This article was published on 25 May 2021 before NDIA announced their new price changes on 2 June 2021. We are preparing an updated version of this article and this will be posted soon.
With less than six weeks to go until the new NDIS Price Guide 2021-22 will come into effect we are eagerly awaiting the news of what will and what will not change for NDIS participants and providers in the next financial year.
Last week we attended the NDIS National Provider Forum run by the NDIA Provider Engagement Team, only to find out that the details of the new NDIS Price Guide are a well-kept secret (and possibly still under review) and will not be published until early June. Not even the slightest detail about upcoming changes were communicated, making us wonder if the NDIA will allow providers sufficient time for implementation. Or does the silence indicate that there won’t be major changes? The past has taught us otherwise and given that ‘long-term sustainability’ has become the latest NDIS buzzword, we are somewhat nervous of what lies ahead. What do we know?
NDIS plan duration
The preferred duration of NDIS plans is now 24 months. Finally, someone has calculated that the time required for planning meetings and development of 450,000 new plans each year is unachievable and not sustainable. Most participants resent the yearly review and the associated uncertainty and welcome longer plan periods. If participants’ plans are currently due to end, they may be eligible for an automatic plan extension. People who have already started a plan review are not eligible for an extension. Also, children under 7 years old do not receive an automated extension. New plans will not be indexed; however, the funding will be adjusted when the new Price Guide comes into place. Participants need to inform providers about plan extensions and new plan dates. Unfortunately, this rarely happens. Service bookings are automatically extended yet, providers need to manually adjust the amount in the service booking if the participant wishes to continue services.
NDIS group supports
Providers have until 1 July 2021 to adapt to the new claiming structure for group supports. Many larger providers of group support have made the switch, yet we have observed that some providers – particularly small providers – are oblivious or in denial about the change and are completely unprepared. Our request to the NDIA of whether the transitional arrangements will definitely cease and if the line items for group ratios will be removed from the Price Guide for good remains unanswered.
On the webinar, a question on how providers can best communicate the change to participants and how the NDIA supports the communication was ignored. Explaining the change to participants can be tricky. A person who regularly attends a program for six hours and used to be charged for six hours of support may from now on be charged for 90 minutes face to face time (if four participants share the support), six hours of centre capital costs, as well as non-face to face time that potentially occurs on days when they are not attending the program. Quoting for non-face to face time in advance and keeping track of non-face to face time proves difficult for providers. Many small providers do not understand how to apply the new claiming structure and its impact on the sustainability of their services.
The new claiming structure simplifies the NDIS Price Guide yet complicates the administration processes of providers and makes it challenging for participants to budget for the entire year. Providers who support participants with complex needs have the opportunity to charge for the additional time to prepare and communicate regarding support needs, yet we wonder if the need for additional non-face to face time will be considered by NDIS planners when developing the plan budget.
We strongly recommend that providers of NDIS group supports monitor, record, and invoice for non-face to face time as this cost was factored into the transitional (old) group support charges. Failure to charge for non-face to face time will considerably reduce revenue and put the financial viability of group supports at risk. Providers need to confirm the accuracy of payment requests at all times. Non-face to face time may require case noting to substantiate the support. This will increase the time and cost of non-face to face time. We have heard that some support coordinators tell participants that they do not have to accept the cost of non-face to face time, and we strongly advise providers to discuss the need to charge for non-face to face time with participants and include this in their service agreements.
The NDIA has not published any guides for providers of group supports however we expect that the new Price Guide will include some examples. Providers requiring more information may find the NDIS supports in employment booklet helpful. NDIS employment supports apply the same group-based support pricing structure, however employment providers have until 31 December 2021 to transition to the new model. The NDIA is currently conducting a survey to understand how Australian Disability Enterprises (ADE) providers transition to the new pricing framework.
Programs of support
Providers of group supports who are concerned they will miss out on payments if participants call in sick should consider establishing programs of support as an alternative to the traditional, sessional group model. These were introduced into the NDIS Price Guide 2020-21 and allow providers to charge an agreed fee for a program of up to 12 weeks, using the typical pattern of support for the period. Participants can still exit from a program of support by giving two weeks’ notice, leaving the provider to pick up the cost if they cannot fill the spot.
The NDIA also emphasises that programs of support must be adjusted for weeks when the participant is absent on planned leave (including public holidays and annual leave). This rule is currently not stated in the NDIS Price Guide however we expect this to be mentioned in the July 2021-21 version. We are wondering how a participant will take annual leave from a group support and how much notice will be seen as appropriate.
The NDIS states that providers who offer programs of support must enter into an agreement with each participant specifying the program of support, including the length, exit rules and intended outcomes. We consider community access and making new friends to be worthwhile outcomes.
Supported Independent Living (SIL) supports
SIL price controls are currently being reviewed and the results will be released in the coming weeks. The NDIA states that current price limits apply until the review will be completed. Providers are still required to submit a roster of care (ROC) under the Assistance of Daily Living price limit and need to submit a new ROC if a change of circumstance has been submitted. The NDIA reports on overcharging for auto-extended plans after May 2020 and is currently investigating those claims. The NDIA recently held workshops with large SIL providers to discuss longer- term alternatives to SIL.
Early Childhood Intervention (ECEI)
The NDIA has conducted a review of Early Childhood Intervention. A consultation paper published in February 2021 received 192 submissions and the post consultation report has now been published. Upcoming changes have not been announced yet, however we anticipate a range of adaptations depending on the recommendation and the corresponding responses. Proposed changes among others are
- the increase of age for early childhood services to under nine years
- introducing a distinct ECEI model to support children and families early on
- better promotion and explanation, with easier and more consistent language for families
- the removal of the terminology ‘gateway’
- the introduction of operating guidelines
- the introduction of distinct NDIA planners to focus on young children
- increased capacity to provide Short Term Early Intervention for longer
- better support for children in remote and very remote areas
- mandatory use of the recently introduced provider outcome reports.
The introduction of independent assessments for young children received mixed responses.
Planning policy for personalised budgets and plan flexibility
The NDIA also conducted a consultation on its planning policy for personalised budgets and plan flexibility, receiving 293 online submissions. Interestingly, this consultation was not mentioned in the Provider Forum and given the questions in the consultation were framed around Independent Assessments (a topic that was definitely avoided) we don’t anticipate any imminent changes. In the consultation feedback there was however wide support for more plan flexibility and making plans easier to understand, yet the proposed approach to release funds periodically was objected.
The latest quarterly report explains why the rate of growth in participant payments poses a challenged to the scheme’s affordability. The average payment per participant has increased by 12.5% p.a. for the past three years. For people in the scheme for five years, payments have increased by 38% p.a. and for people in the scheme for four years by 43% p.a. If recent payment growth rates and new entrants are extrapolated, the scheme could cost more than $40 billion within three years. Under the financial pressure, we can assume with some certainty that there won’t be any major price increases in the NDIS Price Guide 2021-22.