NDIA can (and should) work to mitigate but will never do away with entirely.  



The consultation paper currently suggests participants will be required to have an IA at least once every five years, with the minimum time between assessments being three months. However, this really feels like something that should be open for discussion. Talking about your disability and support needs with a complete stranger can be traumatic, not something you want to be doing on the regular. If the NDIA absolutely insists on making IAs compulsory, we need to have a conversation about how often is reasonable. 

Moreover, the paper suggests that IAs will be required before plan reviews that result in a change to plan funding. The argument is that, if funding is linked to functional capacity, they need to assess a person’s functioning before they can raise or lower funds. But there are many other reasons someone might request additional funding that have nothing to do with changes in capacity. For example, what if someone wants to go from working one day to two days a week? In such cases, wouldn’t a simple planning conversation be enough? 



Under the proposal in the paper, participants would have their funding released at monthly or quarterly intervals. This seems to be linked to the move to longer plans, and there is certainly a case for it. If we were given our salaries in five-year intervals, most of us would be pretty overwhelmed and consequently do a shocking job of budgeting. But you must admit that it is kind of a patronising solution to the problem. 

More importantly, there are significant risks that have not been adequately addressed. Notably, we do not know what will happen if people need to draw on additional funds because of the episodic nature of their disability or temporary changes in life circumstances. The proposed changes allow for unspent funds to roll over into the next payment interval, but not for overdrawing. Therefore, if a person is at the beginning of their plan or hasn’t managed to save up from past payments, then it is not clear how easily they will be able to access additional funding.

To be fair, the paper does say, “if additional funds are required in the first month of a plan, or a participant wants to make a bulk purchase, a higher initial allocation may be arranged and then be offset by smaller monthly allocations.” We are given no details about what the process for arranging for additional funds might look like, and it is possible that the NDIA will design a system that is quick and easy to use. But let’s face it, “quick and easy” is not exactly what the NDIA is known for. And at times when participants need extra support for whatever reason, they don’t want to be jumping through bureaucratic hoops. 



The NDIA asks a question that gets close but doesn’t quite hit the mark: 

How can we assure participants that their plan budgets are at the right level? (e.g. panels of the Independent Advisory Council that meet every six months to review learnings and suggest improvements)

So, I’ve edited it slightly:

What’s the difference between “assure” and “ensure”? When you are working through caffeine brain trying to meet a deadline, it’s easy to get them mixed up, but there is a world of difference between a system that seeks to ensure plans are fair and one than aims to assure people that plans are fair. The first is about establishing a system that actually works, while the second is about trying to build confidence in the system, without any particular regard for whether it does work. 

Is ensuring plan budgets are at the right levels easy to do? Hell, no! But these are the real questions the Agency needs to grapple with; anything else is simply skirting the issue. 

The problem with this consultation paper really comes down to the fact that you don’t get the feeling the NDIA actually wants your input. It has the vibe of a tick-box consultation. But the fact they might not want feedback is no reason not to provide it. Starting today, you have 14 days to get your submission together. What are you waiting for?


Sara Gingold

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