Out of Nowhere: a New NDIS Access Request Form

Nice try, NDIA. 

Just when you thought we were distracted, you slipped a new NDIS Access Request Form (ARF) onto the NDIS website. However, it’s hard to go unnoticed when you’re 28 pages and very purple. 

For the last two years, most of my working hours have been spent supporting people with their NDIS Access Requests. My employer (Fighting Chance Australia) facilitates my doing this pro bono, as it recognises that there are very few options for people across Australia to have time-unlimited, intensive, and free support with this often complex and sometimes traumatising process. 

The new form heralds some good and some not-so-good changes. But let’s start with the good news.

The good

• Breaking the form into several discrete sections makes it easier to navigate, and some sections can be completed easily and quickly. 

• There is more clarity around general eligibility criteria – including more context about age, residency, and citizenship status.

• There are more options in the Postal Address section. These include options for people to note that they are homeless, in a hospital or other inpatient facility, or in a correctional facility.

• The new Privacy section now also includes Consent to Share information: the old form did not address this important issue.

• In Part D: Parent, Legal Guardian or Representative section,I really like that “Parental Responsibility” and “Legally Authorised Representative” have been explained. Good call, Agency! I also like that evidence must be provided if someone claims to have power of attorney or be a legal guardian, public trustee, or decision-maker via a living will. This is in line with facilitating supported decision-making for the applicant.

• In Section 2: Completed by the Treating Professional, there is more prompting and structure in the questions, making it clearer exactly what evidence the Agency wants. For example, to establish the permanence of a disability, the form asks questions around describing the current treatments, the duration and frequency of treatments, and the expected results of those treatments. In other words, they are really trying to flesh out whether the impairments are lifelong and permanent and what treatments have already been tried.

• Very kindly, there is a checklist on page 26 of what you need to collect and include before you submit the ARF.

• On pages 27 and 28, there is a list of ways to prove your identity if you have chosen not to give permission for the Agency to speak with Centrelink. 
  
  

Heading in the right direction

• There is more focus on identity (such as asking if you have ever been known by another name).The question around gender, which was presented as Male/Female/Unspecifiedin the old form, is now asked as, “Do you have a preferred gender and/or pronoun?” The options listed are Male, Female, Do not wish to disclose, and Other, with separate sections to write “Preferred gender” and “Preferred pronoun.” This is a positive change in the right direction. However, it should only be seen as the first step of many and one that will be part of a large-scale and whole-of-Agency cultural shift.

• When using the old form, I always recommended people skip the domain sections in lieu of selecting the option to attach reports, assessments, and letters from Treating Professionals. However, since this new form demands so much more detail from Treating Professionals and provides very specific prompts throughout a 12-page section, it may prove more efficient to download, complete, and save the fillable PDF version. However, to expect this to be done well, you will have to follow the advice on page 11 of the form: “You may need to book a longer appointment with your Treating Professional to complete this section of the form.” Yep. And likely more than one.  

Room for improvement

• At 28 pages, it’s a LOT longer than the nine pages in the earlier version. At first glance, the form is overwhelming. It has many parts, many headings, many webpage links, and lots of sector language. I’m also 99% certain that people will end up thinking they need to get every section filled in by a Treating Professional and include separate letters of support, but that is not necessarily the case.

• I would love it if when the form asks, “Do you need an interpreter to help us communicate with you?’, that was presented as more of a two-way, reciprocal communication strategy and that it very clearly stated that “if needed, we will arrange an interpreter for you free of charge.”

• Along with the positive of this new ARF teasing out more thorough and evidence-based information from Treating Professionals, there will likely be a higher financial cost to the applicant, due to the number of billable hours this will take the professional. 

• It is not clear that NDIA Delegates at the National Access Team will have the skills and qualifications to assess decisions based on clinical rationales. For example, one of the questions asked of the Treating Professional is, “Are there any available, evidence-based treatments/interventions that are likely to substantially relieve the applicant’s impairment? Note: If any commonly known treatments are yet to be pursued, please attach a separate document with your clinical rationale.”

As a physiotherapist in a past life, I’m left wondering whether the National Access Team delegates have the training and skills to assess and judge the justifications and evidence presented by Treating Professionals in section 2? Most likely in medical jargon? 

The confusing

• In section 1 of the new form, there is a bigger question around whether the applicant has any immediate family member who is applying to the NDIS or who already is an NDIS Participant, with context explained as “When more than one NDIS participant lives in the same household, we can consider your collective needs.” This makes sense when working out what supports might be reasonable and necessary but doesn’t make any sense to me at the Access request stage. 

• The Privacy and Consent Declaration section has words. Lots of words. Many, many words. And some vague sentences, such as “We will use this information to help develop, implement and review your NDIS Plan and do other things related to the NDIS.” Hmmm. Other things? And then, “We can also collect your information from others when it is allowed under a law.” What information and which laws? This makes me feel a little vulnerable.

• Part E: Overview of Disability is all a bit confusing. It states, “Your Treating Professional may be a GP, psychologist, or speech pathologist.” Full stop. I know people who have already read that sentence and taken it as the whole truth. They assume this means that other professionals – and reports like Occupational Therapy Functional Assessments – cannot be used. However, the link provided on the form goes to a webpage with the following wording:

  You can work with your treating health professionals to provide your evidence of disability. Examples of common treating health professionals include: General Practitioner (GP), Paediatrician, Orthopaedic surgeon, Occupational Therapist, Speech Pathologist (Therapist), Neurologist, Psychologist, Psychiatrist, Physiotherapist.

• Part E does try its best to explain “functional capacity” by listing summary explanations about each of the six domains. However, these summary explanations are far too brief and, in my opinion, will lead to some people believing that a certain domain is not relevant to them. This might mean they under-represent the functional impact and impairment of their disability and reduce their NDIS eligibility chances. 

Some final impressions and thoughts

So, while there are some well-intentioned changes, I anticipate that some people will still need support to successfully complete and lodge an Access Request with this new form. But the NDIA has attempted a more “hand-holding” approach to tease out key eligibility points with this form.

NDIA, please just tell us next time you make a significant change that has an impact on people’s lives. Communication has and always will be key.