Submission on ILC Commissioning Framework

Mental Health Australia made two submissions on the draft Commissioning Framework for Information, Linkages and Capacity Building. The first submission focussed on the details of the ILC Commissioning Framework, and its implications for people with psychosocial disability.

It recommended that:

• the outcome of the audit ILC-type services be released, and that no existing service has their funding cut until ILC commences in their area.
• the NDIA amends the Commissioning Framework to reflect the important role of ILC and LACs in outreach.
• the NDIA amends the ILC Commissioning Framework to place an emphasis on identifying and supporting potential participants from Indigenous, CALD, homeless and other disadvantaged backgrounds, into the NDIS.
• the Commissioning Framework clearly state that ILC funding is not to be used to meet the continuity of service requirements. 
• until ILC is rolled out in each area, the NDIA funds PIR organisations to maintain their existing system reform and sector capacity building projects.
• the NDIA analyses the recommendations of the PIR evaluation and the successes of the PIR innovation fund, and incorporate relevant learnings into the ILC Framework.
• the NDIA explore joint contracting/commissioning models with other Commonwealth agencies and states/territories, in order to deliver the best outcomes for consumers.
• the Commissioning Framework return its focus to the Productivity Commission’s and Policy Framework’s intention that many ILC supports will be targeted at people with disability who:
  • need one-off, low intensity or episodic supports that are better delivered and managed through funding arrangements other than through IFPs; and 
  • need support so that their capacity to live independently does not deteriorate to a point where they would meet the access criteria for the NDIS.
• prior to the ILC Commissioning Framework being finalised, the NDIA publicly release estimates of the number of people who are likely to be reliant on services provided by ILC providers.

The second submission focuses more broadly than mental-health specific issues within the draft ILC Commissioning Framework, and instead considers the issues around preparing the sector for the proposed outcomes-based commissioning being proposed by the NDIA.

Many aspects of service providers’ costs are fixed, or related to the number of clients, rather than the number of client-hours. This includes, for example, ICT infrastructure. As the NDIA’s recent discussion paper on personal care and community participation notes that funders “have [not] supplied the tools and/or additional funding to” measure or improve efficiency, and “donors have often seen operation reviews as not ‘core’ to the mission of the NFP.” In practice, this has meant a significant under investment in ICT (and related workforce skills) and other functions that are essential to the running of an organisation but not directly related to service provision.

The Productivity Commission’s report on the Contribution of the Not-for-Profit Sector noted that “[g]overnments could better tailor their support to promote development of relevant intermediary services and greater adoption of ICT to build sustainable capacity” and that “[g]overnments engaging in sector development activities should ensure that ICT issues are mainstreamed and that NFPs develop ICT strategies along with other business development planning.” The importance of funding ICT for providers in human services has long been recognised in health, and is particularly warranted when the government is enforcing significant system changes on providers.

For at least the last 13 years, the Australian Government has continually provided financial support to the medical sector (in particular GPs) to adjust to new payment processes and ICT requirements on a ‘per patient’ basis. Currently, this is around $6.50 per patient per year. Substantial one-off payments have been made to practices to improve ICT capacity and to implement electronic health records. Based on this, the submission recommends that:

• the Agency works with other parts of government (including IHPA) and non-government mental health stakeholders to ensure alignment and compatibility of data framework and systems;
• funding be provided to service providers to upgrade IT and data collection capacity, in recognition of both the variability in current approaches to data collection and the likelihood that the NDIA’s data requirements will change as the Scheme evolves;
• funding be provided to ICT companies to support the development and implementation of suitable software specifically tailored for NDIS providers.

The submission also considered the suitability of the proposed outcomes and outputs measures. Mental Health Australia, in consultation with monitoring and evaluation experts, has undertaken some initial analysis of the proposed measures, and this analysis is attached to the Submission. Our analysis indicates that the proposed indicators need significant further consideration. Issues include:

• It may be difficult to attribute the desired outcomes to the outputs provided through ILC funding.
• The data is unlikely to be collected in a timely enough manner to improve programme management and is unlikely to contribute to learning around appropriate programme design.
• The indicators are often too highly aggregated.
• The indicators are often imprecise or not well defined.

In addition, the measures mainly relate to people who “turn up” and seek assistance, with relatively few measures that would incentivise ILC providers to engage in assertive outreach with marginalised people who have the greatest need for support. Therefore, the submission recommended that the proposed outcomes, outputs and indicators be reviewed to ensure they meet best practice in monitoring and evaluation and align with work being undertaken elsewhere within government.