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HACSU Submission to the Productivity Commission NDIS Inquiry


The HSU welcomes the opportunity to make an initial submission to this important inquiry into National Disability Insurance Scheme (NDIS) costs. While the terms of reference for the inquiry are narrowly defined on the scheme’s financial sustainability, we believe the Productivity Commission (the Commission) must consider whether NDIS prices and associated price-setting and review arrangements are sufficient to promote and sustain quality, innovation and choice in the provision of funded supports. For this reason, we welcome the Commission’s February 2017 Issues Paper, which highlights a range of matters facing the NDIS, all with significant bearing on its successful implementation.

In particular, we believe that the current inquiry must capture the serious supply-side risks facing the scheme, particularly as they relate to workforce. The Commission, in its 2011 report, Disability Care and Support, which recommended the introduction of the NDIS, identified acute workforce shortages as the key challenge to successful NDIS implementation and suggested strategies to draw more workers into the disability sector. Some of these strategies included the payment of higher wages, strengthening career pathways, improving community perceptions of the sector and promoting better working conditions such as more favourable shift lengths.1 However, the HSU’s experience of the rollout is that these strategies are not being implemented and that the design of the NDIS is causing the reverse to occur:

 Capped and inadequate NDIS prices for key support items are precluding the payment of
higher wages and flattening career pathways for workers.

 Unclear delineation of market development and stewardship responsibilities between the
National Disability Insurance Agency (NDIA), the Commonwealth Department of Social
Services (DSS) and the States and Territories has resulted in no substantive progress on a
workforce development strategy focusing on attraction, retention, skills or quality.

 Individualisation of supports, coupled with low and capped pricing, is eroding workforce
conditions and increasing income insecurity. At the Fair Work Commission, employers are
using the spectre of the NDIS to argue for reductions to minimum shift engagement lengths
in the four-yearly review of the Social, Community, Home Care and Disability Services
Industry Award 2010 (SCHCADS).

 The divestment and privatisation of State and Territory disability services to the nongovernment

and private sectors is leading to the virtual overnight erasure of decent wages
and conditions for large segments of the disability workforce. While divestment is not a
design feature of the NDIS, States and Territories are claiming otherwise. The HSU
recognises, like the Commission, that nothing in the NDIS design architecture precludes
government service provision. 2 Workers, responding to the risks of unilateral cuts to wages,
conditions and job security are threatening to leave the sector. On 30th June 2016, the HSU
Victoria No. 2 Branch conducted an automated ReachTEL telephone survey of 908 disability
support workers employed in the public sector. The poll revealed that over half these workers (53.4%) would leave the disability sector entirely and work elsewhere if they were
to be transferred to the non-government/private sector with reduced wages and conditions
(a further 30.6% responded “don’t know” whilst the remaining 16% of workers would either
remain in the sector or retire).

Ultimately, without a skilled, professional and available workforce to deliver supports to NDIS
participants, the disability sector will continue to be one characterised by unmet demand. Rationed supply will simply replace the rationed funding of pre-NDIS support arrangements, which the Commission unforgettably described as “inequitable, underfunded, fragmented and inefficient and give people with a disability little choice.”  Rather than individually addressing each of the questions in the Issues Paper, this submission responds to key topic areas highlighted by the Commission, specifically: unit pricing; plan utilisation; planning and the role of Local Area Coordinators (LACs); market readiness and workforce issues; the interface between the NDIS and mainstream services; governance and future scheme financial sustainability; and the potential hidden costs of individualisation and competition, which underpin the scheme. In addressing these topic areas, this submission answers a great many of the questions posed by the Issues Paper.

In preparing this submission, the HSU partnered with the Australian Services Union (ASU) and United Voice to survey members from the three unions working in the disability sector across Australia. The survey is still collecting responses; however, this submission uses preliminary results from the sample, which as of 28 March 2017 had 1,522 individual respondents. This submission also uses the words of HSU members from across the country, working in NDIS rollout areas or with NDIS participants. Their experiences, as told by them, provide invaluable insight into the impact of the scheme as it rolls out across Australia.
We thank the Commission for the opportunity to make this submission on behalf of our members and look forward to providing further input into this ongoing inquiry.

You can view the entire submission here