A4's brief and somewhat rushed submission on proposed changes to the NDIS legislation is available below.
The government gave the disability sector insufficient time to respond to its proposed changes. Parts of the disability sector have received legal advice that the limited time allowed is disability discrimination. It certainly shows that the government's aim to build trust (following the Independent Assessments debacle) and to work with the sector is insubstantial.
The report at https://www.abc.net.au/radio/adelaide/p… is one-sided. It fails to speak to qualified or registered clinicians in Applied Behaviour Analysis. It is well known that any early intervention approach for autism does not suit all autistic children, but getting views from clinicians on one side of the debate is biased.
A4 made a late submission in response to DSS's consultation on a National Disability Employment Strategy.
Basically, A4 felt that DSS's proposed holistic strategy to address disability employment over the next decade is the same as it was for the last decade: it's the same strategy expecting a different result. Rather thank acting on what they "think" might work, some of the 10 years could be used to determine reliably what does work for the various parts of the disability sector, then implement working approaches more widely.
Minister Reynolds has the NDIA and disability representatives working on rebuilding trust. The NDIA and some parts of the disability sector seem to think this is just about recent conduct.
For the autism sector, there are deeper issues from the outset.
Here is a letter from A4 to the Minister briefly describing some of the history and issues.
The NDIA did not respond to a number of A4's concerns. Issues of particular concern were:
"misinformation and untruths" from the NDIA's CEO to NDIS participants about the assessment tools that were planned for functional assessment of autistic NDIS participants for the so-called Independent Assessments, and
inexpert and misguided advice from the NDIA's Independent Advisory Council (IAC) about early intervention for autistic children.
The NDIA did not respond to A4 about its concerns.
Dear Senator the Hon Linda Reynolds,
Subject: Government’s ongoing war on autistic Australian
Autism Aspergers Advocacy Australia (A4) deplores media reports (see Annex below) saying that “The Minister responsible for the National Disability Insurance Scheme has blamed an uptick of Australia’s aged, autistic and obese people for the ‘unsustainable’ rising costs of the service”. Your government’s war on autism is unacceptable. We complained about it before and were ignored.
Aged autistic people are one of the smallest subgroups in the NDIS: there were just 125 of them in June 2021, just 0.8% of 14K+ NDIS participants in that age group. While their funding level is higher than average for the NDIS, we doubt the numbers in this very small group will increase significantly for some time. We have not found NDIA reporting on obesity; we doubt the NDIS even has reliable data on obesity of NDIS participants.
The NDIA claims in its Participant Service Charter that it wants to be "transparent". However, it avoids making public communication and decisions about some key issues. For example, the following show that it does not want its records about commentary from a disability representative organisation (DRO) on advice it received from its IAC released.
The NDIA wrote a discussion paper on early intervention for autistic children.
The Hon. Scott Morrison MP
Canberra ACT 2600
Dear Prime Minister Morrison,
There are numerous reports in the media that the National Disability Insurance Scheme (NDIS) has seen the average cost of individual support packages increase by at least 12% per year since 2017. These include: