The Hon. D. Tehan MP

Dear Minister

Autism Aspergers Advocacy Australia (A4) is concerned that the NDIA does not include registered behavioural clinicians on its disability services price list. This exclusion sends a clear message to NDIS planners and delegates that they should not include behavior supports in an individual's NDIS plan. For many autistic people (and some people with other disability types) behaviour support is essential. So excluding behavioural clinicians from the NDIS price list denies many autistic people essential disability services and supports.

This is an entrenched problem. There is no registration process for clinicians who provide good/best practice early intervention for autistic children in Australia. Many autistic students and adults also need behaviour support. We are keen to know what DSS and the NDIA are doing to address this serious deficiency.

Behavioural clinicians, therapists and technicians in Australia can register internationally with the Behavior Analysis Certification Board (see http://bacb.com). A4 is extremely disappointed that the NDIS chose to exclude BCBAs/BCaBAs and RBTs, who are internationally registered, from the NDIS Price List. The exclusion of these service types from the NDIS Price List sends a clear message to NDIS planners and delegates, and families of autistic children -- that the NDIS does not fund good/best or evidence-based early intervention practice for autistic children ... whether or not this was the NDIA's intent.

A4 understands, from an email from Ms Alexandra Gunning in the NDIA (on 1/4/2018), that the latest reason BCBAs, BCaBAs and RBTs are omitted/excluded from the NDIS Price List is "it was simply not possible to list all of the qualifications available for every registration group in every field of study – as a result, only the major qualifications were listed". Surely the NDIS has sufficient word-processing skills to include these people in a simple list ... and if not they could easily have contracted someone with the required skills to help the NDIS add a line or two for the required information into the electronic document.

Ms Gunning also wrote "that [it?] was not intended to exclude professions such as those you list" ... yet omitting them from the list has precisely the effect of excluding them from the actual and perceived list of service providers. We cannot imagine what other effect this exclusion "intended".

On the other hand, we notice that the NDIS lists various providers as providing behavioural services or early intervention for autistic people -- without any certification whatsoever -- on the NDIS state provider lists. Surely, such apparent endorsement of services by the NDIS is a massive legal risk for the NDIA.

A4 understands that the new NDIS Quality and Safety Commission created an incredibly onerous registration process for behavioural clinicians. The Commission could simply accept BACB registration as an alternative. We hear that smaller clinicians regard the Commission's process as far to complex, time-consuming and expensive; we hear that the scheme is a threat to their viability. We understand that the Commission's scheme is based on a Victorian model ... a model that may not be ideal, for example, it leaves families using GoFundMe and media cover to meet their child's behaviour support needs (see here and here).

We need to see some real action in this area. Training and registration for behaviour clinicians in Australia been a concern for A4 for quite a while.

--

Bob Buckley

Convenor, Autism Aspergers Advocacy Australia (A4)

website: http://a4.org.au/



A4 is the national grassroots organisation advocating for autistic people, their families, carers and associates. A4 is internet based so that Australians anywhere can participate.



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