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Joint Standing Committee on the National Disability Insurance Scheme
17/04/2018
Market readiness for provision of services under the National Disability Insurance Scheme

HAILES-MacDONALD, Ms Marion, Assistant Director General, Department of Communities, Western Australia

SEARLE, Mr Grahame, Director General, Department of Communities, Western Australia

Committee met at 08:46

CHAIR ( Mr Andrews ): I declare open this hearing of the Joint Standing Committee on the National Disability Insurance Scheme for the inquiry into the market readiness under the NDIS. These are public proceedings, although the committee may determine or agree to a request to have evidence heard in camera. I remind all that, in giving evidence to the committee, they are protected by parliamentary privilege. It's unlawful for anyone to threaten or disadvantage a witness on account of evidence given to a committee, and such action may be treated by the Senate as contempt. It's also a contempt to give false or misleading evidence to a committee.

If a witness objects to answering a question, the witness should state the ground upon which the objection is taken, and the committee will determine whether it will insist on an answer, having regard to the ground which is claimed. If the committee determines to insist on an answer, a witness may request that the answer be given in camera. Such a request may also be made at any other time.

I also remind those contributing that you cannot divulge confidential, personal or identifying information when you speak. If you wish to supplement your evidence with written information, please forward it to the secretariat after the hearing.

Welcome. I remind officials that the Senate has resolved that an officer of a department of the Commonwealth or of a state or territory shall not be asked to give opinions on matters of policy and shall be given reasonable opportunity to refer questions asked of that officer to superior officers or to a minister. The resolution prohibits only questions asking for opinions on matters of policy and does not preclude questions asking for explanations of policies or factual questions about when and how policies were developed.

I thank you both for appearing before the committee today. Thank you for the submission from the Western Australian government. I invite you, if you would like, to make some opening remarks.

Ms Hailes-MacDonald : Thank you for the opportunity. I'd like to place on record that WA is building on a very solid platform of market development that began in earnest in the 1990s, and that's become more intense over the last four years as we've rolled out the National Disability Insurance Scheme. What we've seen is that the number of service providers registered with Disability Services to provide disability services has increased from 120 to 237 service providers over the last three years, and many of these have been sole providers. They are frequently therapy providers or disability professional service providers, particularly in areas where the NDIS is rolling out at the moment. Of note is that Western Australian service providers have been used to operating with individualised funding, and that's because 80 per cent of disability services funding over the last 20 years has been directed to individuals in individual packages and they've had the choice of which service provider they choose. Over the last four years we've been gradually reducing the remaining block funding that we've had. That's been done judiciously, recognising the need for service provide viability, especially in thin markets in regional and remote areas and specialised niche markets where there is significant expertise required.

As well as increasing the number of service providers, which I've mentioned has increased 100 per cent over the last three years, it's been important to ensure that the existing, sometimes longstanding quality service providers are ready and prepared to operate in an NDIS environment. To this end, the WA government has worked with the National Disability Services state office and the disability sector to inform and assist them in their preparedness to operate within the NDIS environment.

It's fair to say that some organisations are more prepared than other, are more ready than others, but one of our common concerns is workforce capability and capacity, and that's in terms of both scale and scope. It's a common concern across the sector, it's a concern for government and it's a concern for the disability providers themselves. We're working together to address that.

As we've rolled out the NDIS in WA, it's been important that we've been cognisant of supply and demand, because one of the factors that we experience is that, if your supply is there but your demand isn't ready, you cannot expect service providers either to remain in business or enter into the market; hence it's been important to balance supply and demand, hence the WA government has delivered targeted strategies to build individuals' and families' knowledge about the NDIS and their capacity to undertake planning and exercise their choice in seeking service providers. That's being done ahead of the rolling dates as we've had them in WA.

While this has taken different forms, a key success factor that has been consistent to this point has been a single point of contact, which in this case has been the local coordinator, because they have assisted individuals and families to navigate and connect with appropriate services. That may be a community service, it may be a mainstream service or it may be a specialist disability service group provider. But, although there are challenges, we are absolutely committed to actually seeing the NDIS roll out well for people with disabilities and their families. Thank you.

CHAIR: Mr Searle, do you want to add anything?

Mr Searle : No.

CHAIR: To start off: broadly, in a sense, what have you learnt from the experience in the other states that have come online earlier? To summarise in general terms: the evidence before us is that there is about an 80 per cent success rate in terms of getting people plans, but, of that 80 per cent, there's only about a 70 per cent deliver of services after three months, so there's a gap between the aspiration and the reality in terms of the rollout. I'm interested in knowing if there's anything that you've seen, either positive or negative, from the experience of other states that you've been able to take into account in WA in terms of how you implement the rollout here in the coming months.

Ms Hailes-MacDonald : As you would be aware, we had two trials in Western Australia, and one of the significant differences was the connection rate of somebody who has a plan and the connection to access to services. Our experience would be that that point of connection, whether or not you call it a local coordinator, is a point that enables somebody to actually navigate the system. It enables them to have relevant and appropriate information for their support needs and knowledge of what's available to be able to then connect to the service. In many instances that has been assisting the person not necessarily to make the choice but to give them the wherewithal to make the choice to then connect with a particular service.

Under the WA NDIS system we saw connection rates as high as 90 per cent. The difference would be for people who hadn't yet connected and were still in the process of actually deciding.

CHAIR: Do those local coordinators in WA—individuals and organisations—have a experience and a track record in the sector? Again, elsewhere we've found that this varies greatly. There have been some places where they do and other places where they are new on the block, so to speak, and do not necessarily have the experience and are sort of starting behind scratch.

Ms Hailes-MacDonald : I'll comment on three aspects there in terms of learning. One is the importance of information in a readily accessible way to whoever it is. It's information to the person to have the capacity to make the decisions and information about what is available. That needs to be readily available and needs to be developed.

In terms of new service providers versus existing service providers, one of the things that we have done in Western Australia is have forums or expos of service providers where people in local areas can come and get information about the service providers. To give you an example, recently in Rockingham-Mandurah, which was one of our newer areas that rolled into the NDIS, we had about 40 local providers, and that was attended by a significant number of people in the area, so they actually got the personal contact, and that was really important. We—as in the Department of Communities, Disability Services or the Western Australian government—have actually conducted targeted information to new providers. This is particularly so in the Pilbara and the Kimberley, where we've sought, in particular, therapy providers, because it's a thin market there, and then worked with them to explain what their requirements are and how to operate in the NDIS environment. We've taken on very much a role of market stewardship and assisting organisations to operate in that space.

CHAIR: One of the other challenges in some jurisdictions is in relation to the adequacy of data about individuals under the block funding approach. There wasn't necessarily the same collection of data that is required under the NDIS approach. I'm interested in the experience here in relation to that because, if you don't have data but you're essentially relying on data that you don't have, that provides further challenges.

Ms Hailes-MacDonald : Whilst I can't say that we're perfect, as I mentioned in my opening statement, we have had 80 per cent of our funding directed through individualised funding. When I look at a budget of $800 million going into disability services, close to $700 million of that was through individual packages, so we know and knew about the demographics of the people we were supporting; hence only 20 per cent of our funding was through block funding. So we were working from a totally different base of knowledge. As I said, our data is not perfect, but we certainly have the knowledge of predominantly who is receiving services and the general type of services they're receiving. I say 'general type'; it might be that we consider it community access or supported community living rather than the specifics of living with five other people or four other people.

CHAIR: Senator Brockman.

Senator BROCKMAN: My impression—and, as a senator from Western Australia, I certainly don't want to get parochial about this—is that there is a sense out there that we were better placed for the transition process than most states because of the structures that were in place for a reasonably long period of time before the transition. Would you agree? Is that both the feeling on the ground here and what you hear in discussion with other states?

Ms Hailes-MacDonald : It's certainly the feeling I hear from the disability sector and from many individuals. Equally well, there are some who would actually say that we weren't better placed and that it was easier for other jurisdictions to start from a zero base because they didn't know anything different. For Western Australia, we've actually had to adapt systems that have been known to service providers, that have been known to individuals and that have been known to families, and it's changing individualised funding, which we've been operating since the early 1990s. So, the change for us is on a different basis, which is why I say we're operating from a different landscape.

Senator BROCKMAN: In terms of market readiness, which is obviously what we're focusing on here, can you just talk us through that? Western Australia has been slightly different in that it has gone through this double transition from the previous system to the standalone NDIS to the national NDIS. Can you talk us through that transition and how that's been handled in terms of market readiness? Has it made a difference to the providers on the ground? Has it given them a bit more time, perhaps, to scale up for these new entrants to come into the market? Has it been a negative because people have been concerned and uncertain about what the future holds? Can you just talk us through how that has worked on the ground?

Ms Hailes-MacDonald : As I say, starting from the base of most of our services being in the non-government sector, we actually haven't, as a government service, had to transition large institutions, and, service providers being knowledgeable about operating with individualised funding, that hasn't specifically been a major issue. The challenges for the sector are changing from the way the Western Australian system has operated with, generally, in-advance funding versus now moving to an NDIS system which is in-arrears funding. Scaling up to address a different business model is challenging for many and requires investment in systems. Because of the hiatus we had in the decision and not knowing whether we were using the Western Australian system or a national system, there has been sometimes a reluctance to invest in systems. The sector have been reluctant to invest when they don't know which way they're going to have to move.

In terms of some of our providers, they are concerned about their viability into the future because, obviously, they're needing to look at cash flows and cash reserves and change their whole business and governance structure. The concern many have is about the pricing structure under the NDIS as they move forward. When the McKinsey review came out, it was expected to have a significant impact. They were hoping for a positive impact and the read I have from the sector is that they're really having to adjust to looking at how that will impact their moves going forward. Some providers, in terms of market readiness, are looking at whether they will continue to provide all services that they currently provide and which services they will and won't provide. An area that is of significant concern right at this stage is the support and service to be provided to people who have got very complex needs, and that's particularly people who have got high challenging behaviours and support needs around that, which generally require either intensive supervision, significant training or significant expertise to deliver.

Senator BROCKMAN: Is that concern based on the funding streams or is it based on availability of workforce? What's the driver of the concern?

Ms Hailes-MacDonald : Primarily it's price, at this stage. But, equally well, as we move forward, I suspect there will be an indication that the workforce—because we recognise that the workforce capability and capacity, in terms of both scale and scope, need to increase to address the needs.

Senator BROCKMAN: Obviously, you've described a significant number of new potential supply participants in the marketplace. There are some concerns from existing participants, and I think this committee fully understands those concerns. Have you heard of any participants who are exiting parts or all of the market on the basis of those concerns or do they merely have a close watching brief on what's occurring?

Ms Hailes-MacDonald : We have a close watching brief on what's occurring. We have seen some small organisations amalgamate with other organisations, so we've seen a changing marketplace with organisations looking at how their governance structure may work in the future. There is talk of amalgamations and talk of consolidation, and a couple of organisations have actually withdrawn from the market.

Senator BROCKMAN: Finally, we're going to Kalgoorlie tomorrow. The Perth market is the strongest market, I would assume, in terms of suppliers and participants. It sounds like there's a good cohort of suppliers in the Mandurah region. I assume the larger centres like Bunbury and Albany would have at least some breadth of suppliers. What about places that are a bit more remote like Kalgoorlie and the north-west of WA? How does the market look in those areas? Are there going to be multiple providers?

Mr Searle : I've just spent the last two years in the north-west based at Kununurra looking at service provision to remote Aboriginal communities. They are totally underprepared for what's about to occur. The concept of having a choice of provider in a place like Balgo, which is a four-hour car ride from Halls Creek, which is a long way from anywhere to start with, is ludicrous. If we don't actually aggregate demand in some of those communities, you'll never get a provider. Things we all take for granted, like public transport, don't exist in those places. There is no ability for people to move from one place to another to access a service. Actually getting the service provision organised to happen in that community is going to be hugely difficult, and Balgo is one of the larger ones. In the smaller communities, it's going to be almost impossible to organise a provider, let alone a choice of providers. So I think there does need to be a rethink about service provision, particularly in remote and regional Western Australia, which is very different from most of the rest of Australia in terms of the facilities and the infrastructure that are available.

Senator BROCKMAN: In the Northern Territory, for example, we heard that some of the Aboriginal health services are starting to think about and take on these roles and take an active service provision role under the NDIS. Is that starting to occur in Western Australia as well?

Mr Searle : There's the odd medical service that's having the discussion. I haven't heard them on a widespread level. That might be happening, but I'm not aware of them.

Senator BROCKMAN: Is it part of your role to engage with those health services or is that NDIA?

Mr Searle : Technically, it's NDIA. The transition is NDIA's responsibility. We think we're in a pretty good position because there are lots of individualised plans already, and it's up to them whether they just pick up those plans and migrate them from one system to another, which would give them a pretty good head start. We think the transition timetable is ambitious—says he, using a euphemism—but we're really keen to try and help them, because, for us, there are a range of issues about post NDIA, such as the role of the state government in the disability sector in terms of people who aren't covered by NDIA, by which I mean non-Australian citizens. They become an issue for us, in particular, in terms of the role of the state as provider of last resort when there are no providers or when people aren't prepared to provide at a pricepoint. Also, systemic advocacy is one of the things that block funding has tended to pick up to some extent. Once you're only funded for individual services, who picks up the role of systemic advocacy and who funds it?

CHAIR: Can I just take that up with you, Mr Searle, because my clear impression from discussions with the NDIA on numerous other occasions during these inquiries is that there's been a reluctance on the part of the agency to actually start to engage in these issues. And they're real issues. As you say, if there are no services on the ground now, we're not going to magically create them in the future because we've changed the nature of the beast that's actually meant to be delivering services. And I know it's not your responsibility, but what I think this committee would be interested to hear is your impression of whether or not the NDIA is engaged or sufficiently engaged in this sort of conversation, which is, I suspect, going to be inevitable, and the sooner we have it the better.

Mr Searle : We have started discussions with NDIA. We're meeting with them regularly. We are hopeful that they'll get a finer appreciation of the particular difficulties in regional or remote Western Australia than they have at the moment.

Ms Hailes-MacDonald : The other argument to add to that may be that we need to actually look at different funding models, in that, in some instances, individualised funding may not be the best approach, particularly when you look at different communities.

CHAIR: Indeed, and I'm not going to speak for the committee, but it strikes me personally that, at least in some circumstances, some sort of hybrid model is going to have to emerge, not because of some ideological commitment to one or the other but because of the practical reality. Services have been delivered to people with disability in remote and rural areas facing all the challenges for decades now. We're not suddenly going to change the demographics or the four-hour car trip from Halls Creek to wherever it was, Mr Searle. Those things are realities which are fixed, and somehow, this scheme has to find a way of meeting those challenges. That was me editorialising.

Senator STEELE-JOHN: Can you explain your observation around some situations in which individualised funding might not be ideal? We've talked a lot about remote and regional, but has your thought process moved beyond there in terms of demographics or areas in WA where you don't see that potentially working in the long term?

Ms Hailes-MacDonald : I won't say it's moved beyond that; it's moved broader than that. There are some services, such as very specialised services, where you need them immediately, and that might be for specific behaviours. You need the expertise and you need to retain that expertise. It's not the sort of thing that you can do with individualised funding. You almost need a fixed cost to actually have the availability of the service, and you might then look at topping up with individualised funding. Another example would be in the case of emergency or a critical incident. You need the capability. It's a bit like a hotel, where you need to have the place open to be able to access it, and you've generally got people there, and you've generally got an occupancy rate, but you need the availability. You are just asking for service providers to keep a place open in case. Those are some of the areas where I actually see that you might need it. For argument's sake, another one might be the independent living centres, which I'm sure you're aware of. They actually have loans and trials of equipment, but, to actually maintain the expertise to assist people, or even the capital cost of that, is probably not going to always be funded through individualised funding. Yet, it saves cost in the longer term because people get the right equipment.

Senator STEELE-JOHN: With something like the independent living centre, though, wouldn't there be a space for perhaps a modified form of ILC grant to keep something like an independent living centre going, rather than tinkering with the individualised funding system?

Ms Hailes-MacDonald : Quite possibly, and that's my suggestion. I just think we need to think more broadly than only individualised funding. There needs to be consideration of different models of funding relative to the services that one wishes to have available and that people with disabilities need.

Senator STEELE-JOHN: As you say—and we've repeated it ad nauseam already, I would imagine—there is the principle of individualised funding and its relationship to choice and control. I would hate to see somebody with a disability robbed of that ability to have choice and control simply because of the tyranny of the geography of WA and the effect that that has on costing.

Mr Searle : Senator, that is the last thing we're aiming for. The last thing we want to do is take control away from individuals as in an individual's choice. WA has been on this journey for a long time and we are very supportive of it. What we are saying is that there are some things and some bits of the system, some tiny bits, that don't lend themselves to that style of funding. At a very simple level: riding for the disabled is a service which is funded currently. Going to an individualised funding model may well make their lives very difficult for a period of time, and the organisation might not survive that sort of trauma. So we need to rethink those sorts of organisations so that we can make sure the transition is smooth. It is that sort of thing I am talking about, not taking away an individual's choice.

Senator STEELE-JOHN: I do agree with you there, with that example. Just going to your Sector Development Plan more broadly, we're going to see, as we all know, this as a challenge but also a massive opportunity, to my mind, to kill two birds with one stone. We need to give more people more services than they are currently getting. We all know that there is an employment problem in relation to disability as well. Some of the best services are provided and created through a process of co-design and peer working relationships. I am wondering whether—and I haven't read through the plan in detail—the department put any thought into how it might work with the sector to ensure that its jobs growth need is partly met as much as possible by employing people with lived experience.

Ms Hailes-MacDonald : Much of the work done to date has been done in co-design, and that is people with disabilities, their families, the sector and the government. That has been identifying what people need and then working out the best way to deliver it. There have been various forums. There have been advisory committees and reference committees that have had people with disabilities and people with lived experience and/or carers on those committees.

Senator STEELE-JOHN: They were participating in that approach. I didn't mean the formulation of the plan. I mean, in terms of the plan itself, is there within it any kind of work or target or quota saying that you will need X amount of jobs to fill this gap, and ideally you would aim to fill X amount of those jobs with workers with lived experience of disability.

Ms Hailes-MacDonald : At this stage, the WA Sector Development Plan, which was commissioned with the National Disability Services and undertaken by a consultant, brought us the numbers and the recommendations of what needed to be done with an anticipated need of about 10,000 workers required. The plan is still being developed in terms of the actual implementation, but with the actual implementation will certainly be the factors of co-design as we move forwards.

Senator STEELE-JOHN: So you will co-design the implementation moving forward, which is great, but I'm just wondering whether, with that implementation recommendation, your mind has turned to how you might support and recommend the sector that they meet this need in part by employing people with a disability as part of the sector. There is a massive dividend in there, as you would know, but unless you plan for it, unless you take active steps to facilitate that process of the sector actually employing more people with a lived experience, it won't happen for a number of different reasons, which I am sure we here are all familiar with. Has the department's focus shifted at all to that in terms of the implementation process?

Ms Hailes-MacDonald : In terms of the thinking, yes. In terms of the act of development of a plan right at this stage, we are not at that stage right at the moment. So that will take us forwards—

Senator STEELE-JOHN: But it is on your radar for something to include within the plan?

Ms Hailes-MacDonald : Absolutely. In fact, in the department of communities and disability services, we have just over three per cent of people with disabilities. That excludes people who have lived experience by virtue of being a carer. Many of our staff have caring responsibilities for either children or offspring adults with disabilities.

Senator STEELE-JOHN: Fantastic. Could I take you to a specific element of the sector that concerns me around interpreter services for the deaf community. You would be aware that there is quite a serious shortfall in WA in the number of interpreters available, and that has a flow-on effect with price. There is a direct WA government link here, because of the way that the state government facilitates accreditation through TAFE. Has the department made any recommendations to the government or been thinking about how the state government here in WA might facilitate the growth of that particular sector? I think one estimate given to me by the Deaf Society of WA was somewhere in the region of 12,000 additional interpreters could be needed. Has any thought gone into that, specifically?

Mr Searle : Explicitly, none that I can remember; implicitly, part of our database includes the nature of special requirements in households, so not just the deaf but languages, Aboriginal languages, et cetera. That is included in our database, so it is certainly something that we are aware of and focused on in terms of our service delivery. Having thought about it across the sector—I am relatively new so I don't have that background—I think it is certainly something that we take into account.

Senator STEELE-JOHN: It's a massive challenge, because you've got a bottleneck right now in the WA TAFE system and the accreditation process for becoming an Auslan interpreter. You are going to have a situation where a tonne of people who had never been able to access that service will now be able to access it in a way that they had never been able to access it before, which is actually in terms of their need for an interpreter. There will be a demand supply crisis, unless the government makes it easier and puts a bit more money into these training courses.

Mr Searle : I am happy to undertake to go and look at that. We actually employ an Auslan interpreter for all of our departmental presentations to our staff, so it is something that we are aware of and we use.

Senator STEELE-JOHN: You would be aware of the cost.

Mr Searle : I'm happy that we will go away and talk to our colleagues at TAFE around the process and whether it can be improved.

Senator STEELE-JOHN: I would very much appreciate that. Did you say that the Department of Communities has got three per cent of people with lived experience? Is that a result of a target or a quota or was it naturally occurring? Do you have a target or a quota?

Mr Searle : Both. We have targets for most employment groups, particularly around Aboriginal employment. But it is also an organisation which, by its nature, attracts people who have the lived experience from either side as a carer or as someone with a disability.

Senator STEELE-JOHN: I am particularly interested in employment in this space and where we are in relation to the transition. If you were able to provide the committee with information regarding that figure for other departments that would be very useful—not all of then. Don't kill yourself over it. It would be really good to know the comparison rate between the Department of Communities and other departments.

Mr Searle : We are happy to ask our Public Sector Commission if they have the data.

Senator STEELE-JOHN: Wonderful. Thank you.

Ms Hailes-MacDonald : The other addition I would make to that is that, in terms of the number of people with disabilities, it is about people who declare having a disability. Many people in the workplace don't declare their disability for various reasons. So, it is only the declared number.

Senator STEELE-JOHN: I understand that. There is a broader challenge around the way that the Commonwealth collects data in relation to disability, particularly in that deaf and Auslan space. As you would know, you can't find an accurate figure as to how many people actually require those services, because the census doesn't collect it. I do understand the challenge.

CHAIR: I have just a couple of final things. Some of the service providers have indicated disquiet about the McKinsey recommendation in relation to the two-tiered funding approach and have suggested that this will lead to the lack of provision of services for a substantial number of people because of the price differential. Have you had any sense or feedback about that?

Ms Hailes-MacDonald : I'm not sure of your interpretation of 'two-tiered' approach, in that—

CHAIR: It's their interpretation rather than mine. It's a concern that's been raised. I'm just wondering how widespread it is.

Ms Hailes-MacDonald : The concern I've heard raised is not just with respect to the tiered approaches because the McKinsey report has come through with different tiers in different areas. What I have heard is that the concern has been a general concern about the report and the fact that, in their view, it hasn't addressed the root cause of the issues, rather than—and it also provided limited evidence or analysis of how they reached their recommendations.

CHAIR: Are you able to indicate how widespread that concern is, at least, from the feedback you've heard?

Ms Hailes-MacDonald : The best person to ask would be Julie Waylen, who I believe will be appearing before the committee. She is the chairperson of the WA National Disability Services and would have the benchmark of what the sector feeling is. I can just go on the part of the sector I hear from, and certainly it's widespread.

CHAIR: That's useful. I'm going to ask you a question about something, and I don't know why I'm asking you the question, except that it was suggested to me. Carers Western Australia has the White Card system that operates here, I was told, but I didn't get sufficient details about it. There is a concern about the relationship between how that will operate in the future and the NDIS. You're looking as quizzical as I am, in terms of even asking the question.

Mr Searle : I think I understand where the question is coming from. It's apparent that there are a range of concerns at the moment about how you control people who are working in various sectors. We've had the Working With Children Card for a long time. There are now discussions about whether we need a similar thing for seniors. I think it's only a matter of time before there's a more pointed discussion in this space. My concern, as a bureaucrat, is that we will end up with this plethora of individual cards that all fundamentally do the same thing but are all different. So in terms of any step towards saying that if you're dealing with vulnerable people, you need a card or a ticket—and the Working with Children Card is the one that I think is probably being referred to—I would support some sort of consolidation of that function rather than a proliferation of separate cards for separate sectors.

CHAIR: As I said, I wasn't even sure what I was asking about, except that somebody suggested to me that I should ask the question.

Mr Searle : It would make sense that that's the question.

Senator BROCKMAN: That is actually a really good point. Do you know if any other jurisdictions have gone down the path of harmonising a working with vulnerable people type approach?

Mr Searle : Not yet that I'm aware of, but it's certainly a discussion we've started to have in Western Australia. On the national committees we're involved in, we're starting to make that suggestion about being sensible about this stuff up-front and trying to consolidate, so that it has some title like a 'working with vulnerable people card'.

Senator BROCKMAN: That's a very good point.

Ms Hailes-MacDonald : And it's also the intention of the NDIA's quality and safeguarding system to have a National Disability Insurance Scheme worker clearance card, although it might not be called that. Every employee would need to have the card. The question is how far that will extend in terms of volunteers et cetera. That's being worked out at a national level.

CHAIR: I thank you both, first of all for the submission to the committee, and, more importantly, for coming along and discussing it with us this morning. Significantly, thank you for the frankness of your comments in relation to some of these ongoing issues that obviously will need to be addressed.