ECIA NSW/ACT Statement regarding Partners in Communities Early Childhood Early Intervention (ECEI) Services Tender in NSW

MEDIA RELEASE - FOR IMMEDIATE RELEASE
OPEN LETTER TO THE NATIONAL DISABILITY INSURANCE AGENCY (NDIA)
CHAIRPERSON, BOARD AND CEO
19 October 2017

Statement regarding Partners in Communities Early Childhood Early Intervention (ECEI) Services Tender in NSW

ECIA NSW/ACT represents the majority of Early Childhood Intervention (ECI) Service Providers in NSW. 

The role of ECI services is to support children with a developmental delay or disability and to build the capacity of families to support their children. 

EARLY CHILDHOOD EARLY INTERVENTION IN NSW - CONTEXT 

ECIA both nationally and in NSW have supported the National Disability Insurance Scheme (NDIS), the Early Childhood Early Intervention (ECEI) Approach and worked closely with the National Disability Insurance Agency (NDIA),  to promote and enhance Early Childhood Intervention (ECI) and best practice for families and their children with a developmental delay or disability. 

Over the last twelve months Early Childhood Intervention Providers have in the main also been contracted by the state agency Ageing Disability and Home care (ADHC) to provide NDIS supports and planning under the ECEI Approach in NSW. 

In NSW, the ECEI Approach is a transitional role until the Early Childhood Partners are established and finalised across Australia by June 2018. 

WHAT ARE THE CONSEQUENCE OF THE TENDER AS CONSTRUCTED? 

The impact of the “Partners in Communities Tender“ as it is currently constructed, on families and children and the estimated 100 currently skilled expert early childhood intervention provider organisations in NSW is significant. The ECEI Approach is focused on children with developmental delay aged 0 to 6 years, their families and carers in a family-centred manner. ECEI focuses on the needs of the child and their families, to link them with mainstream supports. The tender does not support this important role of ECI. 

ECIA is not making a statement about the number of organisations or even their organisational profile. It has simply argued they must have ECI expertise, knowledge and competency and be based in local communities. This is especially important in rural and remote areas where there are few services and markets are already challenged by the roll out of NDIA. 

The tender prevents an ECI organisation, registered as an NDIS Provider, from being appointed as an ECEI Partner. Given historically ECI services in NSW have performed ECI and ECEI roles, this approach is contradicting effective best practice and will have a detrimental socio-economic flow on to our communities.  

The majority of local ECI services are precluded from applying for the EC Partner role unless there are no alternative providers of ECEI services in the region. The impact of this would be  that local knowledge, networks and expertise of local ECI services, which are largely precluded from applying for this tender, may be lost, resulting in compromised delivery of the ECEI Approach.   
 
Large organisations with no local experience, knowledge or expertise in early childhood intervention will be commissioned. There is a great risk the endorsed ECIA National guidelines for best practice will be weakened through this approach. 

Those large organisations may want to subcontract with local ECI service, but they cannot comply with such a request, even if they wanted to and still operate as an ECI service in their local areas / regions. 

IMPACT ON FAMILIES AND CHILDREN 

Families will be disconnected from their local support networks. Some regions will have no service providers, if they are forced to choose only to be an ECI Provider. 

The tender does not support a combined role of ECI as an NDIS registered provider (RPOS related party) and as an ECEI Partner. Ostensibly, this is because of a perceived conflict of interest, which ECIA has never supported. Concerns of conflict of interest do not apply in our opinion when working with very young children and their families. 

The tender outlines very narrow opportunities for organisations to apply for “exceptional circumstances” which are poorly defined and very limited. 
ECI services in NSW can and have provided ECI support to families for some decades, enhanced by the ADHC Stronger Together programs over the last ten years. We recognise ECEI Services will have additional responsibilities to do planning and referrals to NDIS under reasonable, necessary and other legislative requirements. This can be achieved with appropriate funding and protocols. The duality of roles will not diminish choice and control as perceived by the NDIA. 

Families want seamless services in their local communities, supported by expert skilled, competent and knowledgeable ECI professionals and practitioners. 

ECI services can and have established appropriate systems, organisational structures and protocols to ensure they are accountable and transparent, in separating their role as an ECEI Partner for NDIS and their key role as ECI Providers for families and children. 

COST & SUSTAINABLITY 

• Many families if appropriately supported will not need to enter into the NDIS scheme; they can be supported in community and have meaningful participation in their local community environments. This is the key to Early Intervention.

The tender document makes it difficult to determine what unit cost fund would apply to provide the ECEI service role for families and children. There is no transparent or available formula calculations and no apparent transparency around the cost.  A request in the tender for information on resources required, based on estimated participants in the future, is not likely to be predicable.  

• Under the current arrangements, the costs appear to be unsustainable and few ECI services would be able to or willing to provide the professional and capable service required to support families and children under this model.
• NDIS is an insurance scheme. It therefore has consideration of the costs and benefits of providing NDIS in the community. ECIA NSW/ACT has long argued that early intervention is amongst other things cost effective.

The current tender, as constructed, mitigates against ECI best practise and is likely to result in more families and children entering the scheme, with more costs to the NDIS, government and the taxpayer. 

THE PLANNING PROCESS UNDER NDIA 

The NDIA CEO on Wednesday announced through multiple channels how NDIA was going to improve the referral pathways and experiences for NDIA participants. This approach is not reflected in the ECEI tender. 

This tender process and likely outcome means families and children will not have seamless pathways to their local ECI provider’s and will have to go through the initial and/or review planning with a whole new set of organisations, who do not have the knowledge, skills or community connections of their current providers. This is not acceptable. 

The impact of having to transfer families to the new EC Partner in terms of cost and disruption is likely to be significant.  

The Productivity Commission has just released its report on NDIS and made significant comments about the planning process for participants. The NDIS Partners in Community tender does not support the Productivity Commission’s findings, in particular for the ECEI component of the tender. 

For further information or comment contact:

Margie O’Tarpey
CEO ECIA NSW/ACT
0412 348 770