The objective of this audit was to assess the effectiveness of controls being implemented and/or developed by the National Disability Insurance Agency (NDIA) to ensure National Disability Insurance Scheme (NDIS) access decisions are consistent with legislative and other requirements.
Summary and recommendations
1. The National Disability Insurance Scheme (NDIS or the Scheme) will replace existing Commonwealth, state and territory disability support systems with a nationally consistent scheme for Australians under the age of 65 who have a permanent and significant disability. When fully implemented, the Scheme will benefit an estimated 460 000 Australians with a disability, at a total cost of around $22 billion in the first year of full operation (2020–21).
2. The number of people receiving individualised supports under the NDIS is a major driver of Scheme costs. Eligibility requirements to access the NDIS are set out in the National Disability Insurance Scheme Act 2013 (the Act). The National Disability Insurance Agency (NDIA) is responsible for administering the Scheme, including ensuring that Scheme participants meet the eligibility requirements set out in the Act. The NDIA has outsourced processing of some streamlined access requests to the Department of Human Services (Human Services).
3. The NDIS was trialled in seven sites between July 2013 and June 2016 and is being rolled out nationally from July 2016. The transition to the full Scheme will require a rapid scale up of the NDIA’s capacity to determine access requests.
Audit objective and criteria
4. The objective of this audit is to assess the effectiveness of controls being implemented and/or developed by the NDIA to ensure that NDIS access decisions are consistent with legislative and other requirements. To form a conclusion against the audit objective, the following high-level audit criteria were adopted:
- Suitable information, training and guidance is available to support effective decision-making about access to the NDIS.
- Suitable administrative systems and processes are in place to support transparent, accurate, timely and consistent assessment of NDIS eligibility.
- Suitable quality and compliance arrangements have been established to mitigate the risk of incorrect NDIS access decisions.
5. The NDIA has implemented some controls to ensure that NDIS access decisions are consistent with legislative requirements, but these have been inconsistently applied. As at August 2017, the NDIA is developing an integrated assurance framework to enhance decision-making controls.
6. Accurate and accessible information is available for consumers and carers about how to access the NDIS. Suitable training and guidance is available to support access decision-making by NDIA officers and processing of access requests by Human Services’ staff.
7. Data integrity and reporting issues limit the NDIA’s ability to monitor training completion by access decision-makers. In addition, NDIA requirements for on-the-job training were not documented and the ANAO found limited evidence that these requirements were implemented.
8. The NDIA’s access processes supported the transition of a large volume of people into the NDIS in a short space of time. In practice, the ANAO observed legislative and administrative non-compliance that potentially affected the transparency, accuracy and timeliness of access decisions.
9. The access process was not well supported by the first stage of the NDIA’s ICT system, introduced in July 2016, requiring implementation of inefficient manual work-arounds. The NDIA advised the ANAO that new ICT workflow management functionality was implemented from July 2017.
10. The NDIA had not established efficient or effective processes for internally reviewing access decisions. New procedures introduced by the NDIA in May 2017, if implemented effectively, will provide an internal review process that is consistent with legislative requirements.
11. The NDIA has implemented executive monitoring and reporting of strategic and operational risks, including risks to Scheme financial sustainability, which is informed by actuarial analysis of Scheme outlays and risks.
12. Comprehensive quality and compliance arrangements have not been implemented to mitigate the risk of incorrect NDIS access decisions. These are currently in development as part of a broader integrated assurance framework.
Information, training and guidance
13. Information for consumers and carers on the NDIS is readily accessible from the NDIA website in multiple formats. The NDIA is in the process of translating key communication products into ten languages.
14. The NDIA has established training requirements for access decision-makers but training records are incomplete. Consequently, the NDIA does not have assurance that all officers making access decisions have been appropriately trained.
15. Requirements for on-the-job training for access decision-makers were not documented and the ANAO found limited evidence that pre-decision checks for less experienced decision-makers were occurring.
16. The NDIA’s Operational Guidelines on Scheme access reflect the requirements of the legislation underpinning the Scheme. The Operational Guidelines are supplemented by a range of procedural materials for access decision-makers and relevant Human Services’ staff.
NDIS entry and exit pathways
17. The sample of NDIA general access decisions reviewed by the ANAO demonstrated high levels of legislative and administrative non-compliance, including missing evidence of: disability and impairment; and written advice to applicants notifying them of their review rights. This result occurred within an environment of: rapid expansion in the volume of access requests and the number of access decision-makers; significant changes to the guidance provided to decision-makers; and the introduction of stage one of a new ICT system.
18. Streamlined access was designed to bring a large volume of people into the Scheme quickly when compared to the general access pathway. There was no documentation to support the creation and approval of lists of specified conditions, but the lists had been applied effectively with no evidence of decision errors related to specified conditions in the samples reviewed by the ANAO, once internal review processes had been completed. The quality of data provided to the NDIA by Australian, state and territory governments reduces the NDIA’s ability to link Defined Program participants to approved Defined Programs and therefore to manage a key risk associated with streamlined access arrangements.
19. The first stage of the NDIA ICT system, implemented in July 2016, did not provide for workflow management functionality or real-time monitoring of decision-making timeframes. In July 2017, planned enhancements to the NDIA’s ICT system were introduced which the NDIA advised allows monitoring of workflow and legislated timeframes for access decisions.
20. The ICT system provides computer-aided decision making, which the ANAO identified was being manually overridden in a large volume of cases, associated with a known misalignment between the NDIS Rules and the ICT system business rules. The ANAO also identified a discrepancy between the system business rules and other NDIA guidance.
21. The NDIA has implemented measures to address lower than expected exit rates from the NDIS. It is too early to assess the effectiveness of these strategies.
22. To improve assurance that only people who meet the NDIS access requirements remain in the Scheme there would be value in the NDIA introducing risk-based reassessments of NDIS eligibility for participants who enter the Scheme under the disability requirements.
Internal reviews and appeals
23. The NDIA did not have in place efficient or effective processes for internally reviewing access decisions. Revised internal review procedures introduced by the NDIA from 29 May 2017 are consistent with legislative requirements and provide greater clarity about procedures to be followed by NDIA officers in conducting internal reviews of access decisions. There is scope for the NDIA to improve quality assurance processes for internal reviews of access decisions.
Quality and performance arrangements for access decisions
24. The NDIA Board and executive have established systems and processes to identify, monitor and report strategic and operational risks to Scheme sustainability, including identification by the Scheme Actuary of emerging issues. Actuarial reports identify several access-related threats to Scheme sustainability and monitor the effectiveness of mitigation strategies. Access-specific risks are not reflected in the NDIA’s strategic and operational risk plans.
25. Until July 2017, the NDIA had limited ability to monitor the performance of the National Access Team, due to the absence of a workflow function in the first stage of the NDIA ICT system. A 2017 Business Services Schedule between the NDIA and Human Services established performance metrics for the National Call Centre.
26. During the trial phase of the NDIS, the NDIA did not conduct regular quality assurance reviews of access decisions. The NDIA implemented monthly quality assurance reviews from October 2016, which indicate that the NDIA is not achieving its quality target for access decision-making. The Agency is developing a new quality assurance program, which is expected to be supported by enhanced ICT system functionality from September 2017.
27. The NDIA’s quality assurance reviews of access decisions have identified potential improvements. Implementation of these improvements is monitored through the NDIA Executive Management Group and the NDIA Board. Actuarial analysis is used to inform the development of strategies to address emerging risks and to monitor the impact and effectiveness of these strategies.
Recommendation no. 1
The National Disability Insurance Agency should establish, implement and monitor a robust quality framework for access decisions addressing training, ongoing assessment of officer proficiency and decision quality.
NDIA response: Agreed.
Recommendation no. 2
The National Disability Insurance Agency should ensure that the business rules underpinning computer aided decision-making are clearly documented, aligned with legislative and policy requirements, and verified to ensure they have been correctly incorporated into the National Disability Insurance Agency ICT system.
NDIA response: Agreed.
Recommendation no. 3
The National Disability Insurance Agency should review its processes to include reassessments of the eligibility of participants who enter the Scheme under the disability requirements, taking into account levels of impairment, and conditions that have greater prospects of improvement.
NDIA response: Agreed.
Recommendation no. 4
The National Disability Insurance Agency should implement quality control and assurance processes for internal reviews of access decisions, with the aim of supporting accurate, consistent and transparent decision-making.
NDIA response: Agreed.
Summary of entity responses
28. The National Disability Insurance Agency’s and the Department of Human Services’ summary responses to the proposed report are provided below, with full responses at Appendix 1.
The National Disability Insurance Agency
The NDIA takes the ANAO audit recommendations seriously and is committed to strengthening control weaknesses through continuous improvement.
The NDIA acknowledges the audit findings and agrees with the four recommendations. Steps have already been taken to address a number of the recommendations and issues raised in the report.
As a general observation, the NDIA notes that the audit took place during a time of significant transition and growth. From 1 July 2016 until 31 March 2017 (the period covered by the audit), the NDIA processed 81,172 access decisions. By comparison, over the previous three years of trial a total of 37,946 access decisions were made.
During the audit period the NDIA also faced a number of externally driven pressures and challenges, including: elements of key operational policy was not finalised between governments (for example phasing agreements); data on existing participants was received late and was of variable quality (for example missing information fields on primary disability type); and the late deployment of an IT system resulted in the NDIA staff having limited access to and time for training.
The NDIA is addressing the four recommendations of the audit report through: the implementation of a quality management framework and an integrated assurance framework; improvements to the storage and quality of decision making guidance and support documentation; and staff training to build core competencies. These activities will improve the quality, consistency and assurance of access decisions.
More broadly, the NDIS is implementing a program of work to improve the participant and provider experience which will be underpinned by clear operational processes, practices and controls.
The Department of Human Services
The Department of Human Services (the department) welcomes this review into the effectiveness of the National Disability Insurance Agency’s (NDIA) implementation of the National Disability Insurance Scheme (NDIS).
The department notes the review’s four recommendations refer to the NDIA. The department will work with the NDIA to ensure that the business rules underpinning computer aided decision-making are correctly incorporated into the NDIA business system as outlined in Recommendation Two.