In an inclusive society, people with disabilities are able to take part in the same activities as anyone else. If we successfully removed barriers and integrated everyone into social and recreational activities we would need less disability specific community participation supports.

There have been calls to reduce the incentives for disability providers to offer group supports as people with disabilities should be able to choose their individual supports and the activities they are interested in.

The demand for group supports nevertheless remains high which highlights that group supports are meeting the needs and wants of many participating in group activities. Some recreational activities are simply more enjoyable in a group and together with peers as they offer social interaction, friendship, mental stimulation, sometimes a good laugh or simply a place of belonging.  However, since the COVID-19 pandemic many disability group supports ceased, moving people with disabilities into loneliness, boredom and social isolation and some carers to breaking point. Online group supports have evolved, trying to keep people engaged and active. Some disability providers have indicated that these supports may continue to run when restrictions will ease, however most participants and providers are excited to move back to face to face group supports. Whilst we expect to see the nature and volume of group supports evolve over time, the strong continuing demand should justify appropriate funding for these supports for participants and providers.

The NDIS funding model provides a one size fits all approach, making it difficult for good quality group supports to survive and thrive, and for new ones to evolve. In recent months we have conducted cost analysis for a range of providers of group programs. The results painted a bleak picture, revealing that many programs are not financially viable unless they are supported by volunteers. The NDIS prices for group supports are based on the Disability Support Worker Cost Model and we identified a range of assumptions in the calculations that were incorrect in our investigations:

  • Worker utilisation of 90%: While some workers may just turn up for the program and finish at the end of the session, high quality person-centred programs will always involve planning, preparation and client engagement outside the group session to help participants achieve their goals. The previous NDIS price for group activities accounted for 7 minutes of billable non-face to-face time for each participant in the group. From our experience most workers spend more time than this on activities outside of the billable face to face time. Also, programs rarely run from 9 am to 5 pm and unless the organisation works with a highly casualised workforce, non-chargeable time is inevitable.
  • Ratio of workers per supervisor of 15 to 1: According to the NDIS benchmarking study undertaken as part of the Annual Pricing Review 2020-21, the average ratio among respondents in the disability sector was a ratio of 11.8 workers per one supervisor. The ratio of 15 to 1 that is included in the modelling assumptions was only reported by 25% of the respondents.

We are not aware if the benchmarking study differentiated between Assistance with Daily Life supports and Social and Community Participation supports, which potentially require different supervisor to worker ratios. The nature of the support, the type of disability and support needs of the participant would impact on the demands and necessary skills of the workforce and supervision needs.  Less experienced and low skilled workers would require more supervision, yet the cost model assumes the same ratio across all SCHADS Classifications.

The benchmarking study was not representative of all registered NDIS providers in Australia. The survey was conducted among providers who charge the additional Temporary Transformation Payment (TTP). The assumption that providers that do not charge participants this temporary load are operating on a financially viable basis is unsubstantiated. From our observations, many providers do not charge the higher price because participants’ plans do not receive the correlating funding, so increasing the price of the service would reduce the volume of service available to participants within their plans.

The worker to supervisor ratio of 15:1 assumes a large, highly efficient and standardised operation – one which may be found at large providers in metropolitan areas but certainly not across the supports and many of the providers we support in our consulting work. The NDIS is built on the principles of person centred support which puts the person at the centre of the service and requires flexible services that respects the person’s wishes and preferences.  The NDIS scheme depends on long-term sustainability, for which providers need to be able to maintain or improve quality and develop a sustainable workforce. Effective supervision plays a key role in worker retention and satisfaction as well as client safety. The price model expects disability providers to work efficiently while quality and safety measures seem to be missing in the model. A survey among disability providers conducted in 2019 (by NDS) revealed that 52% of providers stated they would be forced to reduce quality at current prices and 76% stated they won’t be able to provide services at the current price. This is an alarming statement in the context that the Disability Royal Commission was established last year to respond to community concerns about widespread reports of neglect, abuse, exploitation of and violence against people with disability.

  • Providers employ disability support workers with different skill levels and experience: Most group supports are run by disability support workers who are paid under the Social, Community, Home Care and Disability Services Industry Award (SCHADS) 2020. The price cap however prohibits the engagement of ‘experts’ for speciality group programs or activities for example in music, art or technology. The running of quality theatre programs and the up-skilling of artists, musicians, IT developers or chefs are left to a workforce that are untrained in the field. The NDIA would argue that these programs can be offered under capacity building funding supports that are generally paid at a higher rate. Capacity building group supports however are difficult to implement unless the provider is engaging a therapist (which makes them even more expensive) and offering the program as an ‘improved daily living skills’ support. The funding for capacity building among adult participants varies considerably and is limited in terms of what they can spend it on. Participants who do not have funding approved in the correlating capacity building category (as they may not have expressed a correlating goal or the goals were not translated into the funding category) will miss out and be excluded from these group programs.
  • Centre Capital Costs at $2.15 per hour and participant: Providers who own bricks and mortars premises for group activities may appreciate the contribution to running costs of their facilities. However providers who need to hire rooms or halls continue to be out of pocket or highly reliant on community centres or church halls who may open their doors at low or no cost.
  • Resources costs: The cost for equipment, technology, tools, facility modifications, materials, consumables and all other items required to set up and run good programs must be covered by the provider unless invoiced separately to the participant. This may explain why group programs that are easy to set up and run (such as bowling or disco nights) still dominate what is on offer.

In July the NDIS introduced a new way of charging for group supports. The new system has sent shock waves through providers of group supports as individual codes for supports no longer apply. Hourly rates need to be divided by the number of participants attending the group. Thankfully the NDIA backed off the immediate implementation and has given providers 12 months to transition to the new system. Many customer management systems are directly linking codes to prices and are unable to do the pricing calculations (as yet). Under Consumer Law providers are bound by their service agreements with participants, and participants need to agree to service fees and charges – yet the NDIS changes pricing structures with little notice and leaves it to providers to explain and justify the price change to participants.

On the positive side the new system brings the opportunity for providers to more accurately charge for the time spent for non-face to face activities. The NDIS price guide states that ‘when working out the fee for non-face to face supports it is not appropriate to charge all participants an average additional fee. The additional fee must be worked out in each case and related specifically to the non-face to face supports delivered to the particular participant.’ We claim that following this guidance to the letter will increase the cost of administration to unacceptable levels and working out the non-face to face time for each participant for each hour of support is both impossible and unnecessary. Providers of group supports need to be able to quote in advance and participants need to be able to budget and know what costs to expect.

We recommend that providers keep it simple and do some observation and insight gathering over the coming months. How much time do we spend on non-face to face tasks (excluding administration) that apply to all group members and what are the tasks that are different for individuals? How much time do we spend for non-face to face tasks that only apply to some group members? Following your investigation, establish pricing policies that are sensible and substantiated as well as reasonable and fair. And citing the NDIS price guide again ‘this is not to say that the same additional fee might not end up being charged to a number of participants (but it must be worked out separately)’.

There is nothing worse than slapping participants with new and unknown charges, hence we advise providers to communicate early and well and to be transparent about what the non-face to face time charges involve.  As time goes by we will learn how providers will adapt to the change and if the NDIS manages to include sufficient non-face to face time funding into participants’ plans. We are concerned that the new policy will be the final straw for many providers to stop their group supports – yet they continue to be ‘reasonable and necessary’ for many people living with disabilities.