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NDIS Specialist Disability Accommodation issues

  • 1.  NDIS Specialist Disability Accommodation issues

    Posted 07-01-2023 08:58 PM
    Dear all,
    quick question regarding interest in NDIS Specialist Disability Accommodation. Everyone happy with the 2021 SDA Design Standard? I'm not. I am even less impressed to find that the rehabilitation engineers have been left off the LHA list of "specified professions" able to act as LHA & SDA assessors.

    And downright angry that as a result of the 2020 SDA legislative changes I'm at risk of having my SDA home accreditation removed. Along with funding.

    Appreciate hearing from anyone working with SDA - especially having to deal with some of the worst aspects of the SDA Design standard or design process.

    Cheers,
    Allan H


    ------------------------------
    Allan Hunter
    ------------------------------


  • 2.  RE: NDIS Specialist Disability Accommodation issues

    Posted 10-01-2023 09:35 AM
    Hi Allan, 

    Great to hear from you. I'm keen to know more of your background. The rehabilitation engineering community is a diverse group covering a really broad range of specialisations usually at the interface between Biomedical, Mechanical, Electrical & Mechatronic engineering. While the community certainly has an interest in Specialist Disability Accommodation and would be happy to advocate for sensible reforms of standards, in general, we are not involved in the design and modification of accommodation directly. Its possible that I have yet to engage with a sector of engineering in Australia that does this work and uses the title rehabilitation engineer, (if so I would very much like to establish connections with this group), but i've been working pretty hard over the past 5 years to connect self-identifying 'rehabilitation engineers' and haven't come across any. I too find it very odd that there are no engineers on the SDA's list of prerequisite professions. I think it would be appropriate to have some sort of civil/structural engineer listed (more so than a rehabilitation engineer), or even just to leave it as a 'professional engineer'. Having looked at the presrequisites that are listed it would like require pairing with a requirement for CPEng (to demonstrate professional oversight/currency) and for holding either of the Cert IVs listed (CPP40811 or CPP50711). The rehabilitation engineering community is already looking to engage with the NDIS Commission regarding recognition of the role of engineers in the assessment and development of custom-made assistive technology, so perhaps it would be helpful to provide a united front? 

    Please feel free to contact me to follow up. 

    Kind regards,
    Iain Brown PhD MIEAust CPEng(Bio) NER
    [email protected]





    ------------------------------
    Iain Brown
    ------------------------------



  • 3.  RE: NDIS Specialist Disability Accommodation issues

    Posted 10-01-2023 11:21 AM

    Ian,

    Thanks for the response.  Do you have some time to read some documents?

    Cheers,

    Allan H






  • 4.  RE: NDIS Specialist Disability Accommodation issues

    Posted 10-01-2023 11:51 AM
    Hi Allan, 

    Yes, very happy to read some documents then to have a follow up conversation. Send me through what you have,

    Kind regards,
    Iain

    ------------------------------
    Iain Brown
    ------------------------------



  • 5.  RE: NDIS Specialist Disability Accommodation issues

    Posted 10-01-2023 01:10 PM
    Iain,
    good to hear that you're looking at getting involved with the NDIS commission. SDA desperately needs some leadership from an organisation such as Engineering Australia.

    Starting with a clear understanding and definition of the concepts of "accessibility" and "severely disabled". And how to have a conversation about the differences in relationship to Specialist Disability Accommodation design and certification

    The term "accessibility" has a popular interpretation as relating to the ability of a wheelchair user to get out and about. These days there is a wider focus informed by universal design principles, but generally, it's all about wheelchairs.

    From an NDIS point of view, "severely disabled" has a legislative definition, and relates to people "with extreme functional impairment or very high needs". Such is a C3/C4 quadriplegic - me.

    Why am I mentioning this? Because my post was all about Specialist Disability Accommodation. In particular about my home which involves both concepts.

    And in your reply you've quoted "CPP40811 or CPP50711" - which only relate to "accessibility". (Is it only me that has a problem with this?)

    Have you noticed that there is an implicit assumption in documents such as the LHA guidelines that the wheelchair user is fully functional from the waist upwards? Arms can reach upwards and downwards while sitting in a wheelchair. Hands can operate things like light switches and open and close full height pull-out pantries. Take stuff out of the oven and twist sideways to put it on the bench. And this is reflected in the current SDA Design standard.

    The SDA Design Standard doesn't even begin to address issues associated with the accommodation requirements of "severely disabled". So what's missing?

    The obvious omission is the need to tailoring accommodation to the needs of a particular disability. I happen to have a spinal cord injury. My requirements are going to be different to someone with say, MS. Or spina bifida. Or someone with no arms. Someone injured from a motor vehicle accident and has intellectual difficulties as well is clearly going to be an awkward problem to deal with.

    And that's before you start designing SDA for someone with intellectual disabilities or autistic. The little research I have done in that area was a humbling experience. It illustrated how little I know about designing SDA. I had to admit to myself that, as an experienced and qualified systems engineer, I had no idea where to start.

    Clearly, designing accommodation for the severely disabled is a bit more complex than just a dumbed down simplified choice between four different types in the existing approach. Person centred tailoring needs to be the centrepiece of SDA. Not a list of building characteristics someone with a certificate IV can tick off a checklist.

    The other omission - and this is the main area I see Engineers Australia getting involved - is the incorporation of computer based AT in to SDA. How can someone in an electric wheelchair with no hand function live independently and safely by themselves? What about routine tasks by opening a window, turning on a light, or opening and closing the the blinds. How do you incorporate that in the fabric of a home? More importantly how do you verify that the resulting SDA suitable for someone with a severe disability?

    And it's a lot more complex than installing hardware purchased from the Smart Home division of Harvey Norman. To use my home for an example I have both an ethernet network and KNX home automation system performing different functions. I wouldn't expect most houses to be documented to the point of a Masters thesis (Mine looked at the effect of designing to the LHA guide on the six Star energy efficiency). Or the subject of a presentation by an occupational therapist at a assistive technology conference (ARATA 2018 conference in Melbourne). But the complexity of integrating the various systems together needs to be acknowledged and provision made in the SDA Design standard.

    As a systems engineer I have access to the skills and people required to do all of that. Most don't.

    There is no provision for either individual tailoring, or incorporation of computer based AT in the current SDA Design Standard. And that's on top of a long list of detailed technical deficiencies. Which makes the document not fit for purpose. Rather awkward when you consider that last financial year a bit under $200 million of taxpayer funds was spent building SDA accommodation.

    How we got to the stage is a fascinating lesson in business connections, politics, and influence. .

    I've just written this off the top of my head. Before I start imposing large documents on others, I thought it would be more appropriate to lay out exactly where I'm coming from. Is this appropriate for an Engineers Australia forum? Or have I gone completely off the track? Appreciate some feedback here please.

    Cheers,
    Allan H

    Cheers,
    Allan H

    ------------------------------
    Allan Hunter
    ------------------------------



  • 6.  RE: NDIS Specialist Disability Accommodation issues

    Posted 10-01-2023 03:02 PM

    Iain,

    a good starting point is the written submission (032 Allan Hunter.pdf) to the South Australian Parliament Social Development Committee enquiry into NDIS essay participant in or at risk of living inappropriate accommodation (https://www.parliament.sa.gov.au/committees/sdc). The verbal submission is not up yet, and I don't think they will include the notes are provided when they did a tour of my house on the fifth of December.

     

    Also included is the NDIS code of conduct complaint I lodged just before Christmas. Fairly self-explanatory.

     

    The SDA comments dated May 2021 written after a few years of informal discussions achieved nothing. Ministerial  directive to provide review comments was ignored by the ndia. Twice.

     

    And you get a mention in the draft ACCC complaint. Although this needs a drastic edit BEFORE being sent.

     

    The most urgent however is clause 22.1 emergency power supplies. This really does need an engineer who knows what they're talking about to provide advice.

     

    Any question, please don't hesitate to give me a ring on 0414 734 648.

    Cheers,

    Allan H

     

     

     

    Hi Allan,  Yes, very happy to read some documents then to have a follow up conversation. Send me through what you have, Kind regards, Iain ----...

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    Re: NDIS Specialist Disability Accommodation issues

    Jan 10, 2023 11:51 AM

    Iain Brown

    Hi Allan, 

    Yes, very happy to read some documents then to have a follow up conversation. Send me through what you have,

    Kind regards,
    Iain

    ------------------------------
    Iain Brown
    ------------------------------

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    Ian,

    Thanks for the response.  Do you have some time to read some documents?

    Cheers,

    Allan H




    Original Message:
    Sent: 1/9/2023 5:35:00 PM
    From: Iain Brown
    Subject: RE: NDIS Specialist Disability Accommodation issues

    Hi Allan, 

    Great to hear from you. I'm keen to know more of your background. The rehabilitation engineering community is a diverse group covering a really broad range of specialisations usually at the interface between Biomedical, Mechanical, Electrical & Mechatronic engineering. While the community certainly has an interest in Specialist Disability Accommodation and would be happy to advocate for sensible reforms of standards, in general, we are not involved in the design and modification of accommodation directly. Its possible that I have yet to engage with a sector of engineering in Australia that does this work and uses the title rehabilitation engineer, (if so I would very much like to establish connections with this group), but i've been working pretty hard over the past 5 years to connect self-identifying 'rehabilitation engineers' and haven't come across any. I too find it very odd that there are no engineers on the SDA's list of prerequisite professions. I think it would be appropriate to have some sort of civil/structural engineer listed (more so than a rehabilitation engineer), or even just to leave it as a 'professional engineer'. Having looked at the presrequisites that are listed it would like require pairing with a requirement for CPEng (to demonstrate professional oversight/currency) and for holding either of the Cert IVs listed (CPP40811 or CPP50711). The rehabilitation engineering community is already looking to engage with the NDIS Commission regarding recognition of the role of engineers in the assessment and development of custom-made assistive technology, so perhaps it would be helpful to provide a united front? 

    Please feel free to contact me to follow up. 

    Kind regards,
    Iain Brown PhD MIEAust CPEng(Bio) NER
    [email protected]





    ------------------------------
    Iain Brown



     

     

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    Original Message:
    Sent: 1/9/2023 5:35:00 PM
    From: Iain Brown
    Subject: RE: NDIS Specialist Disability Accommodation issues

    Hi Allan, 

    Great to hear from you. I'm keen to know more of your background. The rehabilitation engineering community is a diverse group covering a really broad range of specialisations usually at the interface between Biomedical, Mechanical, Electrical & Mechatronic engineering. While the community certainly has an interest in Specialist Disability Accommodation and would be happy to advocate for sensible reforms of standards, in general, we are not involved in the design and modification of accommodation directly. Its possible that I have yet to engage with a sector of engineering in Australia that does this work and uses the title rehabilitation engineer, (if so I would very much like to establish connections with this group), but i've been working pretty hard over the past 5 years to connect self-identifying 'rehabilitation engineers' and haven't come across any. I too find it very odd that there are no engineers on the SDA's list of prerequisite professions. I think it would be appropriate to have some sort of civil/structural engineer listed (more so than a rehabilitation engineer), or even just to leave it as a 'professional engineer'. Having looked at the presrequisites that are listed it would like require pairing with a requirement for CPEng (to demonstrate professional oversight/currency) and for holding either of the Cert IVs listed (CPP40811 or CPP50711). The rehabilitation engineering community is already looking to engage with the NDIS Commission regarding recognition of the role of engineers in the assessment and development of custom-made assistive technology, so perhaps it would be helpful to provide a united front? 

    Please feel free to contact me to follow up. 

    Kind regards,
    Iain Brown PhD MIEAust CPEng(Bio) NER
    [email protected]





    ------------------------------
    Iain Brown
    ------------------------------


  • 7.  RE: NDIS Specialist Disability Accommodation issues

    Posted 10-01-2023 11:18 PM
    Hi Allan, 

    Thanks for the comprehensive post and the attached documents. I have skimmed them quickly to get a broader sense of where you are coming from, but will go back and read them in closer detail, providing a better response, likely by mid next week. I agree that there are some serious issues with the current approach to SDA accrediting that it would be good to advocate solutions to. I also think that Clause 22.1 is a good case to start with. If EA is able to advocate successfully and cordially with the SDA and LHA on Clause 22.1 then I believe further cases could be explored and reviewed with greater ease. 

    Kind regards,
    Iain

    ------------------------------
    Iain Brown
    ------------------------------



  • 8.  RE: NDIS Specialist Disability Accommodation issues

    Posted 11-01-2023 11:26 AM

    Iain,

     

    thanks very much for reading those documents. Please let me know if you think I'm being unreasonable or just having an inappropriate rant. After a few years doing this, start to wonder whether I should just give up.

     

    I have barely scratched the surface. Conduct that would be totally unacceptable on any engineering project I have worked on is explicitly endorsed by the NDIA. In my verbal response to the SA Parliamentary enquiry I ended up quoting Prof John Hewson. In an article in the Saturday paper, he looked at some of the problems with the ideological adoption of neoliberalism in Australia and made some comments about the role of public sector as regulator. Why am I mentioning this?

     

    My first job as a professional engineer was working for the (then) Electricity Trust of South Australia. I am old enough to have watched the transition from essentially a state run in regulated power industry, to a national electricity market driven by market forces. Allegedly. And in particular followed the way greed and profiteering resulted in the collapse of the market forcing the regulator to step in last year.

     

    There are just so many parallels with the way taxpayer funds are used to make investment in SDA attractive to the private sector.

     

    When it comes to SDA, scary bit is way the a handful individuals with some serious business and political connections have driven the process over the last decade or so. The building industry captured NDIA policy to the point that there are no independent arm's-length regulator functions actually happening. It's entirely managed, run, and regulated by interests associated with the LHA board. It's a learning curve I didn't expect to have to address. Not surprised to find out that our now ex-Prime Minister Scott Morrison spent six years working as a researcher for the industry lobby group Property Council of Australia.

     

    Last night an email from a senior SDA manager confirmed what I suspected. Current NDIA position is that compliance with LHA platinum level is sufficient in itself to certify residence as suitable for someone with a severe disability. I'm in the process of drafting a response to confirm that a residential review "requested" by the NDIA by a LHA certified assessor can, on the grounds of a non-compliance with LHA platinum level, is sufficient to withdraw SDA funding.

     

    And I just got off the phone from a staffer in the office of the Minister for skills and training. With the new government, everything's in the process of changing. He is going to forward some documentation detailing how Engineers Australia to get involved with development process for LHA and SDA course development, training, and certification requirements.

     

    I'll let you know how it goes.

     

    Cheers,

    Allan H

     

     






  • 9.  RE: NDIS Specialist Disability Accommodation issues

    Posted 14-01-2023 03:53 PM

    Iain,

    Can you just hit the reply button please. Just confirming that this is in fact a private email and not via the forum.

    Cheers,

    Allan H






  • 10.  RE: NDIS Specialist Disability Accommodation issues

    Posted 14-01-2023 03:57 PM
    that answers that question...

    ------------------------------
    Allan Hunter
    ------------------------------



  • 11.  RE: NDIS Specialist Disability Accommodation issues

    Posted 12-01-2023 09:35 AM
    Hello Allan,

    Interesting topic which would involve 'architecture' and 'building services' both 'electrical' as well 'mechanical' engineering.

    Qualified in building services (in Europe as well) - Mechanical engineering - would have thought 'respectful building services' to have progressed beyond.

    Sad to read that not to be the case.
    (Important needs and possible opportunities though ...)
    .
    Thanks for highlighting SDA issues, and regards,

    ------------------------------
    Sebastian Tops
    ------------------------------