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Department of Communities Tasmania

Review of the Disability Services Act 2011

Tasmanian Government Response to the Review

Draft - Version: 1.0a

ContentsBackground 5

Recommendations of the Review 6

Assessment against Recommendations 8

Proposed amendments to the Disability Services Act (2011) 16

Matters to be addressed by Communities Tasmania 17

Appendix 1 Disability Services Act 2011 Review Committee – Terms of Reference 18

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Matters to be addressed by Communities Tasmania

BackgroundThe Review

Section 53 of the Disability Services Act 2011 (the Act) stipulates that an independent review of the Act be undertaken “as soon as practicable after the third anniversary of its commencement”.The review that was due in 2015 was delayed due to the national reform agenda and development of national policy areas, in particular the rollout of the National Disability Insurance Scheme (NDIS).In July 2017 the Minister for Human Services (now Minister for Disability Services and Community Development) endorsed the recommendation by the then Department of Health and Human Services (DHHS) for the Disability Services Act 2011 review (the Review) to proceed with a focus on the Act’s operational effectiveness since implementation. Specifically, the Review was to consider: the operational effectiveness of the Disability Services Act 2011 since

implementation; interoperability of the Disability Services Act 2011 with other legislation; and issues with the Disability Services Act 2011 which have arisen as a result of the

Tasmanian Bilateral Agreement for transition to the NDIS. To initiate the Review, the DHHS convened an independent Review Committee (the Committee) with broad representation. In addition to responding to the Terms of Reference (Appendix 1), the Committee sought to establish how well the Act has delivered, or not delivered, benefits to people living with disability. The Review was intentionally a small scale initial review of the current operations of the Act. A full-scale review and rewrite of the Act will occur after Tasmania has fully transitioned to the NDIS in 2019. The Committee commissioned an independent consultant, Fae Robinson, Principal Consultant, Fae Robinson Futures to conduct public and stakeholder consultations, analyse feedback, and assist the Committee to prepare a Review report for the Minister.The Committee’s work concluded when it commended the Review of the Disability Act 2011 – Report of the Review Committee (the Report) to the Minister on 29 June 2018. Current Status

The Report is now a public document, having been tabled in Parliament on Thursday 5 July 2018 and placed on the Department of Communities Tasmania (Communities Tasmania) website.The Minister has publicly acknowledged the Report and its recommendations and announced that the Government will consider the recommendations.Moving Forward

The purpose of this document is to:

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initiate assessment of the recommendations; identify recommendations that will be actioned with an amendment of the Act; identify recommendations that will be referred to the future review of the Act; identify recommendations that do not require an amendment; and identify recommendations that were out of scope of the Review Terms of

Reference, but will still be considered as actions by Communities Tasmania.

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Recommendations of the ReviewThe Review provided 19 recommendations presented under 5 headings and further categorised against strategic themes. The recommendations and related themes are as follows:Operational effectiveness in the delivery of safe, quality services

Theme 1: Interpretation and Principles

1. Amend the Disability Services Act 2011 to harmonise definitions with those in the National Disability Insurance Scheme Act 2013 (NDIS Act).

2. Align the Disability Services Act 2011 with the Convention on the Rights of Persons with Disabilities and other international obligations.

Theme 2: Inclusion and control in planning and reporting

3. Develop consultation policies that deliver comprehensive and genuine engagement with people with disability, taking full account of their needs and circumstances.

4. Ensure appropriate, inclusive engagement with people with disability is included in future disability services legislation.

Theme 3: Protection, compliance and accountability

5. Work with the NDIS Quality and Safeguards Commission’s Complaints Commissioner to ensure they are acting in the interests of people with disability in Tasmania in a timely manner.

6. Ensure workers in the disability sector in Tasmania are held accountable to an appropriate Code of Conduct.

Theme 4: Role of Senior Practitioner

7. Amend the Disability Services Act 2011 to articulate recognition that the role of the Senior Practitioner is to act independently in relation to matters under Division 4 of the Act – ‘Investigations and directions’.

8. Ensure the independence of the role of the Senior Practitioner is prioritised in the development of new disability services legislation and is in alignment with the role of the Senior Practitioner outlined in the NDIS Quality and Safeguarding Framework.

Theme 5: Restrictive interventions

9. Insert an authority under the Disability Services Act 2011 to allow interim authorisations for restrictive interventions to be granted subject to appropriate safeguards.

Theme 6: Information sharing

10. Amend the Disability Services Act 2011 to improve the scope and effectiveness of information-sharing provisions.

Theme 7: Children and young people 5

11. Publish and disseminate information, including a Fact Sheet, that clarifies how children with disability are included in the Act, having regard to international obligations (Convention on the Rights of the Child and Convention on the Rights of Persons with Disabilities) to children and young people.

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Interoperability with other Tasmanian legislation

Theme 8: Legislative alignment

12. Clarify the scope of the Disability Services Act 2011 in relation to children with disability in different settings, for example, home, school.

Legislative issues during transition to the NDIS

Theme 9: Individual plans

13. Review and revise approval processes at Sections 11(2)(b) and 12(4) of the Disability Services Act 2011 to ensure the policy framework of ‘choice and control’ replaces the need for approval of plans by the Secretary or any other entity.

Issues outside scope of the Review

Theme 10: Support for advocacy

14. Work to ensure independent advocacy, inclusion and support organisations continue to be viable and meet the needs of people with disability.

Theme 11: Worker training

15. Continue to invest in education, training and capacity building for disability support workers in Tasmania.

Theme 12: Communication and education

16. Develop and implement a targeted stakeholder engagement strategy that builds understanding of the protections, possibilities, authorities, and responsibilities conferred under the Disability Services Act 2011.

Theme 13: Client experience during transition

17. Provide feedback to the National Disability Insurance Agency about participants’ experiences during the transition process to the NDIS.

Theme 14: Planning for the future

18. Work with stakeholders to ensure services are delivered in line with the requirements of the National Disability Strategy 2010-2020 and Accessible Island: Tasmania’s Disability Framework for Action 2018-2021 (Accessible Island).

Stakeholder Requests

19. Consider and implement as appropriate, the recommended actions set out in the Matrix of Stakeholder Requests (a list of 60+ issues raised by stakeholders during the consultation process).

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Assessment against RecommendationsAssessment ProcessAgree and action an amendment to the Act as soon as practicableNoted and Agree but defer to future review of the Act post-1 July 2019Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action

Recommendation Assessment Timeframe

1. Amend the Disability Services Act 2011 (the Act) to harmonise definitions with those in the National Disability Insurance Scheme Act 2013 (NDIS Act).

Agree and action an amendment to the Act as soon as practicable. Adopt the General Principles guiding actions under the NDIS Act (Part 4). The Principles will require minor rewording to reflect application in the Tasmanian context rather than the NDIS. In addition to this recommendation consider - NDIS Act - Part 4 Children – Section 76 - Duty to Children or similar – for example: “duty to ascertain the wishes of the child concerned and act in the best interests of the child” or as per UN Convention on the Rights of Persons with Disabilities (CRPD) – Article 7(3) for example: “States Parties shall ensure that children with disabilities have the right to express their views freely on all matters affecting them, their views being given due weight in accordance with their age and maturity, or on equal basis with other children, and to be provided with disability and age-appropriate assistance to realize that right”.

Propose an amendment as soon as practicable.

2. Align the Disability Services Act 2011 with the Convention on the Rights of Persons with Disabilities and other international obligations.

Agree and action an amendment to the Act as soon as practicable. Adoption of the General Principles in the NDIS Act will achieve this recommendation.Also see above (Recommendation 1) with regard to rewording the Act


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for the inclusion of duties to children and/or acknowledgement of the rights of children.


3. Develop consultation policies that deliver comprehensive and genuine engagement with people with disability, taking full account of their needs and circumstances.

Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. Part 7, Section 2 and Part 8, Section 3 in relation to the Strategic Plan and Operational Plan respectively, direct that the Minister shall consult with ‘persons with disability and those who care for such persons’ in the development of these plans. However, the Act doesn’t specify how plans should be developed. Action in response to this recommendation is reflected in commitments under the National Disability Strategy 2010-2020 and Accessible Island: Tasmania’s Disability Framework for Action 2018 – 2021 (Accessible Island).CRPD – Article 4(3) – “In the development and implementation of legislation and policies to implement the present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, states Parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organizations.” The National Disability Strategy 2010-2020 underpins the principles adopted in the CRPD. The principles ensure that people with disability and their representatives are included in developing, designing and implementing policies, programs and services.Accessible Island contains the following Actions:Outcome Area 1 – Inclusive and Accessible Communities - Foster a collaborative approach across agencies, with stakeholders and with

2019-2021 - in line with the Disability Services Strategic Plan (due 1 January 2019).

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http://www.dss.gov.au/our-responsibilities/disability-and-carers/publications-articles/policy-research/national-disability-strategy-2010-2020

the Tasmanian community, to create inclusive and accessible environments for people with disability. Action 1.23 Build working relationships with disability organisations and service providers to provide information and advice on disability issues. This will inform service delivery and policy development and provide a feedback mechanism for people with disability. Action 1.24 Consult with people with disability on the design and implementation of Tasmanian Government policy and legislation.


4. Ensure appropriate, inclusive engagement with people with disability is included in future disability services legislation.

Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. As Above (Recommendation 3) – such consultation would be an outcome of the process described above.

2019-2021 in line with the Disability Services Strategic Plan (due 1 January 2019).

5. Work with the NDIS Quality and Safeguards Commission’s Complaints Commissioner to ensure they are acting in the interests of people with disability in Tasmania in a timely manner.

Noted and Agree but defer to future review of the Act post-1 July 2019. The NDIS Quality and Safeguards Commission will: play a crucial role on behalf of NDIS participants as an overseer of

the quality and safety of services and supports they are accessing through the NDIS;

regulate NDIS providers and investigate and determine complaints and uphold the rights of people living with disability;

ensure a nationally consistent regulatory framework for providers, regardless of how many states or territories they operate in, and

provide nationally consistent protections for NDIS participants. The Tasmanian Quality Assurance and Safeguards Working Arrangements require existing and new providers of NDIS services to

Noted for consideration in development of the Act post-1 July 2019.

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comply with the Tasmanian Quality and Safety Framework for DHHS Funded Community Sector for the transition to full scheme NDIS, or until the NDIS Quality and Safeguarding Framework is implemented. This includes compliance with all Tasmanian legislation, regulations and reporting requirements.

6. Ensure workers in the disability sector in Tasmania are held accountable to an appropriate Code of Conduct.

Noted and Agree but defer to future review of the Act post-1 July 2019. See above (Assessment of Recommendation 5).NDIS Code of Conduct arises from the NDIS Quality and Safeguards Commission and is a requirement for all workers.



7. Amend the Disability Services Act 2011 to articulate recognition that the role of the Senior Practitioner is to act independently in relation to matters under Division 4 of the Act – ‘Investigations and directions’.

Noted and Agree but defer to future review of the Act post-1 July 2019. Re-examine the role of the Senior Practitioner in light of the National Disability Insurance Scheme Amendment (Quality and Safeguards Commission and Other Measures) Bill 2017. As a State Service employee, the incumbent is bound by the code of conduct of the State Service Act which includes the need for employees to work honestly and with integrity, to avoid any conflict of interest and not make improper use of their duties, status, power or authority. The Act gives guidance about how the Senior Practitioner should conduct their duties, in particular to consult with all interested parties, including the person with disability and work with them to reduce the need for the use of a restrictive practice. The provisions set out in the Act and the State Service Act give sufficient protections to avoid risk of lack of transparency, accountability and independence. Noting the above, it is the view that there are sufficient current protections for this role to stay within the State Service.


8. Ensure the independence of the role Noted and Agree but defer to future review of the Act post-1 July 2019. Noted for 11

of the Senior Practitioner is prioritised in the development of new disability services legislation and is in alignment with the role of the Senior Practitioner outlined in the NDIS Quality and Safeguarding Framework.

Re-examine the role of the Senior Practitioner in light of the National Disability Insurance Scheme Amendment (Quality and Safeguards Commission and Other Measures) Bill 2017. See comments above (assessment of Recommendation 7).

consideration in development of the Act post-1 July 2019.

9. Insert an authority under the Disability Services Act 2011 to allow interim authorisations for restrictive interventions to be granted subject to appropriate safeguards.

Agree and action an amendment to the Act as soon as practicable.This amendment would provide for a 90 day provisional approval of a restrictive intervention to cover an interim period before an application is heard and determined by the Guardianship and Administration Board.



10. Amend the Disability Services Act 2011 to improve the scope and effectiveness of information-sharing provisions.

Agree and action an amendment to the Act as soon as practicable.This amendment would relate to information sharing arrangements under the NDIS, consent arrangements, clarification of circumstances where information can be shared, and information sharing with regard to carers and addition of allied health professionals. Alignment of the NDIS Act and other relevant Tasmanian Acts with the Personal Information Protection Act 2004 and the Privacy Act 1988 will be considered under the nationally-aligned Protection and Disclosure of Information Rules.In addition, include the NDIS Quality and Safeguards Commission as an information sharing entity.


11. Publish and disseminate information, including a Fact Sheet

Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action.

Communication strategy and

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that clarifies how children with disability are included in the Act, having regard to international obligations to children and young people.

This work would flow from Recommendation One and the addition of material relating to Duty to Children. DCS to prepare a Guideline to guide interpretation of Act.

Guideline to accompany passing of amendments.

12. Clarify the scope of the Disability Services Act 2011 in relation to children with disability in different settings; for example, home, school.

Noted and Agree but defer to future review of the Act post-1 July 2019.Relates to legislative alignment. Alignment of definitions and terminology, omissions and clarification about which are the prevailing Act(s) e.g. NDIS Act, Education Act 2016 and Youth Justice Act 1997 and Children, Young Persons and their Families Act 1997.


13. Review and revise approval processes at Sections 11(2)(b) and 12(4) of the Disability Services Act 2011 to ensure the policy framework of ‘choice and control’ replaces the need for approval of plans by the Secretary or any other entity.

Noted and Agree but defer to future review of the Act post-1 July 2019.Future practice will need to reflect the NDIS Quality and Safeguarding Framework. Most current requirements relating to Individual Plans will no longer be relevant under future NDIS arrangements.In the interim, Disability and Community Services (DCS) will work with the disability sector on the continued development of a framework in relation to the development of Individual Plans. This will include information relating to consultation with individuals and approvals processes. (Note that Recommendation 13 also constitutes ‘Matters for Communities Tasmania’ to action at page 14.)


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14. Work to ensure independent advocacy, inclusion and support organisations continue to be viable and meet the needs of people with disability.

Noted as outside the scope of the Review Terms of Reference.Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. DCS will continue to participate in work at a national level relating to Advocacy services.


15. Continue to invest in education, training and capacity building for disability support workers in Tasmania.

Noted as outside the scope of the Review Terms of Reference.Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. During transition DCS has supported Sector Development activities and projects to support market, sector and workforce transition in the lead up to full scheme NDIS. This recommendation will in part be achieved via a 2018-19 Election Commitment through which National Disability Services have received $200 000 to support Sector Development activities. These funds are to be used to engage and support the Tasmanian disability sector, including NDIS registered providers and other stakeholders, to assist in the achievement of positive outcomes for Tasmanians with disability.


16. Develop and implement a targeted stakeholder engagement strategy that builds understanding of the protections, possibilities, authorities, and responsibilities conferred under the Disability Services Act 2011.

Noted as outside the scope of the Review Terms of Reference.Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. A communication strategy will be developed to accompany passing of amendments and engagement in a subsequent review of the Act. This strategy will aim to reengage stakeholders about the purpose and main features of the Act.


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17. Provide feedback to the National Disability Insurance Agency about participants’ experiences during the transition process to the NDIS.

Noted as outside the scope of the Review Terms of Reference.Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. There are a range of governance structures in place relating to the NDIS through which the Tasmanian Government can provide feedback on systemic and participant experiences is transition to the NDIS.


18. Work with stakeholders to ensure services are delivered in line with the requirements of the National Disability Strategy 2010-2020 and Accessible Island: Tasmania’s Disability Framework for Action 2018-2021.

Noted as outside the scope of the Review Terms of Reference.Agree but does not require an amendment to the Act – Communities Tasmania or other Tasmanian Government Agency to action. The Tasmanian Government is committed to Accessible Island and each Department has developed an Action Plan.

Communities Tasmania and Department of Health Interim Disability Action Plan 2018-2021 – regular reporting to 2021.

19. Consider and implement as appropriate, the recommended actions set out in the Matrix of Stakeholder Requests.

Matters recorded in the Stakeholder matrix relating to Restrictive Interventions and the Guardianship and Administration Act 1995 will be considered in a future review of the Act. The three following matters (19A, 19B and 19C) were identified as needing to progress to an amendment.


19A - Strategic Plan Section 7(10) – delete reference to ‘purchase’.

Agree and action an amendment to the Act as soon as practicable.The Strategic Plan is available for free on Communities Tasmania website.In addition, this recommendation would also logically apply to Section 8(7) relating to purchase of the Operational Plan.


19B - Section 28(3)(a) Rights of authorised officers after entry to premises – individual is entitled to ‘request’ or has the ‘right’ to have another person present.

Agree and action an amendment to the Act as soon as practicable. Proposed wording - ‘A person with disability who is requested under subsection 2 to answer questions has the right to –

(a) request that another person be present when the person with


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disability answers the questions; …’


19C - Section 36(3) & Section 50(1)(d) -Update References to the Mental Health Act (1996).

Agree and action an amendment to the Act as soon as practicable.Include Chief Civil Psychiatrist in addition to Chief Forensic Psychiatrist.


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Proposed amendments to the Disability Services Act (2011)The following amendments to the Act will be prepared for consideration by the Tasmanian Parliament:In response to Recommendation 1 and 2: Adopt principles contained within the NDIS Act and refine to reflect Tasmanian

context: Part 1, Section 5. Adopt the NDIS Act principles relating to Duty of Care to Children: Part 1, Section 5.In response to Recommendation 9: Introduce provision for interim authorisation for Restrictive Interventions. In response to Recommendation 10: Improve information sharing provisions to ensure alignment with the NDIS Act, the

Personal Information Protection Act 2004 and the Privacy Act 1988 (Commonwealth): Section 50(1).

In response to Recommendation 19: The strategies to address the majority of issues in the Stakeholder Matrix will be influenced by the outcome of the current review of the Guardianship and Administration Act 1995 and the implementation of the NDIS Quality and Safeguarding Framework from 1 July 2019. Therefore, most issues raised in the Stakeholder Matrix will be addressed post-1 July 2019. The following however, will progress to an amendment: Remove reference to purchase of the Strategic and Operational Plans: Part 2,

Sections 7(10) and 8(7). Replace word ‘request’ with ‘right to’ in circumstance where a person with

disability is requested to answer questions by an authorised officer: Part 4, Section 28(3)(a).

Add reference to the Chief Civil Psychiatrist: Sections 36(3) and 50(1)(d).

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Matters to be addressed by Communities TasmaniaThe following matters do not require an amendment to the Act either now or in the future. However, they will be included as actions in the Disability Services Strategic Plan. In response to Recommendations 3, 4 and 18 (noting recommendation 18 is considered out of scope of the Review Terms of Reference): Build working relationships with disability organisations and service providers to

provide information and advice on disability issues. This will inform service delivery and policy development and provide a feedback mechanism for people with disability (as per Accessible Island).

Consult with people with disability on the design and implementation of Tasmanian Government policy and legislation (as per Accessible Island).

In response to Recommendation 11: Develop a Guideline to assist with interpretation of the Disability Services Act

(2011) as it relates to Children and Young People. In response to Recommendation 13: Enhance the Choice and Control of people with disability through the development

of an Individual Planning Guideline. This Guideline will inform practice relating to preparation and maintenance of Individual Plans.

The following matters were out of scope of the Review Terms of Reference; however, they are recognised as having value and will therefore be considered as Communities Tasmania actions in both the Interim Disability Action Plan 2018-2021 and the Disability Services Strategic Plan (due January 2019). In response to Recommendation 14: Continue to participate in the National Reform Agenda with regard to evolution of

systemic advocacy for people with disability. In response to Recommendation 15: Continue to invest in sector development activities during transition to the NDIS

and beyond. This includes the $200 000 commitment to National Disability Services Tasmania to engage and support the Tasmanian disability sector, including NDIS registered providers and other stakeholders, to assist in the achievement of positive outcomes for Tasmanians with disability.

In response to Recommendation 16: Develop a Communication Strategy to promote awareness and understanding of

the Disability Services Act (2011). This activity will promote understanding of the current Act and assist with a further review of the Act post- 1 July 2019.

In response to Recommendation 17:

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Continue to participate in the National Reform Agenda and governance structures relating to transition to the NDIS. Participation in these processes provides a formal mechanism through which to highlight individual and systemic opportunities and problems arising from transition to the NDIS.

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Appendix 1 Disability Services Act 2011 Review Committee – Terms of ReferencePurpose

The purpose of the Review committee will be to consider and provide advice on:1. the operational effectiveness of the Disability Services Act 2011 since

implementation;2. the inter-operability of the Disability Services Act 2011 with other legislation; and3. issues with the Disability Services Act 2011 which have arisen as a result of the

Tasmanian Bilateral Agreement for transition to the National Disability Insurance Scheme (NDIS).

Background

The Disability Services Act 2011 (the Act) was given effect by the Parliament of Tasmania and commenced in January 2012. A condition of the Act is to undertake a review, as soon as practicable, three years from commencement. Due to the National reform agenda and development of national policy areas, such as the National Quality and Safeguard Framework for the NDIS, it was recommended to the Minister for Human Services to delay the Review which would otherwise have been required in 2015. In 2015 Tasmania introduced the Disability Services Regulations to support the intent of the Act and to align with the National Disability Standards.At the Disability Reform Council meeting on 2 September 2016, Ministers agreed to progress the National Quality and Safeguard Framework (the Framework), a Regulatory Impact Statement and the outcomes of the review of the National Disability Insurance Scheme Act 2013 to the Council of Australian Governments (COAG). As the above activity has progressed to COAG and the Framework has been released, this means that the review of the Tasmanian Disability Services Act 2011 can now progress. Role and Function of the Review Committee

1. Approve and direct a consumer and communication engagement plan relating to the Review.

2. Inform and enable a methodology for measuring the perceptions of interested parties, e.g. survey and consultation. This must include methods which will assist in the active participation of individuals with disability in the Review.

3. Consider issues arising from the consultation process and provide a written report to the Minister for Human Services addressing: the operational effectiveness of the Act since implementation; interoperability issues between the Act and other legislation; and

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immediate legislative issues resulting from transition to the NDIS.4. It is anticipated that a further review of the Act will be required to reflect

legislative requirements in an environment where a full scheme NDIS is in operation. These requirements are out of scope for this Review, but will be noted for future review.

5. The Review Committee will be supported in its work by an appropriately experienced consultancy.

Membership

Chair: A consumer representative through the Ministers Disability Advisory Committee.

Membership: A provider representative through National Disability Services Tasmania.

A representative of Advocacy providers through one of the three funded advocacy organisations.

The Senior Practitioner. A representative of Disability and Community Services

(DCS). A representative from the Department of Justice. Ex-officio support provided by DCS. NB. the Terms of Reference will be updated to reflect

individual names once they have accepted a place on the Review Committee.

Communication during the life of the Review

The Chair, on behalf of the Review Committee, will provide progress updates to the Minister for Human Services as required.

Public communication in regard to the outcomes and outputs of the Review Committees work should be communicated via the Chair.

Timeframes

In recognition of the volunteer nature of the Disability Services Act 2011 Review Committee, it is anticipated that in order to address the requirement of the Terms of Reference, the Review Committee will need to meet on a face to face basis four times and that some additional communication will be undertaken out of session. It is expected that the review period would be over a period of six months commencing in July 2017. At the end of the Review, it would be expected that the Review Committee would hand down a report with a series of recommendations.

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