Building a mature approach to risk governance

You have probably read about the importance of the Board’s role when it comes to providing oversight of risk management in an organisation. But how do you do this practically? What sorts of activities are common to organisations that have a mature approach to risk governance?

Boards play a key role in overseeing the culture, governance and risk management framework. Different organisations have varying degrees of sophistication and rigour as it applies to the practice of risk management.

Depending on the sector that your not for profit is operating within, there are differing and frequently changing compliance standards to comply with. New Aged Care Quality Standards came in to place last year which address governance and risk management systems.

With the ongoing evolution of the disability sector, there have been increasing compliance requirements for risk management – such as through the risk management section within the NDIS Practice Standards which is administered by the NDIS Quality and Safeguards Commission. With the Disability Royal Commission underway and investigations into several tragic and neglected deaths, it’s likely we will see further changes to systems and governance with the NDIS.

Risk intelligent organisations are rarely surprised by the outcomes of processes like this since they have often addressed any shortcomings of compliance/regulation within their own risk management processes.

Risk governance maturity is different to risk management maturity which we wrote about last month in this article.

Deloitte consultants in the UK have written a number of publications on risk intelligent businesses, and we have used their insights in compiling this article.

Deloitte identified six actions that boards can take to enable a risk intelligent approach to governance. From our experience, we will look at practical applications of how these actions can be applied to not for profit and disability focused organisations.

The six distinct actions are:

  1. Define the board’s risk oversight role

In my experience with not for profit Boards, I have seen the Board’s role on risk oversight articulated and defined in documents such as the Board charter, Board committee terms of reference, governance policies and Director position descriptions. If you don’t have documents like this, then you should consider putting them in place, or reviewing and updating if you haven’t done so for a few years.

  1. Foster a risk intelligent culture

The risk culture needs to flow from your values, and also relates to your code of conduct. Your culture is set by the tone of leadership. Board members and executives should think about how the questions they ask focus on risk – not just from the perspective of avoiding it, but understanding how to effectively manage the risks inherent in providing your core services.

For example, many disability providers need to provide unsupervised services within the NDIS participant’s home and this introduces risks to care workers such as safety, and potential for them to be involved in theft or other forms of abuse to a vulnerable client. It’s not possible to avoid this risk and still deliver the service – so providers need to be selective on who they recruit, supervision processes and other checks and balances.

Being risk intelligent involves taking on the risks that you know best how to manage – and not just avoiding risk.

  1. Understand and approve an appropriate risk appetite

It is becoming increasingly more common for Boards and CEOs to define a risk appetite statement that defines the tolerances around different categories of risk: e.g. financial, safety, environment, customer satisfaction and public reputation.

As part of the risk appetite, you should define the risks that you want to take and those you want to avoid.

For example, organisations with low financial reserves will have little room for error on missed financial goals, and while no one wants to lose money, organisations with larger reserves have the ability to fund projects – such as launching a new office or new product/service under the NDIS – that can take some time to grow, achieve a surplus and provide financial returns.

  1. Help management incorporate strategic risk thinking into strategy

One way to consider risks in the strategic planning process is to look at the strategic plan from the perspective of multiple scenarios and different perspectives on the future. You may like to read about this idea further in the article Your post COVID-19 Strategic Plan.

One of the most practical ways I have seen risk being addressed in the strategic plan is to specifically have a section in the plan for risk which identifies the main risks to achieving the plan, and the mitigation strategies to put in place.

To go a step further, risk mature organisations will also address risks and opportunities within the budget build-up. A budget always has inherent assumptions and sometimes they turn out to be conservative while other times they are underestimated. For example, a medium size disability provider might target a budgeted surplus of $100k, but have identified 4-5 risks (potential negative impact) and 4-5 opportunities (potential positive impact) that might be realised in the year which could result in the actual results being better or worse. This analysis provides a sensitivity analysis to how ambitious or ‘risky’ the budget is.

  1. Assess the “maturity” of the risk governance process

Boards can benefit from completing a self-assessment to compare their practices to best practice standards. Different sectors will often have relevant standards to measure against.

For example with disability service providers, it is the NDIS Practice Standards, and so a self-assessment should include reviewing compliance against the NDIS Practice Standards for Risk Management. Inherent in this is a practical application for these Boards to have visibility over complaints and incidents reporting and follow up.

  1. Make sure the organisation discloses the risk story to stakeholders

The Deloitte framework applies to publicly listed companies which would include requirements relating to disclosure to the shareholders and stock exchange. However, when applied to the NFP and disability sector, it is important to provide disclosures to the ACNC, NDIA, external auditors and your members via an AGM. It would also be appropriate to consider risk as relating to your customers, and any risk that needs communication with them.

We trust this article has provided some insights to consider in reflecting on your own board’s risk governance processes.

CBB has a number of consultants with experience in risk management and governance. If this article has identified something that you would like assistance with for your organisation, then please contact one of our consultants for an initial obligation free consultation on 1300 763 505.

 

Andrew Ellis
Business Consultant
Email: aellis@cbb.com.au
Phone: 1300 763 505

 

Deloitte – Risk Intelligent governance – Lessons from state-of-the-art board practices https://www2.deloitte.com/content/dam/Deloitte/us/Documents/risk/us-risk-intelligent-governance_102214.pdf


Four key items to look for in your end of year financial review

For many organisations a great deal of thought and effort goes into planning an upcoming financial year. Strategic plans are reviewed, meetings are held and budgets are prepared.

With so much effort put into looking forward, it is equally important to look back and review the financial year that has just passed.

When reviewing financial results the time horizon in which results are reviewed sets the scene for the entire analysis.

A year on year review will compare 12 months of financial results to the corresponding previous 12 months. This can of course be for any 12 month period however a 12 month period that corresponds with your reporting period, such as 1 July to 30 June, is most common. You will note that the standard convention of year end accounts is to show the previous year results, however this merely shows the results for the two years. By performing certain calculations and analysing the results, as outlined below, and even visualising the year on year changes, as outlined here [placeholder], far greater insights can be gained.

Here are four key items to look for in a year on year review. Although some may seem obvious, ask yourself, have you done the following calculations and do you know the results for your organisation?

1. Revenue

Most of us when reviewing financial reports will look to revenue first. Revenue is one of the most insightful figures (in addition and in combination with other figures such margins and cash – outlined below) when reviewing and analysing financials. It is a key indicator of growth or contraction and is often sighted in long term strategic planning.

Determine how revenue has changed year on year with the following formula:

(Revenue most recent 12 months / Revenue corresponding previous 12 months)
x 100%

Review the year on year percentage change against your strategic objectives. Broadly speaking if the result is below zero it may suggest that your organisation is contracting and a result above zero may suggest that you are expanding. You may choose to use inflation or a number around 2% as your base rather than zero as you are effectively contracting if you are growing at less than inflation.

Any changes in revenue should be reviewed in the context of the events in the last 12 months. A key question to ask when reviewing revenue changes is whether any changes are systemic or one-off. Systemic changes occur due fundamental factors that are not one-off in nature. Declining revenue due to an increase in customer attrition caused by poor customer service would be an example of a systemic issue.

Conversely revenue may change due to a one-off event that was unpredictable and hopefully will not be repeated in the future. Decline in revenue due Covid-19 related issues is an example of a one-off issue.

Being able to differentiate between systemic and one-off issues is critical in reviewing year on year changes and will play a vital role in the action required next. Systemic issues are more likely to be repeated if not addressed, whereas one-off issues may resolve themselves or require a strategic organisational shift if the one-off is deemed to have now changed the landscape and environment in which your organisation operates. Such is the case for many organisations with Covid 19.

Once issues causing a change in revenue are identified, ask yourself, how likely is it that the issues will be repeated?

2. Surplus

Your organisation’s ability to cover all of its expenses is key to your long term financial sustainability. The level of surpluses generated also reflects the financial efficiency of your organisation and your ability to manage margins.

Determine how surpluses have changed year on year with the following formulas:

Net profit margin:
Most recent 12 months: (Surplus / Revenue) x 100%
Corresponding previous 12 months: (Surplus / Revenue) x 100%

Compare the two net profit margins. A higher result in the most recent 12 months suggests that the organisation is financially more efficient. A lower result in the most recent 12 months suggests that the organisation is financially less efficient and may be experiencing issues regarding margin management.

Again ask yourself if margins are being compressed because of systemic or one-off issues and how likely it is that these issues will be repeated? You may be less worried if margins this year have been compressed due one-off expenses that are unlikely to be repeated in comparison to margins falling due to systemic issues such as consistent overspending.

In addition to year on year changes in your net profit margin, it is worth noting that cash reserves are often built through year on year surplus. Each year your net profit margin should at a minimum beat inflation, and in addition to beating inflation contribute to your long-term cash target.

3. Key expense margins

Your organisation’s ability to manage margins is also key to the long term financial sustainability of your organisation. After all if expenses are increasing at a faster rate than revenue, financial losses will become inevitable.

To review key expense items, choose an expense item and review it as a percentage of revenue for both years.

For example:

Wages to revenue:
Most recent 12 months: (Wages / Revenue) x 100%
Corresponding previous 12 months: (Wages / Revenue) x 100%

Compare the two results. A higher result in the past 12 months suggests that the organisation is financially more efficient in relation to the expense item in question. A lower result in the past 12 months suggests that the organisation is financially less efficient in relation to the expense item and may be experiencing issues regarding margin management.

Margin management is vitally important to an organisation, particularly for a growing organisation. Organisations that are growing need to grow in a financially sustainable way and a key way to check this is by reviewing if margins are remaining stable or improving.

4. Cash position

It goes without saying that cash is critical to all organisations.

In relation to a year on year review, reviewing the closing cash position at the end of the most recent 12 months compared to the closing cash position at the end of the previous 12 months, allows you to cut through the noise that can occur in a raft of numbers. In 12 months many many transactions and changes would have occurred. Revenue may have increased, expenses may have increased and non cash items such as provisions may have changed.

By reviewing the closing cash positions, you can focus on the key question – “Are we holding more cash?”

Change in Cash held
Cash position at the end of the most recent 12 months
Cash position at the end of the corresponding previous 12 months

As mentioned earlier, it is also worth reviewing your closing cash position against your long-term cash target.

Each of the items above should be reviewed against your long term strategic objectives and considered specifically in relation to the goals and aspirations of your organisation.

Expanding your financial analysis and review to a 24 month – or longer – horizon will provide high level, longer term insights.

If you’d like any assistance with your end of year financial review, please call 1300 763 505 for an initial obligation free consultation with Dimitri.

 

Dimitri Matsouliadis
Business Consultant
Email: dmatsouliadis@cbb.com.au
Phone: 1300 763 505

 

 


Your post COVID-19 Strategic Plan

What were you hoping that 2020 would be about? What did your strategic plan or business plan say that you wanted to achieve this year? What underlying assumptions did you have in the strategic plan that no longer hold true?

I saw a statistic recently that 82% of the time a strategy fails can be attributed to misleading assumptions. Think of Kodak and how they were left behind in the transition from film to digital photography.

Many businesses have thrown out whatever strategic plan they had for 2020 and have been reacting day to day and month to month as the COVID-19 health crisis and related economic crisis have unfolded. Whatever you assumed in your strategic plan for 2020 has quite possibly already proven to be false.

Growing uncertainty

It can be challenging to prepare strategy in a VUCA environment – VUCA stands for volatility, uncertainty, complexity, and ambiguity.

Even pre COVID-19, the more innovative organisations were questioning the value of a three to five year strategic plan given the likely changes to the operating environment over that period – meaning the shift to a more agile strategy process.

Now we have the COVID-19 health crisis, ensuing economic crisis, reduced travel and other social restrictions, and many geopolitical risks are escalating too.

Even in this ever changing and VUCA environment, organisations need to stay true to their ‘anchors’. In the absence of being able to operate to a structured plan, what are the things that are critically important to you as an organisation (could be values, client focus, impact etc)? These will provide your context for decision making when the external environment turns your strategy to dust.

Future scenarios

Organisations often think about different strategic planning horizons – with the short, medium and longer term – but this is usually focused on a linear progression.

With this mindset, we think in strategic plans about the one desired future that we are working towards. What if instead we were to have multiple views of the future under different scenarios, and to develop a strategic plan on that basis?

In a recent presentation to members of peak body National Disability Services, futurist Professor Sohail Inayatullah spoke about a range of potential unfolding social and economic scenarios.

It is possible in the time ahead that a range of scenarios could play out: the coronavirus could mutate, wages growth be flat, nations could break apart, international travel could be restricted for years and/or we could fall in to a multi-year recession. Despite best efforts and bipartisan support, could a multi-year recession put budget pressure on the NDIS program to be reduced in size and scale?

Less dramatic but still significant, this current economic period could be a time of slowing down in order to speed up – with the potential for the crisis to drive innovation and reforms that will provide for greater economic growth and prosperity.

There may also be ‘sticky changes’ that flow from our present crisis, with changes made to personal and business behaviour becoming more mainstream: increased working from home, a greener economy to reduce pollution, added COVID safety/risk measures, increased domestic travel over international and increased telehealth or remote service provision.

Within the disability sector, there are other uncertainties like the potential impacts of the Disability Royal Commission on regulation and compliance, and continued changes to the NDIS marketplace including to the Price Guide.

For many disability providers, there is some surety in funding with the NDIS business model but COVID-19 has had an impact on the way services are delivered.

It’s more work to build out a strategic plan with possible different future scenarios, but if there is any time this is worthwhile it would be in the current situation. Successful organisations now will be the ones that spend more time planning and strategizing rather than being blown around by the changes.

Business recovery shape

As you look to the future of your own organisation and its growth trajectory (whether measured by customer numbers, revenue or staff numbers), what shape does it look like? Is it:

  • V-shaped with a sharp decline and sharp recovery?
  • U shaped with a more gradual decline and recovery?
  • W-shaped with a double dip – perhaps corresponding to a COVID-19 scenario where there is a second wave of the virus outbreak?
  • L-shaped with a sharp decline settling in to a new normal smaller size?
  • Hockey stick shaped with a small decline but expectation that the trajectory will return to growth?

Making the right assessment of the future is important in preparing your organisation to be in the best position for the future. Getting this wrong could prove disastrous – for example, maintaining your existing cost base assuming a U or V-shaped recovery only to find down the track that it is L-shaped.

Organisations should be having regular conversations about unfolding risks, market changes and implications to strategic plans at a management and Board level.

Taking a view on future scenarios and the shape of the recovery are important strategic discussions to focus on.

CBB has a number of consultants with experience in business and strategic planning. We could help you with the whole strategic planning process, or just to workshop one or a few elements like this.

If you’d like any assistance with reviewing or developing elements of your strategic plan, please contact 1300 763 505 for an obligation free consultation with one of our Business Consultants.

 

Andrew Ellis
Business Consultant
Email: aellis@cbb.com.au
Phone: 1300 763 505

 


For a good strategy you don’t need much time…

Strategy needs space

In an interview the productivity consultant David Allen said that strategic thinking does not require large amounts of time (Clark, 2015).  More importantly, it’s space that allows innovative ideas and decisions that will guide the future direction of your not for profit.

Being strategic is one of the most important behaviours that guarantee an organisation’s long term success and almost every leader would like to have more time for strategic planning (Clark 2018). We are all too busy, dealing with the daily fires, and now that many of us are working from home, we feel like we’re working all the time.

Keeping track of our time and setting a regular time aside for strategic thinking and planning can help to embed strategic thinking into our schedule (Clark, 2018). Getting away from our routine and ‘to do lists’ can create some mental space. Encouraging our managers and team leaders to set some time aside for strategy and offering opportunities to share their thoughts and ideas can also foster strategic thinking throughout our organisation.

Strategy needs knowledge

You would not buy new a family car without doing some research, a test drive and without asking a friend who knows more about cars to have a look under the bonnet. Yet, I am regularly meeting not for profit leaders who open a new office or start a new service based on their gut feel.

Gut feel and intuition are important instigators but once you have formed your idea you should also consciously and thoroughly evaluate your strategy. Time pressure can work against assessing a decision, however often it only takes a few hours of top line research and number crunching to find the necessary data and evidence that supports or dismisses the idea. If you or your leadership team doesn’t have the time or know-how, you could engage a student to do some basic data analysis, or for something more sophisticated seek assistance from a consultant with experience in the sector. Spending some more time and effort on researching your idea can open new alternatives or modified ideas that can lead to better outcomes and more effective use of your limited resources.

Strategy needs multiple views

‘The government representative or the consultant has told us that there is the future and there is great potential for us’.  If this was the case why isn’t everyone doing this – or is everyone doing this? Good listeners tend to have more ideas, yet listening to just one source risks establishing a strategy on a distorted, or narrowly focussed reality. A stakeholder analysis can help us identify who has an interest and who will be impacted by the strategy. Talking and listening to all parties involved can help form a more realistic approach and lead to better outcomes. Engaging people who may influence the success of the project early on can help to overcome barriers and create more allies once you begin to implement the strategy.

Strategy needs empathy

Just because we have worked for many years in the sector and our clients tend to be loyal, it does not necessarily mean that we really understand and know the people we support. Do we know our clients’ aspirations, interests and passions? Do we understand what is currently working well and what is not? Do we understand the hardship, the barriers and the worries of our beneficiary? What are their physical and emotional needs, how do they think about the world and what matters to them? What would they like to achieve and how would they like to live their lives. We live in a fast moving world and while basic needs are likely to stay the same, external pressures heavily impact on barriers and support needs.  Unless we ask the right questions and we are prepared to empathise we are unlikely to come up with a strategy that creates meaningful and lasting change. Defining and understanding the need will help us to establish a strategy that creates outcomes that are needed and wanted, and drive meaningful improvements in quality of life.

Strategy needs courage

‘We have trialled this and it did not work’ is a common sentence that I hear in strategy workshops. It is an effective innovation killer and indicates that we are too scared to do things differently.  It also reveals that we are often too focussed on the activities, the ‘how’ of our strategy before we define the ‘what’. What do we want to achieve that creates lasting change?

Once we have defined the outcomes we require some courage to do things differently to the past.  Our beneficiaries and other stakeholders could assist us to co-design the activities or clarify why our attempts in the past failed. Most importantly we should have the courage to make ourselves redundant. Does our work create dependencies or do we empower our beneficiaries, facilitate independence and create long term impact?

Strategy needs ideation

Have you ever done a home renovation or built a new house? Usually it takes several plans, discussions and modifications until the final plan can be approved. Strategy needs ideation and time to form. If we rush the approval process the end result will reveal many unwanted surprises. Gaining better knowledge, reviewing our internal strengths and weaknesses, listening to everyone involved and giving our beneficiaries a strong voice will necessarily lead to variations along the way. Engaging a critical sounding board can broaden our thinking, or adopting an outsider’s view can help us review our assumptions and biases to develop a strategy that is bigger and better.

If you need assistance with your next strategy workshop, market research or if you would like an outsider’s view, please contact 1300 763 505 for an obligation free consultation with one of our Business Consultants.

Dr Ellen Schuler 
Business Consultant
Email: eschuler@cbb.com.au
Phone: 1300 284 364

 


The NDIS Annual Pricing Review and changes in the NDIS Price Guide 2020-21

The final version of the NDIS Price Guide 2020-21 (Version 1.0) effective from 1 July 2020 has been released. The 102 page document reflects the outcomes of the Annual Price Review. The most significant recommendation in the review is the advice that the NDIS should not increase prices due to the uncertainty of COVID-19. The NDIA should monitor economic conditions carefully and promptly to respond to emerging issues.

The new Price Guide reflects the outcomes of the Fair Work Commission’s annual price increase on minimum wage rates, the ABS consumer price for capital supports and an adjustment of shift loading for casual workers on weekends in line with the SCHADS Award. The temporary 10 percent COVID-19 price loading was removed from the new Price Guide. Support Coordination can still be charged under core supports. This is expected to be removed from the Price Guide by September 2020.

Changes to the Disability Support Cost Model

The price limits for core supports are determined by a formula based on the NDIS Disability Support Worker resourcing model. The review examined the assumptions and parameters of the model and came up with the following adjustments:

  • Decrease of permanent to casual staff to 70%/30% (from 80%/20%)
  • Increase the share of staff assumed to take up their long service leave entitlements to 100%
  • Decrease the assumed workers compensation premium from 3 to 1.7%
  • Increase the assumed overheads percentage to 12%
  • Increase the supervision ratio from 11 to 15
  • Increase the provision of allowances for support workers and supervisors to 1% of salary

Some positive changes, yet we believe the increase in supervision ratio fails to recognise that efficiency needs to be balanced against service quality and safety as well as employee support and satisfaction. The argument that numerous providers manage to be more efficient with a higher supervision ratio indicates a narrow finance focused mindset. The survey has revealed that the average utilisation rate is in fact lower than the model assumptions (average of 79.8% surveyed versus to 92% for standard supports in the model assumptions). The average overhead percentage (as loading on direct care costs) among survey respondents is at 27.7% (in comparison to 12 % in the new model). The changes to the model plus the wage component have resulted in moderate price increases. The price for a standard weekday support has increased from $52.85 to $54.30. Participant plans will be indexed from 1 July 2020 and will be adjusted through a systems update on 11 July. Providers will have to manually adjust service bookings.

Changes to Temporary Transformation Payments

The Temporary Transformation Payment (TTP) was reduced by 1.5 % to 6 % which is no surprise as this was announced when the TTP was introduced. What is new to the TTP is that providers now need to ‘opt in’ or ‘opt out’ of claiming TTP during the 2020-21 financial year. Providers need to inform the NDIA if they are planning to charge TTP by replying to an email they can expect shortly. All other eligibility criteria for charging TTP remain in place and unregistered providers still cannot claim this rate. Plan managers are not responsible for ensuring that providers are TTP compliant however need to be able to inform the NDIA which providers have claimed for TTP and should not pay TTP claims from non-registered providers.

The Annual Price Review assumes that providers who do not charge the TTP have lower costs and are managing to operate at below the current price limits with 40 % of eligible providers choosing not to access the higher TTP prices. We believe that this assumption is lacking evidence. Registered providers are concerned that participants need to give up some of their support hours to pay for services that are charging TTP prices. Some are fearful that they might lose customers if they decide to charge the higher fee. Many more providers would opt for the TTP payment and use the funds to improve their services, systems and workforce capabilities if the NDIS plan funding would be indexed or if the TTP payment would be paid directly to providers.

Cancellation rates

Providers will be able to continue to charge 100% of the service fee when participants cancel at short notice. The increase from 90% was introduced as a response to COVID-19 and this rule is here to stay. The definition of ‘short notice’ however will change back to the pre COVID rules. As of July participants need to give two clear business days’ notice (for supports less than 8 hours and less than $1000) or the provider can claim 100% of the agreed fee if they cannot find alternative billable work.

Modified definitions

Level 1-3

The Level 1-3 high intensity support has led to some confusion in the past and the review has recommended that the new Price Guide clearly links the price limits to skills and experience of the support worker:

Level 1- Social and Community Services Employee level 2 (below the maximum pay point)

Level 2- Social and Community Services Employee level 2 (at the maximum pay point) or level 3

Level 3 – Social and Community Services Employee above level 3

The Price Guide 2020/2021 states that in general level 2 applies to most high intensity supports, however if the worker does not have the skills and experience then level 1 should be applied. In translation this means that if a less skilled and experienced worker provides support to a person who requires high intensity support, then this is still called high intensity support, however it is paid at standard support level. Or in short, if a provider employs less experienced staff and pays less salaries the NDIS will pay less for the support. We recommend that providers who charge at the higher levels should clearly communicate to their customers that they will be looked after by staff with a higher skills and experience.

Time of day, day of week

Providers of assistance with daily activities need to claim based on the time when the support is delivered to the participant. The new Price Guide clarifies definitions to assist providers determine the day of the week and the time of day during which the support was delivered. When a support for a participant crosses shift boundaries and the same worker delivers the support the worker may be paid the higher rate as determined in the Enterprise Bargaining Agreement or Industry Award. In this case, the higher of the relevant price limits applies to the entire support, however the provider must discuss this with the participant in advance.

Establishment fees

In the past only providers of daily personal activities could charge an establishment fee for new NDIS participants in their first plan. This has been extended and now providers of personal care, and participation supports including Specialist Supported Employment, can charge a once-off establishment fee if they are supplying a minimum of 20 hours per a month for three or more consecutive months. Each provider can only claim an establishment fee once across all plans. The establishment fee cannot be greater than an amount equal to ten times the hourly weekday price limits for a disability support worker and is set at $543.00 in 2020/21.

Group based activities

Group based activities in the community and in a centre will now have the same maximum price. This applies for group support under High Intensity Daily Personal Activities (104), Specialised supported employment (133) and Group and Centre Based Activities (136). Providers can charge an extra fee if the support is delivered in the centre to cover capital costs such as maintenance and refurbishments of the centre ($2.15/ per participant). Providers will also be able to claim for non-face-to-face supports as this will no longer be built into the price. This was set at seven minutes (or an additional 12%) for each participant in the previous group charges.

This is a major change as providers no longer use the various worker to participant ratio support items. To claim for a group service providers need to claim against the 1:1 support item by apportioning the time spent with the group among the members of the group. This will eliminate around 200 line items from the support catalogue, however it sounds like a logistical nightmare for providers who now have to apply three line items instead of one. The price guide states that in working out the fee for non-face to face supports it is not appropriate to charge all participants an average fee. This additional fee needs to be worked out for each participant, which appears challenging in the context of group supports. It will be even more challenging to calculate the cost of group support by group number and time spent in the group as CRM systems are currently not set up to calculate costs. The change could provide opportunities for ‘open group’ concepts in centres where participants can roam between groups to choose which activity they would rather do on the day.

Thankfully the NDIS has introduced some interim arrangements and providers will be able to use the old group prices (at the appropriate participant to staff ratio) for the next 12 months. Providers must use the same method for claiming across all group supports. The group rates have been indexed and can be found in the Support Catalogue 2020-21.

Introduction of programs of support

From 1 July 2020 providers are allowed to enter into service agreements for programs of support for assistance with social, economic and community participation, supports in employment, or any capacity building support. The program should work towards the achievement of a specified outcome and run no longer than 12 weeks. Providers must enter into service agreement with each participant who should be able to exit from the agreed program subject to an agreed notice period (maximum of 2 weeks’ notice). This means that participants need to pay if they cancel the attendance of a program, however if they leave the program providers will still be out of pocket. Providers cannot pre-claim for the program however can claim for each instance of support.  Programs of support are listed under group supports in new Price Guide and we assume that the group activity rates apply.

Line item updates

The New Price Guide has re-introduced the following support items: Self-Management Capacity Building, Skills Development and Training, Innovative Community Participation. These were missing from the draft published a few weeks ago.

Plan management

The price review found that capacity building and training in plan administration and financial management support does not function as intended. As of July, Support Coordinators and Plan Managers will be able to charge for travel and non-face to face supports to offer this support more effectively.

Geographic Classification

The pricing review recommends that the NDIA should adopt the Modified Monash Model (MMM) 2019 classification (as released by the Department of Health) to determine prices and travel time limits in remote and very remote areas. The classification in the current and new Price Guide is still based on the MMM 2015 model, plus some reclassified postcodes. The NDIS website announces that this change will be introduced in October 2020. Penneshaw in SA and Carnarvon and Kununurra in WA for example will change from regional (MMM5) to remote (MMM6). Other regions that are impacted are listed here. The review also recognised that higher prices in remote and very remote areas are unlikely to address thin markets and recommends the greater use of commissioning. We are curious and eager to learn how this will look in the future.

Telehealth

The Price Guide draft requested that services provided via telehealth use the price limit that applies to the location of the person delivering the support. The final Price Guide however allows participants in Remote and Very Remote areas to agree on the higher price limits if they are satisfied that the support provides value for money. The higher rate cannot be charged for Non-Face-to-Face Supports or report writing.

Therapy supports

The pricing review as well as the review of NDIS therapy pricing arrangements (2019) found that the NDIS price limits for therapy services seem high compared to other state compensable schemes and may be distorting the market for therapy services. The review recommends that prices for therapy supports should not be indexed in July 2020 and that the NDIA should conduct a comprehensive review as part of the Annual Pricing Review every two years to commence in July 2021.  Some capacity building supports were indexed. Support Coordination and Plan management were increased by 2.1%.

Provider travel

As of July the travel expenses of providers will no longer be regarded as a business overhead. The new Price Guide introduces 37 new line items to charge for Provider travel – non-labour costs. This can be charged in addition to the provider’s travel time and up to $0.85/km (for a vehicle that is not modified) or the costs of other forms of transports and associated costs (up to the full amount).

For example a provider delivering a group support in a centre can charge: provider travel – non-labour costs, provider travel (for the time of travel), support line item (appropriated for the number of participants and for the time of support), non-face to face time and centre capital costs. If the support is not delivered in a centre but involves an outing – the provider can charge for activity based transport instead of the centre capital cost. Thankfully the structure of the new Price Guide will make it much easier for providers to understand what can and cannot be charged for each support, however the quoting for services in advance will be challenging.

The new Price Guide also states that when a worker is travelling in a ‘region’ to provide services to more than one participant, the provider should apportion the travel time between participants (including the return journey if appropriate). The terminology ‘region’ is not explained and we anticipate that this is up to the provider to define regions of support.

Future NDIS Annual Pricing Reviews

The Annual Pricing Review recommends that future reviews should be conducted from July to December each year (commencing in 2021) with changes to take effect from the following July. A welcome change as this would give providers time to understand and review the impact of these changes, to adapt and plan accordingly.

More Price Guide changes

The New Price Guide 2020/21 introduces more changes and new supports that are not discussed in the Annual Price Review. These include

  • Assistive Technology Rental support to facilitate hospital discharge. Two new line items allow participants to rent any assistive technology they need to live at home for up to six months until their assessments and amended plan is in place. This is an interim arrangement until September 2020.
  • Psychosocial Recovery Coaches to offer added supports to participants with a psychosocial disability. This support is provided under the ‘Assistance in Coordinating or Managing Life Stages, Transitions and Supports (Support Coordination)’ registration. Psychosocial recovery coaches require at least a Certificate IV in Mental Health Peer Work or in Mental Health or equivalent training and a minimum two years of experience in mental health related work. Recovery coaches are different from support coordinators as they are expected to bring specialist knowledge and skills in psychosocial recovery and mental health in addition to service navigation. The NDIS will not fund support coordination if a participant receives funding for a recovery coach.
  • Individualised Living Options (ILO)

This is for support to give people access to alternative living arrangements including assistance with the exploration and design of living options (charged on an hourly rate) and funding for the support model (which is a quotable item). The support model funding also includes the costs for monitoring and redesign of the ILO. The NDIS is expected to publish additional information on ILO shortly.

  • Assistance from Live-in Carers is an alternative living support, however needs to be stated in the plan under line item 01_003_017_1_1. The Price Guide does not specify who can classify as a live-in carer. The Price Guide also lists supports for other living arrangements such as a host family or assistance in a shared living arrangement. These supports are also subject to quotation.
  • Supported Independent Living (SIL) will receive a major shakeup, including abandoning the quoting process. The new Price Guide sets hourly prices based on the time and day of the week, and if the person is receiving standard or high intensity support (one level only). The Price Guide does not differentiate between the sizes of the group homes nor specifies a maximum number of residents. The NDIA website states that the NDIA is conducting a review of SIL prices and that new SIL specific price limits will be included in an updated Price Guide later in 2020.

Existing plans containing agreed quotes will continue until the end of their 12 month term. For participant’s NDIS planning meetings, the provider should develop a roster of care to help the NDIA decide the type of supports to be included in the participant’s plan. The NDIA is also working to strengthen participant input into the SIL planning process.

  • Supports in Employment are designed to offer more flexibility to assist participants successfully engage in employment.

Five new line items offer opportunities to deliver support in employment with hourly price limits based on the day of the week and time of supports. Where the support is delivered to a group of participants the provider should claim the relevant fraction of the time for the support from each participant’s plan. ADE providers registered as Specialised Supported Employment providers can use the support items. Alternatively, ADE providers can choose to use the pre July ADE pricing arrangement for up to 18 months.

Employment providers will also be able to claim for transport of participants to and from community based supports and claim non-labour costs associated with provider travel.

For questions, comments or individualised Price Guide support for your organisation contact Ellen.

Dr Ellen Schuler 
Business Consultant
Email: eschuler@cbb.com.au
Phone: 1300 763 505

 


The community impacts of COVID 19

We recently ran a grant program for community organisations, offering 20 places on a ‘Working Mind’ program to apply mindfulness and neuroscience practices to organisational leadership in a VUCA environment. We opened the program to organisations who had been particularly impacted by COVID 19.

Unsurprisingly, the program was oversubscribed. The applicant organisations were diverse – coming from every state and territory; metro, regional and remote; and covering all areas of the not for profit sector. It was hard to pick the 20 most deserving and suitable for the program, but the process gave us an insight into the way that COVID 19 is affecting communities, and the organisations that support them.

In recent months I’ve been reflecting on how COVID 19 impacts all of us differently as individuals. For all the talk of people being bored in lockdown with nothing to do, others have never been busier, or more in need of the opportunity to return to the sanctuary of their home and shut out the outside world. At CBB we work with nearly 600 community service organisations nationwide. Since the COVID 19 restrictions kicked in, we’ve been trying to predict how shutdown would affect our clients. Any attempt to segment our clients to analyse the potential impact has been futile – they’re all affected differently. Whilst we can anticipate that most organisations will have shifted their office-based employees to home working, the rest is determined by the interplay between their client group, their service model and their funding. Disability organisations are providing essential services, but if all your services are group work or activity based, the only way to operate under COVID 19 has been to take services online. Organisations dependent on event-based fundraising income will feel an immediate impact, but those that rely on regular donations – well that depends on your donor profile and how their income has been impacted by COVID 19. Grant funded organisations have a secure income (for their grant period), and have been able to continue operating, as long as they can distance, or work online.

Each of our applicants to our Working Mind program was asked to describe how COVID 19 had impacted their business. Their stories were varied. As expected, most had moved employees to home working and event based fundraising was taking a hit. Some had shifted face to face or group based activities to online platforms, but in some cases client access and capability with technology meant that online platforms simply wouldn’t cut it – end of program. Others had to move premises, so that they could still operate with social distancing in place. Employees and volunteers were also impacted. Volunteers – particularly those in high risk cohorts – were staying away, and employees were struggling with the isolation of home working. This was a particular issue for those with counselling and case management roles, where working from home removed them from the peer support networks to spontaneously debrief a difficult or distressing client interaction. Those offering cultural or heritage venues were facing extended closure periods with no visitors, a key source of income. Major organisational milestones were going uncelebrated – a missed opportunity to raise funds and engage with communities.

Inevitably, given the nature of the program, organisation leaders described the personal toll of the complex challenges. The combined pressures of business continuity, maintaining employee wellbeing and delivering community services, alongside fulfilling their family and domestic responsibilities, is putting their own wellbeing at risk. Looking after self and ensuring recovery time is a key aspect of the Working Mind program.

In terms of community impacts it was not surprising that some organisations were seeing an increased demand – particularly those working with food poverty and family violence – at a time when securing employee and volunteer engagement was unusually challenging. Several reported the impact of lockdown in ‘trapping’ people. Whilst this has been discussed in the context of family violence, it is also an issue for carers – hit by a double whammy where they have been unable to access community support or respite services, and the provision of paid supports into the home has declined.  Those living in remote communities have not been able to leave to access work or services, and the supports that normally come into communities have stopped. And people with pre-existing mental and physical health conditions, or those with previous experience of trauma or stigma, have found anxiety levels increased as they are triggered by the pandemic.

Collectively, these accounts of COVID 19 paint a picture of the impact of the virus itself, and the measures to restrict its spread, on the most disadvantaged and marginalised people in our communities, and the organisations that serve them. We’ve seen some great examples of organisations being innovative with their business model – taking training programs and arts groups online; shifting from group based to one to one activities. Collectively we’ve shown that we can adapt and change quickly when there is a big enough driver to do so. We can see potential for some of the positive changes to sustain beyond the virus and the lockdown restrictions – more flexible working, reduced travel time and costs, increasing reach through more digital working. We’ve honed our skills in risk and crisis management, and we’re looking at business continuity plans from a different perspective. But we can also see the costs (financial and non financial), particularly in fatigue, mental energy and wellbeing – in communities, in organisations and in individuals. These aren’t going to go away quickly when the pubs reopen. We’re all going to need some recovery time.

If you’d like any assistance with your organisation’s recovery from the impacts of COVID 19, please contact 1300 763 505 for an obligation free consultation with one of our Business Consultants.

Jane Arnott
General Manager, Consulting and Business Services
Email: jarnott@cbb.com.au
Phone: 1300 763 505


Risk maturity

Does this sound like you or your organisation?…..

We’ve got a risk register and mitigation plans. We report to the Board on risk every meeting. We’ve got dozens of procedures that help us with compliance and work health safety. We’re accredited to the NDIS Quality and Safeguarding standards and maybe even another different accreditation body as well. We tick the boxes on what we need to do with clinical compliance. We even have a risk policy that was based on the international standard. Surely, we are doing everything we need to on risk management, right?

Maybe. If this example sounds like you, then you are certainly doing a lot of things right on risk management, and that is really important for minimising the risk of incidents and ensuring you achieve the objectives in the strategic plan that you are aspiring towards.

Maybe you don’t have many or all of the above elements in place, and that’s ok too. Every organisation starts somewhere, and risk management measures need to be scaled from small, low risk organisations up to larger, complex and higher risk organisations.

Deloitte produced The Risk Intelligent Enterprise Maturity Model about a decade ago and I think it provides a great perspective to look at your risk management activities, no matter the size or focus of your organisation.

Level 1 Tribal and Heroic is about ad hoc risk management which might be done well by one person or group within the organisation

Level 2 Specialist Silos is where there are some risk mitigations in place and steps taken to reduce risk. You might have insurance in place and a few simple policies, but risk is only thought about by a few people.

Level 3 Top-down is where the tone of risk management is set at the top and policies/procedures are in place, but risk management is still somewhat reactive. Many disability and aged care organisations are at this point now – the quality and safeguarding standards that we operate under have ensured that most organisations get to this point. However, accreditations are about setting minimum standards, and best practice requires doing more than the minimum.

Level 4 Systematic is where risk management is getting more sophisticated. By this point, risk is a factor in every business decision being made, staff take ownership bottom up in the organisation, and a cultural transformation has taken place where all staff view their decisions and actions through a lens of risk management.

Level 5 Risk Intelligent is the highest aspiration, and it is difficult to get an entire organisation to this level. I’ve seen some teams operate at this level, and when you do, you can make amazing decisions which boost profitability and remove the downside risks when things go wrong, as they sometimes do.

There is a big difference between being Risk Intelligent and Risk Averse. Being Risk Intelligent is about knowing what risks your organisation is better than anyone else at taking on, rather than avoiding risk altogether.

The international standard on risk management defines risk in terms of the effect of uncertainty on achieving objectives. Risk management is linked inextricably to your strategy and what you are aspiring to achieve. If your strategy and business model involve working in difficult situations or with challenging people, and you have the right people and systems in place, then you can operate a business model like that in a Risk Intelligent way.

I’ve been in workshops where this model has been shown and it is fascinating to see people look at it and calibrate the risk practices against all the different parts of their organisation.

We all want to be level five. It’s only human when you put up a model like this to think that you are doing well. However, more often than not, I have heard people reflect that there are functions or parts of the organisation which operate at different levels.

Maybe some of the clinical elements of the work are at about a level three or four, but other back office administration functions are more like a level two. If your goal is to put in place the minimum standards of quality and safeguarding for your industry sector, then you are likely only operating at level three at best. Achieving a higher level requires leadership modelling and an organisation commitment to resource it appropriately.

What are some practical steps you can take to improve your level of risk intelligence?

Stop and think – do we need to change? What needs to change? Who do I need to talk to about making changes? Have I got the right people or tools/technology to get there? Do I need to update or write a new risk policy? What do you need to do to improve the risk culture? Do you need some external help to map out a path to becoming more risk intelligent, or a specialist consultant to help with one element of it?

CBB consultants have experience in helping organisations plan their risk management activities. If you’d like any assistance with risk management, please contact 1300 763 505 for an obligation free consultation with one of our Business Consultants.

 

Andrew Ellis
Business Consultant
Email: aellis@cbb.com.au
Phone: 1300 763 505

 

Reference: Deloitte – The Risk Intelligent Enterprise: ERM Done Right https://www2.deloitte.com/content/dam/Deloitte/global/Documents/Governance-Risk-Compliance/dttl-grc-riskintelligent-erm-doneright.pdf


SWOT and SOAR

Everyone has probably heard of a SWOT analysis, and most people have done one before. A SWOT can be a great way to quickly summarise many of the key issues that need to be considered in the strategy process.

In a SWOT, the strengths and weaknesses are looked at in terms of the organisation’s internal perspective. For example, what strengths and weaknesses are there with the organisation’s people, systems, technology, products/services, marketing and so on.

In my experience, many people and organisations think more highly of their strengths than they should. You might have a piece of software or a key person that you see as a strength, but wouldn’t the competitor down the road say the same thing about their organisation? Strengths need to be thought of in relation to competitors.

The opportunities and threats reflect external considerations. It might relate to growth opportunities in the market, new technology being developed, competitor actions or government policy changes, for example.

While simple to complete, a SWOT analysis can suffer from being too negatively focused on the Weaknesses and Threats. It can become about fixing what is wrong, rather than pursuing the opportunities and potential growth available.

CBB consultants recommend that organisations consider using a SOAR model instead of a SWOT analysis. We used this model when working with disability service providers to plan their transition to the NDIS. We have found that it encourages people to look past the immediate challenges to what can be in the longer term.

SOAR stands for Strengths, Opportunities, Aspirations and Results. The model removes such a heavy focus on the Weaknesses and Threats (which make up two of four elements, or half of the model), and focuses more on Opportunities aligned to the Aspirations.

The Aspirations part of the model also helps to provide a greater alignment to the organisation’s vision and purpose. The Aspiration and Results help people contributing to the SOAR to be more positive and future oriented.

We used the SOAR model with a disability services client recently to look at growth options for one of their business areas. In discussions about the model, we agreed to add a new element in to the model for the workshop which was the Constraints. The client wanted to document and consider both the internal and external Constraints that could stop them getting to the Aspirations and Results.

With this addition, we adapted the model to SOCAR. There was a suggestion from someone who thinks that acronyms used as management tools need to sound like a real word, and that the new element be Barriers, so that the model would be SOBAR!

Here’s an example of SOAR used with a local occupational therapist provider working with children or young people with disability.

We trust that this article has got you thinking more about the benefits of using the SOAR model instead of doing a SWOT because “that’s what we have always done”.

To make the learnings from this article more real, why not delay whatever you were planning on doing next just for 15 minutes and have a think about where your business is now. If you are like me, then pick up a pen and paper and put the four headings across an A4 page, or if you prefer,  just open up a Word document and create a 2×2 table.

We’ve heard from many organisations at the moment that they are needing to review their current strategy as a result of the continually changing environment we find ourselves in with COVID-19. There’s never been a better time to stop for a few minutes and think about your strategy. I guarantee that the time spent writing this down now will provide some greater clarity for you in the priorities for coming weeks and months.

CBB has a number of consultants with experience in using different business modelling tools as part of the strategy development process. We could help you with the whole strategic planning process, or just to workshop one or a few elements like this.

If you’d like any assistance with reviewing or developing elements of your strategic plan, please contact 1300 763 505 for an obligation free consultation with one of our Business Consultants.

 

Andrew Ellis
Business Consultant
Email: aellis@cbb.com.au
Phone: 1300 763 505

 


Data visualisation will change your life

Data visualisation will change your life and there’s a very good chance that it already has. Start-ups will talk about “hockey stick growth” and you’ve no doubt heard the term “flattening the curve”. Both terms refer to data visualisation and quite simply the insights that are drawn from being able to see past a mass of numbers, as data is presented in graphs and infographics. This cuts through the noise often created by large sets of data and allows people to see trends and outliers which in turn brings a focus to the key indicators that drive change.

Before we move to the impact that data visualisation can have, it’s worth defining data visualisation.

Data visualisation is the graphical representation of information and data ¹

This sounds simple enough but in a world of endless facts, figures and information, data visualisation provides a number of benefits.

Here are three key benefits of data visualisation:

  1. Appeals to visual people

Everybody has their own unique learning style and medium for which they prefer to take in information. A large proportion of the population prefer visual images, particularly over large sets of numbers. Data visualisation – for all the obvious reasons – appeals to this portion of the population.

  1. A picture tells a thousand words

Well visualised data can portray vast amounts of information in just one graphic, making it much more efficient for time poor readers (such as Boards) to access and interpret information.

  1. Quicker insights

Insights can be gained much much quicker, particularly in comparison to a list of numbers. Trends, disproportionate data sets and outliers are all significantly easier to identify when visualised., The impact of graphs and infographics is immediate, and – when done well – easy to understand and interpret. This can allow for greater transparency amongst various stakeholders which can in turn lead to quicker and more accurate decision making.

Data visualisation operates at different levels. In its simplest form, it highlights anomalies (such as year on year differences or the difference between budgets and actuals). At this level, it may not explain the drivers or reasons behind the trends identified, rather it highlights areas for further investigation and analysis. For more sophisticated reporting, data visualisation may represent more complex information – perhaps in relation to your KPIs or other indicators – that helps to explain the context beneath the headline results.

This may sound great in theory and something that only applies to particular organisations – or big data – but it very much applies to the not for profit sector. We are currently working with a number of not for profits to present their financial data in more visual formats.

The visualisation and presentation of financial data and information can highlight and present the following:

    1. Trends
    • Revenue trends
    • Expense trends
    • Cash flow trends
    • Monthly trends
    • Annual trends
    1. Proportions
    • Major revenue items
    • Major expense items
    • Major balance sheet items
    1. Comparisons
    • Actuals vs budget
    • This year vs last year
    1. Targets
    • Year to date actuals vs annual target

Of course knowing what data to visualise and how best to visualise it is a skill in itself. With the right data visualised in the most appropriate and meaningful way, organisations’ boards and leadership are supported in interpreting data so that they can make well informed decisions and take appropriate actions.

The following is a simple example of data visualisation:

  • Not for profit XYZ set an annual target to spend $6,000 this financial year on a particular social objective.
  • As shown in the chart below, after six months into the year, the organisation is well behind its target. and will need to take more action and spend more money in the remaining six months if they are to meet their annual objective.
  • The chart below very clearly and concisely presents this information, evidenced by the linear target which is in line with a linear objective (in this instance). This allows those reviewing the chart (ie the CEO and board) to quickly identify this as an area for further discussion and investigation and discuss required next steps.

In summary when the right data is visualised in the most appropriate way, it can either provide focus on areas for further discussion – or provide meaningful insights in its own right. This in turn can inform decisions and actions that support an organisation towards achieving their objectives.

If you’d like any assistance with visualising your financial data, please call 1300 763 505 for an initial obligation free consultation with Dimitri.

 

 

 

Dimitri Matsouliadis
Business Consultant
Email: dmatsouliadis@cbb.com.au
Phone: 1300 763 505

 

 

¹ https://www.tableau.com/learn/articles/data-visualization


COVID 19 – NDIS Price Guide update and provider support

Posted on 28 April 2020

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.

Price increases

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

Cancellation policy

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.

Support Coordination

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.

What worries you most and what support would make a real difference to your NDIS service? Please email your comments or questions to:

Dr Ellen Schuler 
Business Consultant
Email: eschuler@cbb.com.au
Phone: 1300 763 505