interpreting the evidence and using it to make a subjective decision . It seems like subjectivity is exactly the thing that the NDIA would rather avoid . One of the key justifications for implementing IAs is the inconsistent decision making that has been a hallmark of the current planning model . And – no shit – it ’ s a problem . But is a touch of inconsistency simply the price we have to pay for individualisation and leaving decisions in the hands of humans ? Perhaps inconsistency is something the NDIA can ( and should ) work to mitigate but will never do away with entirely .
QUESTION 3 : IF THE NDIA DOES REQUIRE PEOPLE TO UNDERGO IAS , HOW OFTEN IS REASONABLE ?
The consultation paper currently suggests participants will be required to have an IA at least once every five years , with the minimum time between assessments being three months . However , this really feels like something that should be open for discussion . Talking about your disability and support needs with a complete stranger can be traumatic , not something you want to be doing on the regular . If the NDIA absolutely insists on making IAs compulsory , we need to have a conversation about how often is reasonable .
Moreover , the paper suggests that IAs will be required before plan reviews that result in a change to plan funding . The argument is that , if funding is linked to functional capacity , they need to assess a person ’ s functioning before they can raise or lower funds . But there are many other reasons someone might request additional funding that have nothing to do with changes in capacity . For example , what if someone wants to go from working one day to two days a week ? In such cases , wouldn ’ t a simple planning conversation be enough ?
QUESTION 4 : SHOULD THE NDIA RELEASE FUNDING IN INTERVALS ?
Under the proposal in the paper , participants would have their funding released at monthly or quarterly intervals . This seems to be linked to the move to longer plans , and there is certainly a case for it . If we were given our salaries in five-year intervals , most of us would be pretty overwhelmed and consequently do a shocking job of budgeting . But you must admit that it is kind of a patronising solution to the problem .
More importantly , there are significant risks that have not been adequately addressed . Notably , we do not know what will happen if people need to draw on additional funds because of the episodic nature of their disability or temporary changes in life circumstances . The proposed changes allow for unspent funds to roll over into the next payment interval , but not for overdrawing . Therefore , if a person is at the beginning of their plan or hasn ’ t managed to save up from past payments , then it is not clear how easily they will be able to access additional funding .
To be fair , the paper does say , “ if additional funds are required in the first month of a plan , or a participant wants to make a bulk purchase , a higher initial allocation may be arranged and then be offset by smaller monthly allocations .” We are given no details about what the process for arranging for additional funds might look like , and it is possible that the NDIA will design a system that is quick and easy to use . But let ’ s face it , “ quick and easy ” is not exactly what the NDIA is known for . And at times when participants need extra support for whatever reason , they don ’ t want to be jumping through bureaucratic hoops .
QUESTION 5 : HOW DO WE ENSURE PARTICIPANTS ARE FUNDED AT THE RIGHT LEVEL ?
The NDIA asks a question that gets close but doesn ’ t quite hit the mark :
How can we assure participants that their plan budgets are at the right level ? ( e . g . panels of the Independent Advisory Council that meet every six months to review learnings and suggest improvements )
So , I ’ ve edited it slightly :
How can we ensure participants plan budgets are at the right level ?
What ’ s the difference between “ assure ” and “ ensure ”? When you are working through caffeine brain trying to meet a deadline , it ’ s easy to get them mixed up , but there is a world of difference between a system that seeks to ensure plans are fair and one than aims to assure people that plans are fair . The first is about establishing a system that actually works , while the second is about trying to build confidence in the system , without any particular regard for whether it does work .
Is ensuring plan budgets are at the right levels easy to do ? Hell , no ! But these are the real questions the Agency needs to grapple with ; anything else is simply skirting the issue .
The problem with this consultation paper really comes down to the fact that you don ’ t get the feeling the NDIA actually wants your input . It has the vibe of a tick-box consultation . But the fact they might not want feedback is no reason not to provide it . Starting today , you have 14 days to get your submission together . What are you waiting for ?
14 EBL QUARTERLY NEWSLETTER