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Submissions

In consultation with the Victorian autism community, Amazes writes policy advice and submissions to state and federal governments to ensure the needs of autistic people and their families are voiced and heard to influence positive systemic change.

Previous submissions

Below, you can read about and download Amaze’s major policy submissions from the last three years.

For earlier submissions, please contact communications@amaze.org.au or call 03 9657 1600.

On 26 March 2019, the Victorian Government launched a Royal Commission into Victoria’s Mental Health System – the first of its kind in Australia. Amaze, Yellow Ladybugs and Different Journeys have collaborated to ensure autistic voices and needs are represented in this important investigation.

The aim of the Royal Commission is to provide the community with a clear set of actions that will change Victoria’s mental health system and enable Victorians to experience their best mental health.

Informed by academic research, more than 300 responses to our online community consultation survey, and a roundtable discussion with 11 mental health and autism professionals and researchers, the submission clearly demonstrates the urgent need for greater mental health supports for autistic people.

Download the Amaze, Yellow Ladybugs and Different Journeys Submision

The extensive consultation and research explored many barriers faced by autistic people in accessing and navigating Victoria’s mental health system, including:

  • Misdiagnosis
  • Difficulties in navigating the mental health system
  • Mental health practitioners’ inadequate knowledge of autism
  • Lack of appropriate services, and prohibitive costs associated with services
  • Lack of mental health supports for carers of autistic people with mental health conditions.

We found that knowledge about autism and mental health is increasing within the mental health sector, but it’s not complete or consistent across the sector. Some of the other barriers mental health professionals encounter in supporting autistic people are: a lack of autism training; no easily available information and guidance for supporting autistic people with mental health conditions; and an unsupportive mental health system.

Recommendation 1

A service model be developed that sets out how the mental health system can provide appropriate support to autistic people. The service model should:

  • be underpinned by the notion that autistic people must have access to continuous care throughout their lives, with key aspects of this care including a multi-disciplinary team of specialists and case management
  • ensure that information specifically related to autism and mental health – including where to access services and supports, and which practitioners specialise in this area – is made accessible to health practitioners, as well as the general public
  • ensure that professionals across all sectors – including mental health, health, disability, justice and education – are aware of, and have access to, appropriate training in autism and mental health
  • ensure that carers of autistic people are provided with appropriate mental health support.

Recommendation 2

A clinical practice model be developed to support mental health in autistic people generally, and for adolescents and adults more specifically.

Recommendation 3

The Victorian Government supports research into autism and mental health by:

  • establishing a mental health and autism research fund
  • funding a mental health and autism summit, to bring together mental health and autism researchers, practitioners and consumer representatives to identify research priorities, capacity building requirements and opportunities for service collaboration.

Recommendation 4 

The Victorian Government works towards eliminating restrictive practices across all service systems and sectors in Victoria, including the mental health system, and advocates for a nationally consistent framework for eliminating restrictive practices.

Next steps

The Commission will provide an interim report to the Victorian Government in November 2019, and a final report by October 2020.

The Victorian Government has already committed to implementing every recommendation from the Royal Commission.

In May 2016, the Victorian State Parliament’s Family and Community Development Committee launched an Inquiry into services for people with autism spectrum disorder.  Its terms of reference included, but were not limited to the prevalence of autism in Victoria, the availability and adequacy of services for autistic people and the social and economic consequences of failing to provide adequate services. 

Amaze’s submission was informed by robust evidence and the 500 responses it received to its survey of autistic people and their families, regarding the issues they were facing and how they wanted them to be addressed. The submission provided detailed evidence and recommendations in relation to early intervention, education, employment, NDIS transition, restrictive interventions and the economic cost of autism.

Download Driving Change, Amaze’s Submission Inquiry into services for people with Autism Spectrum Disorder (PDF)

Outcome

In June 2017, the Family and Community Development Committee released its Inquiry into services for people with autism spectrum disorder – Final Report.  The report was significantly informed by Amaze’s submission and contained 101 recommendations to create a more inclusive and supportive Victoria for autistic people, including a recommendation that the Victorian government develop a new State Autism Plan.

In December 2017, the Victorian government released its Response to the Parliamentary Inquiry into services for people with autism spectrum disorder.  In its response, the government committed to developing a new State Autism Plan and a public education campaign. It also included some commitments to increase support for autistic children in the early years and school, develop a responsive workforce, create inclusive sport and recreation opportunities, provide more support for rural and regional communities and support autistic women and girls.

To date, the State Autism Plan has not been released.

Amaze is continuing to advocate to the Victorian government for the release of the State Autism Plan and the adoption of all 101 recommendations from the inquiry.

In November 2016, the Senate Community Affairs References Committee (SCARC) was asked by the Senate to inquire and report on the delivery of outcomes under the National Disability Strategy 2010 – 2020, to build inclusive and accessible communities.  When considering the delivery of outcomes, Amaze’s submission encouraged the SCARC to consider whether progress had been made toward building inclusive and accessible communities for autistic people. 

Amaze’s submission highlighted the range of environment barriers autistic people can face when seeking to access their community, as well as robust evidence that a building’s design or modification can improve access and participation for autistic people. 

It urged the SCARC to review the extent to which existing building codes and design guidelines support access for autistic people and consider actions that could be taken by governments, planners and community organizations to improve accessibility.

Download Amaze’s submission on the delivery of outcomes under the NDIS (PDF) 

Outcome

In November 2017, the SCARC released its report titled Delivery of outcomes under the National Disability Strategy 2010-2020 to build inclusive and accessible communities. The report acknowledged Amaze’s submission and the importance of inclusive and accessible communities for autistic people.

While the report did not make any recommendations specific to improving outcomes for autistic people, it did make made a range of recommendations to improve the oversight, implementation, co-ordination and data collection/monitoring of the National Disability Strategy, including the establishment of an Office of Disability Strategy.

In 2017, the Productivity Commission reviewed the costs of the National Disability Insurance Scheme (NDIS). It released its Issues Paper in February 2017, and responses to its Issues Paper helped shape its Position Paper (June 2017) and subsequent Final Report (October 2017). 

The Productivity Commission’s review examined the sustainability of scheme costs, cost pressures faced by the National Disability Insurance Agency (NDIA) and other stakeholders, obligations across jurisdictions and the intersection between mainstream and disability services.

Amaze’s submissions to the Issues Paper and Position Paper highlighted the cost benefits of ensuring the NDIS meets the needs of autistic people and their families, including through an evidence based approach to access and planning, the use of appropriate assessment tools, ensuring access to clear and accessible information for autistic people, investment in peer networks and pre-planning support, autism training and guidance for planners, and providing clear guidance regarding the intersection between mainstream and disability supports. It also recommended that KPIs on Early Childhood Early Intervention (ECEI) partners, which ensure less than 50% of ECEI participants are referred for access to NDIS, be removed.

Amaze’s submission was informed by a community survey it conducted on NDIS experiences for the purpose of the inquiry.

Download Amaze’s submission to the Productivity Commission’s on NDIS costs

Outcome

The Productivity Commission released its Final Report in October 2017.  It highlighted a number of findings from Amaze’s community survey and agreed that there is an urgent need for better autism understanding among planners and LAC’s, as well as improved transparency, communication and pre-planning support. It also agreed that the KPI on ECEI partners should be removed.

More broadly it found that while NDIS costs were generally on track, some cost pressures and likely workforce shortages are emerging. It found that the quality of plans and the planning process have been comprised at the expense of quantity/transition targets. It also highlighted the need for clearer guidance on the intersection between mainstream and disability supports, and jurisdictional/governments obligations.

In June 2017, the Commonwealth Government released its NDIS Code of Conduct Discussion Paper  to seek community input into the development of a new NDIS Code of Conduct (Code) for NDIS providers (including people employed or otherwise engaged by NDIS providers).

Amaze’s submission supported the development of the new Code to ensure the safe and ethical delivery of high quality services and supports to people with disability. It also highlighted the importance of the Code and complaints process being accessible to autistic people. 

Download Amaze’s submission on the NDIS Code of Conduct Discussion Paper

Outcome

The new National Disability Insurance Scheme (Code of Conduct) Rules 2018  were published 17 May 2018. The new NDIS Quality and Safeguards Commission also commenced rolling out its operation in July 2018, with a key function of overseeing the implementation of the Code and associated Practice Standards. For more information, see the NDIS Quality and Safeguards Commission website at https://www.ndiscommission.gov.au/ .

Amaze will also continue to monitor implementation of the Code and its accessibility for autistic people.

In November 2017, the Joint Standing Committee on the NDIS launched inquiry into the provision of services under the NDIS Early Childhood Early Intervention Approach.

Amaze’s submission supported the development of an ECEI pathway for accessing the NDIS. However, it raised concerns regarding the data used by the NDIA in 2016 to project the likely numbers of autistic children entering the scheme through the NDIS ECEI pathway. It highlighted the need for ECEI Access Partners build autism specific expertise and use of a functional assessment tool better suited to measuring the support needs of young autistic people.

It also demonstrated the need for more consistent and accessible information for families/carers of children entering the ECEI pathway, and a more consistent and evidence based approach to planning and funding of supports. The issue of workforce shortages, particularly in rural areas was also addressed.  

To inform its submission, Amaze conducted a survey of parents/cares of ECEI participants about their NDIS ECEI experiences.

Download Amaze’s submission to the Joint Standing Committee on the NDIS’s inquiry into the provision of services

Outcome

Amaze’s submission and parent/carer surveyed informed a number of findings and recommendations by the Joint Standing Committee on the NDIS, in its final report titled Provision of services under the NDIS ECEI Approach (December 2017). 

In particular, the report recommended that a new functional assessment tool be developed for autistic children. It also highlighted Amaze’s concerns regarding the autism understanding and inconsistent approaches to planning, as well as workforce shortages, influencing conclusions and recommendations in relation to these matters.

In October 2017, Amaze provided a submission to the Cooperative Research Centre for Living with Autism’s (‘Autism CRC’) draft national guideline for community consultation, The diagnostic process for children, adolescents and adults referred for assessment of autism spectrum disorder in Australia.

Amaze’s submission welcomed the guideline’s development, highlighting the poor experiences to date of many autistic people and their families/carers when seeking to access an autism diagnosis. It made a number of recommendations to support the development of an evidence based guideline capable of supporting reliable and accessible diagnostic, and functional and support needs assessments. It also highlighted important considerations relating to autistic women and autistic people who experience co-occurring conditions, including mental health conditions.

Download Amaze’s submission on the Autism CRC’s Draft national diagnostic guideline

Outcome

In October 2018, Autism CRC (with funding from the National Disability Insurance Agency) announced its final National Guideline for the Assessment and Diagnosis of Autism Spectrum Disorder in Australia. Amaze welcomed the guideline which will create greater consistency in diagnostic practices across Australia and ensure access to timely and reliable diagnostic, and functional and support needs assessments.

The new guideline can be accessed via Autism CRC’s website.

In December 2017, the Victorian Parliamentary Economic, Education, Jobs and Skills Committee announced its Inquiry into Career Advice Activities in Victorian Schools. 

Amaze’s submission welcomed the inquiry and highlighted the poor career advice activities and employment outcomes for autistic people in Australia. It demonstrated that career advice activities in Victorian schools lack consistency and co-ordination, and often fail to meet the needs of autistic students. It also demonstrated that inadequate career advice activities are contributing to poor post-school outcomes and experiences.

Amaze recommended that the Victorian Government develop, implement and fund a Post-School Transitions Policy for autistic students (ideally as a component of an updated State Autism Plan). Amaze’s submission was informed by a survey of young autistic people and their families/carers it conducted for the purpose of this inquiry.

Download Amaze’s submission to the Inquiry into Career Advice Activities in Victorian Schools (PDF)

Outcome

In August 2018, the Committee released its report titled Inquiry into career advice activities in Victorian schools.  The report found that career development is not currently meeting the needs of Victorian students. It made a number of recommendations to build a whole of school approach to career advice activities and build the capacity of schools and career development services to better meet the needs of all students (including students with disabilities).

The report highlighted a number of Amaze’s concerns, which informed its associated findings.

The Victorian government tabled its response to the inquiry on 21 February 2019. It supported in full or in principle all recommendations made by the Committee. It announced a suite of initiatives to improve quality and access to career development services in Victorian schools, and outlined commitments to increase students’ workplace exposure and raise the profile of vocational education and training.

It also committed to addressing the needs of students experiencing disadvantage, noting that in 2018 it developed additional resources to support the career education and work readiness of students with a disability (including teaching and learning resources, professional learning for career practitioners and teachers, and seminars for parents and carers).

In August 2018, the Commonwealth Parliament’s Joint Standing Committee on the NDIS announced its inquiry into the provision of Assistive Technology (AT) under the NDIS.  For NDIS purposes, AT refers to any device, equipment or system that allows a person to perform tasks they may otherwise be unable to do, or increases the ease or safety with which tasks can be performed.

To inform its submission to this inquiry, Amaze conducted a survey to hear the experiences of autistic people, and their families and carers, applying for AT under the NDIS. The survey responses demonstrated the lack of information available to autistic people and their families/carers regarding the types of AT that may be funded by the NDIS, and significant inconsistencies in funding decisions.

Amaze’s submission to the inquiry outlined its survey findings, highlighted common AT needs of autistic people and emphasised the need for a more transparent, consistent and evidence based approach to AT funding for autistic people under the NDIS (including through the development of AT guidelines for autistic participants).

Download Amaze’s submission to the Inquiry into the provision of Assistive Technology (PDF)

Outcome

The Joint Standing Committee on the NDIS released its inquiry report titled Provision of AT under the NDIS on 12 December 2018. The report included 8 recommendations to improve the experiences of NDIS participants (and their families/carers) applying for AT under the NDIS, increase access to AT and reduce delays.

In October 2017, the Australian Building Codes Board (ABCB) released its Accessible Housing Options Paper, and sought community feedback to inform the development of a national regulation impact assesment on the costs and benefits of applying a minimum accessibility standard to all new residential dwellings in Australia.  

Amaze’s submission welcomed the development of a minimum accessibility standard but emphasized the importance of assessing the accessibility needs of all people with disability, including autistic people. It highlighted some options for exploring how the accessibility needs of autistic people may be met and the costs and benefits associated with meeting these needs.

Download Amaze’s submission to the Australian Building Codes Board Accessible Housing Options Paper (PDF)

Outcome

An Outcomes Report from this inquiry, which will inform the development of the regulatory impact statement, will be released in early 2019. For more information, please see the consultation page at https://www.abcb.gov.au/Resources/Publications/Consultation/Accessible-Housing-Options-Paper

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