Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697643501848.pdf (Australia)
Submission in response to the Parliamentary Enquiry into Independent Assessments March 2021 RCAA® Rehabilitation COlnelUng Assooationd Australasia 1 https://rcaa.org.au Independent AssessmentsSubmission 244 2 Independent AssessmentsSubmission 244 Table of Contents Preamble…………………………………………………………………………………….4 Terms of Reference C ……………………………………………………………………..5 Terms of Reference D …………………………………………………………………….

7 References………………………………………………………………………………….


8 3 Independent AssessmentsSubmission 244 Preamble for tertiary qualified The Rehabilitation Counselling Association of Australasia (RCAA) is the peak professional body throughout Australasia.

Established in 2003, RCAA was formed out of recognition of the need for a Rehabilitation Counselling professional organisation with entrance criteria consistent with Allied Health Professions currently practising in Australia.
As a result, RCAA represents a single profession, of which members are required to hold tertiary qualifications in rehabilitation counselling.
rehabilitation counsellors RCAA deliverables include: • Self- regulation of the profession; • Membership of Allied Health Professions Australia (AHPA); • Membership of Career Industry Council of Australia (CICA); • Accreditation of Rehabilitation Counselling education programs at Australian Universities; • Robust Australian Competency Standards and Code of Ethics; • Access to current local and international research through subscriptions to the Australian Rehabilitation Research Review and the International Journal of Disability Management; • Continuing Professional Development (CPD) requirements, resources and education to ensure members remain abreast of current evidence-based practice frameworks.
RCAA is the sole accrediting body of Rehabilitation Counselling degrees at The University of Sydney and Griffith University, the primary providers of qualified rehabilitation counsellors in Australia.

RCAA also accredits Rehabilitation Counselling degree at Flinders University.

In addition, RCAA is a member of Allied Health Professions Australia (AHPA) and the Career Industry Council of Australia (CICA).
RCAA supports the inquiry into Independent Assessments and the opportunity to provide comment on several of the terms of reference.

Allied health professions play an important role in the National Disability Insurance Scheme, in facilitating access to the scheme and provision of therapies and supports.
Rehabilitation Counsellors (RCs) help facilitate social, educational and economic inclusion and participation for people experiencing illness, injury, disability or disadvantage through assessment, case management, case coordination and counselling.
Local and international rehabilitation counselling competency research undertaken over an extended period has identified vocational counselling, professional practice, personal counselling, rehabilitation case management, workplace disability case management, and workplace intervention and program management as important and frequently used job functions and knowledge areas (Biggs, Herbert Charles & Flett, Ross, 1995; Leahy, Chan & Saunders, 2003; Matthews, Buys, Randall, Biggs & Hazelwood, 2010).
Core competencies in vocational assessment have long been established within the profession of Rehabilitation Counselling (Black, 2018).

4 Independent AssessmentsSubmission 244 In this submission we will be providing feedback and recommendations in relation to: c. the human and financial resources needed to effectively implement independent assessments; and; d. the independence, qualifications, training, expertise and quality assurance of assessors.
C. The human and financial resources needed to effectively implement independent assessments.

It is frequently reported that there is a significant shortage of Allied Health Professionals to provide services NDIS for participants.

There are extensive waitlists for assessments to support access requests and to provide therapeutic interventions once participants are approved for services.
The NDIS guidelines for types of disability are unclear as to which professions NDIS will accept evidence from in relation to some disabilities.

For example, the guidelines for a primary diagnosis of Acquired Brain Injury states any member of a multidisciplinary team can provide the evidence and that Care and Need Scale (CANS) and World Health Organisation Disability Assessment Schedule (WHODAS) should be completed as part of the evidence.
Additionally, the guidelines pertaining to psychosocial disability state clinical psychiatric staff and Mental Health Allied Health Professionals can provide evidence, with requirement for Life Skills Profile, Health of the Nation Outcomes Scale and WHODAS to be completed as part of the assessment.
Anecdotal evidence from RCAA members who work in the NDIS space suggests that Support Coordinators and Participants are often of the belief that these assessments can only be completed by an Occupational Therapist or a Psychologist and as such there are often lengthy waitlists for these assessments to be completed.

For example, the current waiting period for a functional assessment is 4 to 12 months.
It is necessary to promote a better understanding of the skills and knowledge of other professions, such as rehabilitation counselling, to maximise access to address the scope and diversity of client needs.
RCAA recommends that greater clarity be provided by NDIS regarding which professions can provide evidence about an individual’s disability, so that participants are armed with appropriate knowledge and support coordinators can assist in educating NDIS participants about the range of allied health professionals with relevant expertise.
It is anticipated that this would alleviate waitlists and staff shortages, as well as improve on the quality of assessments for individuals with diverse needs to supporting the independence and social and economic participation of people with disability.

5 Independent AssessmentsSubmission 244 Similarly, NDIS guidelines require a letter from an Allied Health Professional outlining the therapeutic need for technology, such as laptops, and their relevance to participant goals.
Again, anecdotal evidence from our members suggests that many participants are of the belief these letters must be completed by an Occupational Therapist, so better education around which professions can provide written support is recommended, to again address waitlist issues, perceived staff shortages, and access.

This would also increase individual choice and control for people with disability to access a range of relevantly qualified professionals.
RCAA recommend that Rehabilitation Counsellors be noted as a profession to provide evidence of function and need especially for participants with acquired brain injury and psychosocial disability.

Rehabilitation Counsellors are also qualified to undertake comprehensive needs assessments and support coordination within the NSW Lifetime Care and Support Authority and National Injury Insurance Scheme Queensland (NIISQ), both of which are catastrophic injury schemes.
RCs working in the catastrophic injury space regularly administer the Care and Needs Scale (CANS) and WHODAS as part of the Needs Assessment process, so are well equipped to provide NDIS Functional Assessments or Needs Assessments to participants with complex conditions.
In accordance with line Section 33 of the Act and Section 4 of the NDIS Rules 2013, Rehabilitation Counsellors are specifically qualified to work with people with disability to identify goals, aspirations, strengths, capacity, circumstances and context (Australian Government, 2013).

Rehabilitation Counsellors are well placed to provide evidence of impact on function for people with psychosocial disability given their historical involvement in psychiatric rehabilitation.
For nearly 30 years, Rehabilitation Counsellors have been offering specific expertise in vocational and psychosocial interventions to people at-risk of, and managing diagnosed mental illness (Garske, 1992).

Rehabilitation Counsellors also have an extensive history of completing Allied Health Assessments for Centrelink and understand the impact of mental health on occupational functioning and effects of medication on areas such as energy and executive function.
Rehabilitation Counsellors are highly trained and experienced in working with and disseminating information to multidisciplinary treatment teams.

Members of the profession have the demonstrated competency standards to deliver an extensive range of rehabilitation services for people experiencing mental illness, as evidenced by recent General Practitioner clinical guidelines published by Monash University (Mazza, Brijnath, Chakraborty, & the Guideline Development Group, 2019).
6 Independent AssessmentsSubmission 244 D. The independence, qualifications, training, expertise and quality assurance of assessors Rehabilitation Counsellors who are full members of RCAA have the required knowledge of disability to perform independent assessments (Matthews, Buys, Randall, Biggs & Hazelwood, 2010).

All RCAA members demonstrate the requisite skills and knowledge in disability needs and perspectives in their core studies.
Rehabilitation Counselling students undertake training in major models of disability such as medical, social, and biopsychosocial, together with training in disability theories and practices such as Social Role Valorisation, Restrictive Practices and Independent Living.

They also develop knowledge and understanding of the functional impacts of a wide range of disabilities including developmental, intellectual, neurological, psychosocial, physical and acquired.
RCs are trained to review and interpret medical information, to identify and understand the aetiology of disabilities, how they may present and the impact of disability on life domains.

Rehabilitation Counsellors undertake comprehensive needs assessments to understand functional impacts of disability, providing evidence-based recommendations to mitigate the impacts and support goal achievement.
Disability knowledge is a central competency standard of the profession and is an ongoing curriculum requirement of RCAA accredited programs.

RC knowledge of disabilities is already recognised and accepted within a number of assessment domains including Catastrophic Injury Schemes, Capacity Assessments for Centrelink and Job Access Assessments such as Supported Wage Assessments.
As an accrediting body, RCAA is confident about the qualifications, training and expertise of our members completing Independent Assessments.
In response to publicly raised concerns about the use of Independent Assessments, RCAA recommends that: • the six professions proposed to deliver Independent Assessments also be listed as the professions approved to provide supporting evidence of function or need; • an assessment and report writing time limit cap be developed following consultation with the professional bodies representing the 6 professions; • participants can access the assessments at no cost; and • a new department within the NDIA be created to support the management of costs associated with delivery of assessments.
• Clinicians providing these assessments should not be limited to just AHPRA registered professions.

Other forms of assessment which measure eligibility for services/income such as assessments completed be Allied Health staff at Department of Human Services are provided by both AHPRA registered and self-regulating professions.

AHPRA registration is concerned with level of risk to the public and is not an endorsement that a profession is more suited to work with a particular group or cohort.
7 Independent AssessmentsSubmission 244 References Australian Government (2013).

National Disability Insurance Scheme (Supports for Participants) Rules 2013.

Accessed 30th March 2021 from https://www.legislation.gov.au/Details/F2013L01063 Becker, D; Bond, G., & Oulvey, E. (2015).

Individual Placement & Support Model of Supported Employment: Translating Research for Vocational Rehabilitation Practice Biggs, Herbert Charles & Flett, R. A.

(1995).
(1995).

Rehabilitation counsellor competency studies: a review of praxis in a human service profession.

The Australian Journal of Rehabilitation Counselling, 1(1), pp.

1-12.

Black, M. (2018).

Employability Assessment in Total and Permanent Disability Insurance Claims.

Retrieved from https://www.metisrehab.com.au/downloads/Black_ME_Thesis_2018.pdf Butterworth, P., Leach, L. S., McManus, S., & Stansfield, S. A.

(2013).
(2013).

Common mental disorders, unemployment and psychosocial job quality: is a poor job better than no job at all?

.

Psychological Medicine, 43(8), 1763-1772.

Buys, N., Hensby, S., and Rennie, J.

(2003).

Reconceptualising the vocational rehabilitation process using a career development approach.

Australian Council for Educational Research Buys, N., Matthews, L. R., & Randall, C. (2014).

Contemporary vocational rehabilitation in Australia.
Disability and Rehabilitation, 37(9), 820-824. doi:10.3109/09638288.2014.942001 Drake, R. E., & Bond, G. R. (2014).

Introduction to the special issue on individual placement and support.

Psychiatric Rehabilitation Journal, 37(2), 76-78.

Garske, G. G. (1992).

Working with people who have severe psychiatric disabilities.

American Rehabilitation, 8(2), 23-27.

Iles, R. A., Davidson, M., & Taylor, N. F. (2008).


Psychosocial predictors of failure to return to work in non-chronic non-specific low back pain: a systematic review.

Occupational and Environmental Medicine, 65(8), 507-517.

Katz, L. J.

(1991).

Interagency collaboration in the rehabilitation of persons with psychiatric disabilities.

Journal of Vocational Rehabilitation, 1, 45-57.

Kent, P. M., & Keating, J. L. (2008).

Can we predict poor recovery from recent-onset non-specific low back pain?
A systematic review.

Manual Therapy, 13(1), 12-28.

Leahy, M.J, Chan, F., & Saunders, J.L.

(2003).

Job Functions and Knowledge Requirements of Certified Rehabilitation Counselors in the 21st Century.

Rehabilitation Counseling Bulletin, 46 (2), Matthews, L.R., Buys, N., Randall, C., Biggs, H., & Hazelwood, Z., (2010).

Evolution of vocational rehabilitation competencies in Australia.

International Journal of Rehabilitation Research, 33, 124-133.
8 Independent AssessmentsSubmission 244 Mazza, D., Brijnath, B., Chakraborty, S. P., & the Guideline Development Group.

(2019).

Clinical guideline for the diagnosis and management of work-related mental health conditions in general practice.

Melbourne: Monash University.

Modini, M., Joyce, S., Mykletun, A., Christensen, H., Bryant, R. A., Mitchell, P. B., & Harvey, S. B.

(2016).

The mental health benefits of employment: results of a systematic meta-review.

Australas Psychiatry, 24(4), 331-336.


The Royal Australasian College of Physicians and the Australasian Faculty of Occupational and Environmental Medicine.

(2013).

What is good work?

Position Statement.

Retrieved from https://www.racp.edu.au/advocacy/division-faculty- and-chapter-priorities/faculty-of-occupational-environmental-medicine/health- benefits-of-good-work van der Noordt, M., IJzelenberg, H., Droomers, M., & Proper, K. I.

(2014).
(2014).

Health effects of employment: a systematic review of propective studies.

Occupational and Environmental Medicine, 71(10), 730.

Wagner, C. & McMahon, B.T.

(2004).

Motivational Interviewing and Rehabilitation Counseling Practice.

Rehabilitation Counseling Bulletin, 47, 162-161.

9 Independent AssessmentsSubmission 244