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

 


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


COVID-19 Impact on NDIS audits

Posted on 1 April 2020

In this time of uncertainty, many providers have been concerned about how COVID-19 will affect the rollout of planned NDIS audits.NDIS audits

The NDIS Commission has recognised that both providers and auditing bodies may experience significant disruption, which will impact on audit engagement activities.

The NDIS Commission recently issued advice recognising that the priority for infection management and continuity of support during the COVID-19 pandemic is likely to affect ‘the readiness and capacity of some providers to engage with any registration renewal audits, particularly on-site activities.’

The NDIS Commission has advised auditing bodies to:

  • review their audit practices to ensure these are provided in a way that minimises the risk of exposure to COVID-19 for participants, providers and auditors.
  • where audits are scheduled to occur, engage with providers to confirm their availability to continue where practicable to do so.
  • Where going ahead in agreement with the provider, establishing clear arrangements for conducting a Stage 2 audit activities in a way that minimises risk.
  • delay or reschedule audit dates where providers are not in a position to proceed with these. Decisions to suspend or delay completion of a Stage 2 audit beyond three months (as provided in the NDIS Auditing Scheme Guidelines), should be recorded in audit reports.

The Commission plans to provide targeted advice to registered NDIS providers, including arrangements for varying conditions of registration, where necessary, to allow an extended period of time to complete the registration process, including audits.

The latest COVID-19 restrictions involving social distancing will mean that remote audits are the only practical method for conducting Stage 2 audits until these restrictions are lifted. Auditing bodies need to meet certain accreditation requirements to be able to conduct remote audits. 

 

So, what will remote audits look like in practice?

Remote auditing presents some challenges and audit teams and providers alike will no doubt learn new approaches/methods to enhance the audit processes and outcomes over time. It is a requirement that audit teams provide an audit plan to the NDIS provider for the Stage 2 onsite audit, and this equally applies where a Stage 2 audit is conducted remotely.

Audit teams need to follow the same processes during the conduct of a remote audit, which would include:

  • having an opening and closing meeting with the NDIS provider
  • being respectful to participants and their family, and minimising disruption to service delivery
  • collecting a range of audit evidence demonstrating implementation of procedures and practices, which includes participant and staff files, registers, minutes, brochures, records etc. through ‘triangulation’ of evidence
  • specifying how long the audit will take (audit duration)
  • interviewing required ‘samples’ of participants (which are randomly selected by the audit team)
  • interviewing a representative number of workers
  • multisite sampling.

The Audit Plan should identify clearly how and when the interviews will be facilitated, and how information/records will be accessed. This could be through a variety of technologies:

  • videoconferencing (Skype, Facetime, GoTo, Zoom)
  • telephone meetings
  • web based meetings
  • electronic file transfer
  • systems access (cloud based CRM databases)
  • screen sharing.

It is a good idea to have a trial run of the technology before the day of the audit to make sure both the Audit Team and provider can access the technology easily – the same would apply to participants if they are being interviewed via videoconferencing. In the case of CRM databases, the audit team will need access to relevant information which would need to be time-limited.

If the provider has certain records only in hard copy, then the provider will need to think through how these are best made available to the audit team. This could include scanning relevant documentation. Noting this can be time-consuming and may impact on time otherwise spent managing or providing direct service delivery to participants, it may be reasonable to seek advice from the NDIS Commission and your audit body about the practicalities of a remote audit in those cases.

Observation is usually a type of evidence obtained during an onsite audit, and there may be ways that the provider can ‘walk’ the audit team through their premises via Skype, Facetime etc.

Confidentiality is an area that needs to be managed carefully – both for workers and participants. This should be planned appropriately to ensure that the worker or participant is able to speak freely without the presence of others (if that is their choice) so that feedback provided to audit teams remains confidential.

The NDIS Code of Conduct, Continuity of Support and Safe Environments are mandatory compliance requirements for NDIS providers, and in the current COVID-19 environment, it would be an expectation that NDIS providers have evidence to demonstrate how they are providing a safe environment, managing infection control, risks and business continuity. We encourage providers to access the useful resources available from the NDIS Commission’s website as in addition to essential practice, these are great sources of evidence for the audit, in particular:

These are certainly challenging times for us all. We continue to conduct ‘preparatory’ audits for providers, albeit in a remote environment, which are a great way of identifying any potential areas of non-conformance, plus to show how the remote audit will work in practice.

If you would like to discuss how you can best prepare for a remote audit, or to chat about how your Continuity of Support policy and procedure address pandemic requirements, please feel free to contact Engels Floyd, info@engelsfloyd.com or 0478 616 207.

Sharon Floyd

 

Sharon Floyd
Director of Engels Floyd and guest blogger for CBB.
Engels Floyd have trained all the NDIS Quality Auditors and have spoken at CBB’s Community ExecNets.

 

 


First NDIS grant opportunity in 2020

Posted on 26 March 2020

 

Over the last months CBB has been supporting organisations across South Australia to learn more about the Information, Linkage and Capacity Building (ILC) grant opportunities through image of grants written on paperwebinars and workshops. In our ILC Ready one on one support program we have assisted 20 organisations to identify needs in their communities, create a vision for change, and design and plan a project for social impact.

On the 10 March the first ILC grant round for 2020 opened, inviting organisations to apply for Individual Capacity Building grants (ICB round 2). A total of $85 million is available for projects for a period of up to two years.

 

What do ICB grants achieve? 

Projects need to ensure that people with disability have the skills and confidence to participate and contribute to the community and protect their rights through an increase in

  • Skills and capacity
  • Motivation, confidence and empowerment to act
  • Participation and contribution to community.

Grants must be developed and delivered in collaboration with people with disability and need to be for the primary and direct benefit for people with disability.

 

Who can apply for an ICB grant?

  • Disabled People’s Organisations
  • Family Organisations
  • Priority Cohort Led Organisation

As in round 1, the ICB grants are designed to support the work of Disabled People’s Organisations who are run by and for people with disabilities and strongly align with the social model of disability. The majority of paid staff (or volunteers in the absence of paid staff) need to be people with disability. Alternatively the Board needs to have more than 50% members living with a disability. To make applications easier, the NDIA has simplified the assessment criteria and thankfully published an easy read version of the grant opportunity guidelines. Grant Connect however lists 28 grant documents relating to this grant under GO3770, and finding the easy information poses a challenge.

The grant is also open for applications from Family Organisations. Yet, the definition of Family Organisation has changed from previous grants. Family Organisations are now defined as organisations that support and enhance the health, wellbeing, capacity and resilience of families and carers, and design and deliver supports or services for families and carers. Organisations supporting families (and not people with disabilities) were excluded from previous grant rounds and are now strongly encouraged to apply. Family organisations however will require over 50% of staff members that are carers and more than 50% of board members to be carers. This may pose a barrier for many organisations supporting carers and families. We believe that this is to ensure that the program is available to smaller disability organisations that are not NDIS providers or where NDIS provision is only a small part of their business. However the current funding environment means that there are few organisations who will fall into this category.

As in the previous ICB grants Priority Cohort Led Organisation are also invited to apply. For Aboriginal and/or Torrens Strait Islander communities, Culturally and Linguistically Diverse and LGBTIQA+ communities, the selection criteria have tightened.  More than 50% of staff members and 50% of board members need to identify as part of the priority cohort.

New to the list of Priority Cohort Led Organisations are organisations supporting children and young people (0-24 years) and people experiencing homelessness or at risk of homelessness. For both, the organisation only needs to demonstrate a history and a long-term commitment to supporting children or homeless people.

 

What are the NDIA’s funding priorities?

The last ICB round was highly competitive, with almost 500 applications seeking over $210 million. Only one in five applications were successful – a total of 105 grant recipients across the country.

The NDIA’s funding priorities for this grant round are regions, cohorts and organisations not funded in the first ICB round. Given children or homeless people with disability were not specifically invited in the previous rounds, we anticipate to see the approval of eligible projects supporting these communities.

The NDIA also strongly invites organisation to re-apply who had funding in the 12 month interim DPFO funding round but were not successful in the ICB round 1. The funded list of activities now includes activities that scale and extend the scope and/or coverage of previously funded ICB activities which demonstrated effective outcomes. Continuity of support is crucial for people with disability and organisations and we sincerely hope that the change in eligibility criteria does not prohibit these organisations from applying in this grant round.

 

How much funding is available?

Eligible organisations can apply for small grants starting from $10, 000 to $25,000 per year or larger grants in between $100,000 and $500,000 per year. Organisations should take notice that the total application budget should not be more than 125% of the average annual organisational budget for the past three years. This will limit the scope of work for many organisations however, it does give grassroots movements the chance to apply for some funding. Applicants for small grants only need to address two selection criteria. Organisations applying for the larger grant need to submit a more comprehensive application addressing three selection criteria.

Disabled People’s Organisations and Family Organisations that are applying for an ICB grant can in addition also apply for funds for Organisational Capacity Building, up to $50,000 per year. This will allow many to grow their organisation capacity e.g. though upskilling their staff, volunteers or board members. Applications for Organisation Capacity Building funds alone are not permitted.

 

What will increase your chances for funding?

We recommend you should start with the grant guidelines and carefully analyse the eligibility criteria. Also, critically assess if the NDIA is the appropriate funding body or should your program be funded by a different agency or department such as health or education? There is also a helpful summary of Question and Answers available on Grant Connect. Ensure you explain the specific need for people with disability in your community and that you have evidence for this need. Demonstrate how the project will create the outcomes that align with the grant objectives and that your planned activities align with grant guidelines and are for and with people with disability. Do not copy what is already done elsewhere. The NDIA is looking for great innovative ideas that your organisation will be able to deliver. It is always better to start small and to grow slow but steady. Plans that are too ambitious could be considered high risk or not delivering value for money and could miss out on funding. If entering into partnerships, it is important to explain how these partnerships will enhance the outcome of the project and who will be doing what.

 

What if you are not eligible to apply?

We expect to see two more ILC grant rounds this year.

The Economic & Community Participation grant round 2 is expected to open in April 2020. The grant will offer three application streams: Economic Participation, Social and Community Participation and Activating Community Inclusion. Projects should commence in August 2020.

The Mainstream Capacity Building grant round 2 is anticipated to open in May 2020. The program aims at enabling service systems to be more accessible and inclusive and will start from September 2020. Given the first round focused on Health Services we expect a different priority focus this year.

There are no future rounds planned for the National Information Program.

CBB’s ILC Ready program was kindly funded by the South Australia’s Department of Human Services through its NDIA Community Inclusion and Capacity Development Grant.

Please visit our website for more information on ILC and watch our free webinars.

If you have questions or require support or if you would like to discuss ideas and priorities for your Organisational Capacity Building application please contact CBB’s Business Consultant Dr Ellen Schuler.

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

 

 


New ILC grant round open – Individual Capacity Building

Posted on 6 March 2020

 

NDIA’s ILC Investment Strategy has funding secured for Information, Linkage and Capacity Building (ILC) projects until 2022 and it’s time for another round of ILC grants.

The Individual Capacity Building (ICB) grant (round two) is expected to open for applications in just two weeks. Applications will close on the 22 April 2020.

Total funding available:  $85 million (GST excl.)
Project commencement: August/ September 2020
Project period: up to two years

Who can apply?

  • Disabled Peoples Organisations (DPO)
  • Family Organisations (FO)
  • Priority Cohort Led (PCL) organisations (Aboriginal & Torrens Strait Islander, Culturally and linguistically diverse groups, LGBTIQA+ communities)

The definition of the eligible organisation types will slightly vary from the first grant round. The NDIA has promised simplified grant opportunity guidelines and a simplified application form in plain English. The application guideline will inform organisations about the structure and questions they need to prepare for the grant applications.
Funding Priorities are cohorts and organisations in regions that were not funded in ICB round one. Also, organisations that were successful in the 12 month interim Disabled People and Families Organisations funding round and not successful in ICB round one will be prioritised.

Funding amounts per year:

  • Small grants $10 -25,000
  • Large grants $100 – 500,000

Applicants for small grants need to address two selection criteria in their application. Larger grants require a more comprehensive project proposal and answer to three selection criteria.

Disabled Peoples Organisations and Family Organisations applying for ICB can also apply for additional funds for Organisational Capacity Building, up to $50,000 per year.

Tips for successful grant application:

  • Do not duplicate already existing resources.
  • Check if the NDIA is the appropriate funding body or if the program should be funded from another source.
  • Ensure there is evidence of need and claims are substantiated.
  • Ensure people with disability are involved in the project.
  • Demonstrate how the projects aligns with the social model of disability.
  • Start small and create something that can grow bigger and can be copied elsewhere.
  • Always read the grant guidelines.

Favourable are:

  • Great innovative ideas addressing a need in your community.
  • Project and outcomes that are sustainable in the long term.
  • Collaborative partnerships that are leveraging of each other.
  • New and emerging cohort.

To develop a strong application, applicants are required to address the following questions:

  • What makes a strong application?
  • Who will you target?
  • What will you do?
  • Why is there a need for the activity?
  • Where will you deliver the activity?
  • How will the activity be developed, delivered and evaluated?
  • When will the project be delivered?

The last ICB round was a highly competitive grant round, with almost 500 applicants seeking over $210 million. Approximately one in five applications were success (to total of 105) with a funding amount of $105.875 million. Most applications were submitted in NSW (143) and Victoria (116). In SA 7 out of 38 applications received funding.

We expect to see further ILC grant rounds this year:

  • The second Economic & Community Participation grant round will offer three application streams: Economic Participation, Social and Community Participation and Activating Community Inclusion.
  • The Mainstream Capacity Building grant round two aims at enabling service systems to be more accessible and inclusive. Given the first round focused on Health Services we expect a different priority focus this year. At this stage there are no future rounds planned for the National Information Program.

For more information on ILC grants please visit ILC Ready and watch CBB’s free webinars. For questions or assistance or if you would like to discuss your Organisational Capacity Building application please contact:

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

 

 


NDIS Registration Rules – what’s new for providers?

The rules are changing sign

What do the changed requirements to NDIS Registration Rules mean for providers undergoing audits?

Changes to the National Disability Insurance Scheme (Provider Registration and Practice Standards) Rules 2018 (the Rules) came into effect from 1 January 2020.

The changes aim to reduce the regulatory burden on registered providers by providing:

  • a verification audit pathway for all providers delivering low risk supports regardless of legal entity, replacing certification audit pathways for bodies corporate. This effectively means a more streamlined online process for bodies corporate (through the Commission’s portal), in place of onsite audits, and;
  • a mid-term audit within 18 months of registration approval in place of yearly surveillance audits. This ultimately reduces the overall amount of auditing from two surveillances in each certification/registration cycle to one.

What will verification audits look like for body corporates?

The updated NDIS (Approved Quality Auditors Scheme) Guidelines 2018 state that auditors need to refer to the ‘current document published by the Commission which outlines the evidence that auditors must receive to assess conformity with the verification module.’ This is the NDIS Practice Standards: Verification Module – Required documentation document which is available at: NDIS Commission Verification Module.

There is a new section in this document which outlines requirements for body corporates undertaking verification. This section reads:

Bodies Corporate (excluding government providers) seeking registration for verification only registration groups are required to demonstrate the following:

Human Resource Management

  • Pre-employment checks in accordance with workers screening requirements.
  • Qualifications and/ or experience
    • In order to meet this requirement, the provider must provide evidence that one staff member who will deliver supports has met the requirements for each profession(s) the provider intends to deliver under each registration group(s). (See Requirements by Profession within the verification module)

Where a requirement includes the words ‘or equivalent’, this means an institute of a similar status to that which is referred. Factors to be taken into consideration include the relevant industries’ acknowledgement of the institute as a body, which maintains the reputation and quality of the profession, as well as the experience and qualifications required for professionals in the industry to gain membership of the institute.

Where a provider has multiple staff working with the same profession it is the ongoing responsibility of the provider to ensure staff achieve the same standard.

  • Provide the certificate of completion of the NDIS worker orientation program (mandatory training) for each staff member 
  • Personal accident insurance or worker’s compensation insurance. A certificate of currency for current insurance that meets the minimum level of cover commensurate to the scope of the provider. Providers should seek professional advice as to the type and amount of insurance that is necessary.

Incident Management

  • Describe how the provider manages incidents, or provide a copy of your incident management process, as relevant to the supports delivered for this registration group, including any relevant material provided to participants. 

The process must meet the requirements of the National Disability Insurance Scheme (Incident Management and Reportable Incidents) Rules 2018. The process should be relevant (proportionate) to the size and scale of the provider and to the scope and complexity of the supports being delivered. 

Complaints Management

  • Describe how the provider manages complaints, or provide a copy of your complaints process, as relevant to the supports delivered for this registration group, including any relevant material provided to participants. 

The process must meet the requirements of the National Disability Insurance Scheme (Complaints) Rules 2018 and follows principles of fairness and natural justice. The process should be relevant (proportionate) to the size and scale of the provider and to the scope and complexity of the supports being delivered.  

Risk Management

  • Describe or provide a copy of the providers work health and safety policies and procedures relevant to the supports delivered for this registration group, including any relevant material provided to NDIS participants. 

The policies and procedures should be relevant (proportionate) to the size and scale of the provider and to the scope and complexity of the supports being delivered. 

  • Public liability insurance. A certificate of currency for current insurance that meets the minimum level of cover commensurate to the scope of the provider. Providers should seek professional advice as to the type and amount of insurance that is necessary. 
  • Professional indemnity insurance. A certificate of currency for current insurance that meets the minimum level of cover commensurate to the scope of the provider. Providers should seek professional advice as to the type and amount of insurance that is necessary.[1]

There is still a proportional approach to processes, policies and procedures for verification, which means that body corporates with a larger workforce and large numbers of NDIS participants would be expected to have systems addressing risk management, complaints management and incident management which are commensurate with the size, scale and scope of those providers.

 

What is the impact of mid-term audits for registered providers?

The mid-term (18 month) audit has replaced the yearly ‘surveillance’ audit for registered providers. It appears that the mid-term audit will now include assessment of:

  • Division 3 of the Core Module – Governance and Operational Management as a mandatory requirement;
  • Any Standard which was identified in the previous audit as needing to implement a Corrective Action Plan; and
  • Any Standard specified by the NDIS Commission.

 

What does this mean for registered providers that have already had their first ‘surveillance’ monitoring audit in NSW and SA?

 

The updated NDIS (Approved Quality Auditor) Guidelines has a new clause to address these situations, and basically it is good news for this category of providers. Another mid-term audit is not required, if the original surveillance monitoring audit:

  • Was carried out by an Approved Quality Auditor (certification body) using certification no later than 18 months after the beginning of the provider’s registration period;
  • Assessed the Standards relating to Governance and Operational Management;
  • Assessed any specific Standards which were previously identified in the initial certification as requiring the provider to implement a corrective action plan.

It is likely in many cases that the original surveillance monitoring audit would have addressed these requirements, which means that these providers are not due for another audit until the time of the three yearly re-certification. Note: Engels Floyd has assisted a number of providers address corrective actions, so if this is an area of concern for you, please feel free to contact them.

We do encourage providers to contact their certification body to review their quote for the certification cycle, as the original quote would have been based on yearly surveillance audits.

For questions about the NDIS registration rules, comment or compliance support contact Engels Floyd, info@engelsfloyd.com or 0478 616 207.

 

Posted on 27 February 2020

[1] Reproduced from NDIS Practice Standards Verification Module – required documentation, January 2020 (pages 2 to 4)

Sharon Floyd

 

Sharon Floyd
Director of Engels Floyd and guest blogger for CBB.
Engels Floyd have trained all the NDIS Quality Auditors and have spoken at CBB’s Community ExecNets.

 

 


NDIS Price Guide 2020

How many times did the NDIA update the NDIS Price Guide and Support Catalogue in 2019?

  1. 2 times
  2. 4 times
  3. 6 times
  4. We’ve lost count

The NDIA introduced a long list of changes last year. There are new line items, substantial price increases and new rules regarding billable hours. Listing all changes would be impossible however if you answered A, B or C to the question above you could have overlooked some. As a result, your organisation may miss out on critical funding or potentially charge incorrectly. As a provider, you need to make sure you know and understand the Price Guide. Your organisation needs to comply with Australian consumer law and the Competition & Consumer Act, as well as treat your customers fairly and charge in accordance with the rules.

An updated list of the legal requirements of NDIS providers is available on the NDIS website here. This includes declaring your prices to participants before delivering your service and providing receipts to participants.

Here are some important NDIS Price Guide and Support Catalogue rules: Continue reading…


Higher NDIS prices for providers

In July 2019, the NDIA introduced the Temporary Transformation Payment (TTP) for providers of Assistance with Daily Living and Community Participation. The payment is only available to registered providers and is conditional to a set of obligations. The increase was welcomed by providers who continue to struggle financially with the administrative burden of the NDIS and the introduction of the Quality and Safeguard regulations and the associated compliance and audit requirements.

In a national survey among 381 disability service providers, 76% of organisations stated that they are worried that they won’t be able to provide NDIS services at current prices (NDS 2019). The TTP payment is set at 7.5% above the base price, however given the previous Temporary Support for Overheads of 2.5% was removed, it is merely a 5% incentive and this will reduce by 1.5% each year.

Continue reading…


NDIS update (from October 2019)

The NDIA announced a long list of changes and updates late last month. Here is an overview in case you have missed these:

New Price Guide and Support Catalogue valid from 1 October 2019


Disability-related health supports

The new NDIS Price Guide (version 1.2) introduces disability-related health supports as agreed by the COAG Disability Reform Council meeting in June. The NDIS will now fund health supports where the supports are a regular part of the participant’s daily life and result from the participant’s disability. Funded disability-related health supports include dysphagia supports, respiratory supports, nutrition supports, diabetic management supports, continence supports, wound and pressure care supports, podiatry and foot care supports and epilepsy supports. More information about these supports can be found in the Price Guide (page 20).

Continue reading…


Economic and Community Participation (ECP) Grant 2019-2020 and Mainstream Capacity Building (MCB) Grant 2019-2020

The NDIA has opened up two ILC grant programs for economic participation and capacity building.

Economic and Community Participation (ECP) grant program

The Economic and Community Participation (ECP) grant program offers two streams to create opportunities for people with disability to contribute and participate in community life. People with disability experience higher unemployment rates, longer duration of unemployment and a lower level of income (Australian Institute of Health and Welfare 2019).  The Economic Participation stream is targeted at employers to create new pathways to employment and increase their ability to employ people with disability and build inclusive workplaces. The grant program also offers funding for programs that foster entrepreneurship to create opportunities of successful self-employment and innovative approaches that lead to increased employment.

The Social and Community Participation stream aims to create opportunities for people with disability to participate in the same community activities as everyone else, with a focus on arts, culture, sport and recreation. Eligible activities include pilots for new pathways to leadership and civic participation, improved inclusive approaches of local communities, inclusive playgroups and/or staff and volunteer development to better work alongside people with disability.

Application that focus on activities for ILC Priority Cohort Groups (Aboriginal and Torrens Strait Islander communities, CALD communities, LGBTIQA+ cohort and communities living in rural and remote areas) are particularly encouraged to apply. The ECP grant program offers a total of $30 million over three years with a minimum funding amount of $100,000 per year. More information is available here.

Mainstream Capacity Building (MCB) grant program

The Mainstream Capacity Building (MCB) grant program funds activities that build the capacity of health organisation and services to ensure people with disability can use and benefit from the same mainstream health services as everyone else. Many people with disability experience difficulties in accessing mainstream health services. One in six people with disability have experienced discrimination by health staff (Australian Institute of Health and Welfare 2017).

The grant program is designed to help remove barriers within the heath system, including better training for health care staff about disability and inclusion, better collaboration among different sectors and improved service culture and attitudes. The funding priorities vary depending on the jurisdiction where the ILC program will be delivered. Grants start at $100,000 per year or up to $300,000 for three years. The maximum funding amount that applicants can apply for is $750,000 per year (or 2.25 million over three years). Nationally, a total of $32 million will be awarded through this program.

More information about the Mainstream Capacity Building (MCB) Grant Program 2019-2020 is available here.

Specific guidelines for each program are available on Community Grants Hub and Grant Connect. Applications are open until 21 October 2019.

Posted on September 18, 2019 

 

For questions or support please contact:


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