Welcome to the second article in our Rumour Has It series, where we explore questionable decisions that are being repeatedly made by NDIA Planners. This week, we delve into everybody's least favourite policy intersection- Health and NDIS.
Just some quick background information before we jump into the Planning issue. The Council of Australian Governments (COAG) developed a Key Principles document to define the differentiated responsibilities between the NDIS and other government bodies. It assigns State and Federal Health departments obligations for treatment, diagnosis, early intervention and time-limited rehabilitation. In contrast, the NDIS deals with the impact of a person's impairment on their functional capacity, daily living and maintenance once a condition has stabilised. Simple, right? If only.
Policy will always struggle in this area because, in real life, disability and health are incredibly interlinked. Health conditions can develop into disabilities, and disabilities can induce health conditions. Very often decisions about funding responsibilities need to be made at an individual level, taking into account professional expertise. This form of localised decision-making is not something government agencies nor insurance agencies tend to like very much, as it bears the risk that they might end up paying more than what they have budgeted. For the NDIA, that seems to be the nightmare scenario.
What is actually happening?
According to our sources, many Participants are being incorrectly informed in Planning meetings that the NDIS does not fund dietitian services because they are a Health responsibility. In these instances, we are not talking about Participants being told that the NDIS will not fund a dietitian under particular circumstances, but rather that there it is a blanket rule that the NDIS will never fund dietetics. This has occurred frequently enough to become of concern to WA Senator Jordan Steele-John, who raised the issue in the Senate Estimates. In response, the NDIA confirmed that 'allied health and dietary supports are considered on an individual basis.'
So, why is this happening?
If dietary supports should be considered on an individual basis, why are Participants being told differently? We can only assume that this is occurring because of the grey intersection between NDIS and Health. As with many therapy services, in dietetics, it is difficult to draw the line between what is Health and what is an NDIS responsibility. And when things get hard, there will always be the temptation to ignore the issue by passing the buck.
To illustrate how complicated it can be, consider an NDIS Participant who has entered the Scheme due to an amputated leg. If that Participant also has Coeliac Disease, then dietary supports are likely to be considered a Health responsibility. But what if a Participant’s Coeliac Disease is highly associated with Down Syndrome and the related bowel problems are preventing them from leaving the house? Under these circumstances, the same condition starts to look very much like an NDIS responsibility.
Moreover, dietitians treat the person as a whole. So, let's say the Participant with Down Syndrome, Coeliac Disease and bowel issues, also has high cholesterol which is a Health issue. No dietitian is going to not treat the individual in a holistic manner, regardless of who is footing the bill.
In reality, dietetics is often a shared responsibility between Health and NDIS. As such the NDIA might have to follow the lead of other insurance agencies and rely on the expert advice of the dietitians reporting against reasonable and necessary criteria.
What can Participants do?
The idea that the NDIS does not fund dietitians is- as the 45th President of the United States would say- fake news. There are two lines in the Price Guide dedicated to dietary supports. The Price Guide describes this as funding for “individual advice to a participant on managing diet for health and wellbeing due to the impact of their disability”
Participants who are worried that they might receive a blanket no to dietitian funding can arm themselves with the Price Guide, the Dietitian’s Association of Australia peak body statement on Dietitian Services and the NDIS and the NDIA’s response to Senator Steele John’s question. However, it is, of course, very likely that Participants will be unaware that these documents exist. Where they can, providers should empower Participants seeking dietitian services to take these documents to their NDIA planning meeting.
However, it is ultimately the responsibility of the NDIA to ensure that Planners are not spreading fake news. The community needs to have confidence to believe that what they are hearing from Planners is informed, considered and- above all else- true. Misinformed Planners might think that they are saving the Agency money in the short term but the long-term cost consequences for the taxpayer, Participant and support staff are far more costly.
Those interested in learning more can read the Dietitians Associations of Australia’s statement on the NDIS.
There is a reason we have titled this series “Rumour Has It.” Unfortunately, the NDIS doesn’t publish a list of all the bad decisions they’re making, so we have to go sleuthing and rely on our sources. If you know of cases where Planners have acted in a way that contradicts policy, or is based on unclear policy, please let us know.