On 25 March and 30 April the NDIA updated the NDIS price guide (Version 2.3) to help NDIS providers during the COVID 19 crisis. The changes include price increases, changes to cancellation rules and charges, and increased access to Support Coordination for all participants.
The changes will be in place for six months. The NDIA will assess in three months if adjustments are appropriate.
The price limits of selected supports have been increased by 10%. The price of a total of 402 line items have been adjusted and are identified in the NDIS Support Catalogue as ‘includes COVID loading’ in the last column of the table.
This includes supports under:
- Assistance with Daily Life
- Assistance with Social and Community Participation
- Improved Health and Wellbeing (excluding personal training)
- Improved Daily Living Skills
As participants continue to cancel supports to self-quarantine, participants are now required to give ten clear business days’ notice of cancellation of any support. If the provider cannot find any alternative billable work for the relevant worker and is required to pay the worker for their time, the provider can charge 100% (instead of 90%) of the service fee (starting from the 29 March). The provider cannot charge for cancellations with more than 10 days’ notice.
To give participants extra support they can spend core funding to engage a Support Coordinator. Anyone can seek help from a Support Coordinator even if they do not have Support Coordination funded in the plan (as long as there is core funding left). The Support Coordinator can charge under the three new line items (Support Connections, Support Coordination or Specialist Support Coordination), and does not have to be registered for Core supports.
Support for NDIS providers
The changes and price increases are welcome in uncertain times. The income of disability service providers has been dwindling in recent weeks, with group supports cancelled and many participants self-isolating. Cash flow has become more critical than ever and the fight for survival has started for many. The NDIS advises that providers should claim the new prices under the current line item. Line items in the NDIS portal have been updated to the new maximum price.
For ongoing NDIS services, providers and participants already have their Service Agreements in place, with agreed service fees and terms and charges for the cancellation of services. Under Australian consumer law, these terms should apply to the service unless the service is terminated by either party. Some providers have nifty clauses in their Service Agreement that give the provider the liberty to raise prices and adjust terms in line with NDIS Price Guide, yet no provider should just change terms and raise prices unless agreed by the participant. The NDIS advises that providers should inform the participant before implementing any price increase.
If following best practice, service agreements should be amended and signed by both parties, an administrative burden that providers surely don’t want to take on in the current crisis. Making the increase even more laboursome is the fact that service bookings under the current line item need to be updated by the provider.
Also, participants’ plan funds are not adjusted to reflect the price guide increases and many providers are (again) reluctant to charge the higher price, knowing that it ultimately reduces the volume of service that participants can fund from their plans. While participants on average only spend approximately 70% of plan funding, some participants will run out of funds in certain support categories, especially if the budget was tight to start with.
The NDIS Minister Stuart Robert has announced that the NDIA will adopt a flexible approach to amending plans and, where necessary, shift capacity building funding to core supports. Flexibility is welcome, yet participants (who often don’t understand their plan budget and struggle to keep track) need to be able to advocate for the change to their individual plans, and in many cases overall costs are going up. Participants also need to understand that they have the opportunity to engage support coordination support through their core budget (if the budget has not been allocated to other supports yet) or to request an unscheduled plan review.
As with the Temporary Transformation Payment (TTP) payment, the increase in the fees that providers can charge, with no matching increase in plan values, tests the provider participant relationship. Some participants believe that providers are greedy and that the new cancellation rules are unfair.
We are concerned that the price rise will not be is enough to help providers get through and we argue that the 10% top up should not come from individual plans, but instead should be paid directly by the NDIS to the provider. This would make the support less bureaucratic and would reduce the thousands of service booking adjustments, calls and letters to participants and the NDIS help line, plan adjustments, failed log-ins into the portal and the sweat and tears of providers and participants.
The NDIS has offered some non-bureaucratic help for registered providers though a once-off advance payment, yet many providers we spoke to are declining the payment due to the unclear credit terms and their uncertain future.
The NDIS Commission has reminded providers to report certain changes and events, especially those which substantially affect their ability to provide supports and services. We sincerely hope that practical support to providers and participants will be offered if providers falter and are unable to continue supports.
The NDIS has announced proactive outreach to high-risk participants and data sharing with states and territories to ensure continuity of supports. But, if any NDIS participant choses to self-isolate and terminates all service agreements it is not clear who will check in on the person?
Support for SIL providers
Prices of Supported Independent Living (SIL) supports have not been adjusted. Life in group homes has just become extremely stressful. Group homes are in lock down and residents who often spend the day with recreational or employment activities now require 24/7 support. Residents who have the option, and have decided, to leave the group home to isolate with their families are leaving funding gaps for providers. Social distancing between residents and support workers is near impossible in group homes creating a risk for both the participants and the workers. In Western Sydney a support worker with mild COVID 19 symptoms worked for six shifts in an aged care facility and also for a disability service before self-isolating.
The NDIA introduced new line items for SIL residents in case a resident is diagnosed with COVID-19 and needs higher intensity supports and the facility requires deep cleaning. Providers need to be prepared and ready to be able to isolate and replace entire support teams at short notice. Upskilling staff, sourcing PPE, recruitment and safety checks, risk assessments, keeping up on information, establishing business continuity measures, monitoring cash flow and securing food supply are just some of the additional tasks providers are dealing with at the moment. The Disability Royal Commission is deeply concerned about the impact of the pandemic and has issued a Statement of concern which includes the reduced oversight in closed residential settings. Giving group homes an extra hand would be a sensible measure to ensure residents will be looked after well.