I would like to thank The Productivity Commission for the opportunity to put forward a submission in the inquiry into Disability Care and Support.

I would like to congratulate The Commission on their clear "no holds barred", non-sugarcoated description of the current disability support system.

The ideas of A National Disability Insurance Scheme and a National Injury Insurance Scheme proposed by the Productivity Commission are sensible, well thought out (comprehensive, logical description of responsibilities), worthwhile, definitely needed and "on paper", feasible. However, the actuality of all state and territory governments agreeing upon the same thing at the same time (which is what the birth of these schemes relies on), would be nothing short of a miracle - although I do hope that this miracle happens.

Unfortunately, only the "Key Features" and " Overview Booklet ” were available to me in a format that I could read so some of the questions that I have raised may actually be answered in the Draft Report. Hopefully, at least a few of my questions will help the Commission to pinpoint areas in the Draft Report that they could expand upon/better explain.

Also, the DAISY format of these documents did not include page numbers so I'm afraid I have not been able to reference quotations very well. Sorry!

There needs to be much more emphasis on explaining that the schemes do not provide income support. although it is mentioned, it is not highlighted, boxed, underlined (or otherwise made prominent) and can be easily overlooked.

With regards to the third tier of the NDIS which targets people from ages 0 to pension age (and this "pension age" is referred to in many places in the overview booklet) 

•	you need to be more specific about which pension you are talking (remember that many of these people will be on pensions e.g. disability support pension, carers pension etc

Who decides which disability organisations will be "intermediaries"?

Who trains the intermediaries, NDIS and NIIS staff (lowest paid clerk up to senior management) in all aspects of how the NDIS and NIIS function and what they are aiming at and what each person's/organisations duties are?

There appears to be no explanation about the cost of actually establishing a new organisation e.g. rental of premises needed to operate from: purchase of office furniture, design and printing new stationery, training of staff etc

How much money (funding) is a person with disabilities (or a carer) entitled to receive each year?

If a person with disabilities (who is married) is receiving a funding package, is their partner also entitled to funding (assuming the partner is one of the carers)?

As a person with physical and sensory disabilities, I object to the following: "Poor information (a ‘maze’ for people with a disability)..." Table 1 in the Overview Booklet, it makes it sound like only people with a disability (be it physical, intellectual or sensory) have difficulty working their way through the confusion of information.

In The assessment, funding and planning process in the Overview Booklet “But it would usually be appropriate to expect parents of a young child to provide support overnight and for a reasonable period during the week, as this is what parents usually do for their children." - My concern with this attitude is that it is not considering that a child with disabilities is a lot more work for parents and not the usual workload! This situation becomes more complex and more demanding when there is more than one child in the family.

In The assessment, funding and planning process in the Overview Booklet “Assessments and information would be portable across the system … so that people would not have to repeat information for different providers or government agencies.” How is this going to be achieved e.g. implementing a new electronic reporting system such as HADS which the Dept of Ageing Disability and Home Care (New South Wales government) introduced to keep track of disability services and their clients? How are the providers expected to pay for the necessary equipment and training to enable this?

In regards to the discussion of income support provision - it is important that in the rush to provide incentives to people with disabilities in order to get them into the workforce that the NDIS and Centrelink do not inadvertently discriminate against those people with disabilities who will never be able to work no matter how many supports they are given.

“Other payments sometimes classified as income support — Carer Payment, Carer Supplement, Carer Allowance, Mobility Allowance, and the Child Disability Assistance Payment — are really payments for support of people with a disability….
One option would be to add the value of any relevant payments to the individual support packages of people with a disability who qualify for funded supports under the NDIS.” 
How can this be done when in reality payments (in some cases) can vary from week to week e.g. my husband gets a part payment as he is my primary carer and an informal carer and he works part time. The income from the carer payment goes up and down depending on how many hours he works and whether he is on annual leave or long service leave

With regard to self directed funding, " As shown to be effective overseas, people could hire the workers they want, including neighbours and friends, rather than going through specialist disability agencies."
Does the NDIS funding package include enough funding to cover workers compensation, tax withholding and superannuation for informal carers, as well as all other supports deemed necessary?

“The scheme would particularly benefit from having some board members who have experience with long-term care or insurance schemes, since this is how the NDIS should be structured.
This statement is ambiguous. Some advice Does it mean e.g.
a)	6 members who have long-term care experience AND six members who have insurance schemes experience; or
b)	nobody with long-term care experience as long as there is somebody with the insurance scheme experience; or
c)	nobody with insurance scheme experience as long as there is somebody with long-term care experience?
I prefer the first option.

With regard to accident insurance arrangements -

How soon can you request funding from the NIIS eg when still in hospital after the accident?
 
If you can request NIIS funding when in hospital, will the NIIS pay for the gap for treatments such as eg physiotherapy?
If you cannot apply for NIIS funding when you are in hospital, can you keep receipts from treatments such as physiotherapy etc and claim the gap from NIIS?

If there is a person that can be proven to be at fault, is it still OK to sue them eg for loss of income or other damages?

Will this affect the NIIS support?

If yes, how?

"Workforce Issues
Apart from wage increases, other options for alleviating workforce shortages are:..."
an additional suggestion
the NDIS provide incentives to employers of disability support workers/personal care attendants etc to provide better work conditions for staff and employ greater numbers of staff.

Regarding “implementation of the NDIS”
paragraph 1, last sentence
"In the interim, the Australian Government should supplement funding under the National Disability Agreement to reduce some of the worst rationing."
This statement should be given more emphasis - it should be highlighted and boxed - as it is extremely important that the Australian government take notice of it!

I applaud the proposals of the Productivity Commission to include people with a disability and key disability organisations in many of the decisions in the set up. and in ongoing functioning of the NDIS. It would be good if the NDIS employed people with disabilities where ever possible (not just menial tasks, professional positions as well).

Thank you again for this opportunity to put forward my ideas, suggestions and questions in the inquiry for Disability Care and Support.