In February 2018, the NDIS Independent Pricing Review report was published alongside the NDIS response which stated clearly that they would be accepting and implementing all of the recommendations. Some of these recommendations seem to make positive steps towards stabilizing the market and acknowledging that workers with higher skill sets are paid at a slightly higher rate when supporting a person who has more complex support needs. Other recommendations stand to make radical changes to the shape of the market as well as adding further complications to the planning process.
Significant concerns have been raised about some of the recommendations, especially for the therapy changes (see the end of this summary). A secondary consultation is about to occur, if you would like to be a part of this consultation please email marketandsector@ndis.gov.au
Let’s break it down for both Providers and Participants.
Before we start we would like to make the point that it is essential that both the Participant and Provider elements of the NDIS reform to be catered for. Participants plans need to accurately reflect the supports that they need. Providers need to be able to run a stable business within the NDIS rules and regulations. The NDIS needs to be able to remain sustainable.
(Note: there are a number of recommendations that centre around process and administrative changes by the NDIA and these will not be discussed in this article.)
Changes to the way that travel can be charged to regional and rural areas (MM4 and MM5) areas.
You can see a map of these locations here.
Note that this definition is not necessarily the one that will be used by the NDIA. There is also a recommendation that the definition be finalized.
The current issue: these areas often have few providers located within them however are within travelling distance for providers who come from the nearest regional city or town. However the amount of travel time which could be claimed for therapists has been limited to $1000 per calendar year with the first 10km unable to be claimed for. Attendant care workers can charge to a maximum of 20 minutes of travel time between Participants and cannot charge for the first or last visit of the day.
For example: in the Hunter Valley the travel time to the outskirts of the region from the nearest cities of Maitland and Newcastle is around 3 hours which is where most providers are based. A therapist would use up the $1000 travel cap within a few visits and if this person was the first visit of the day for a support worker they could not claim for travel at all. An attendant carer could easily be traveling further than 20 minutes between visits in these areas.
For Participants there is risk that they will not be able to find a provider who will travel to them; they can in reality be left with funds to spend on support but no way to pay a provider to get to them.
The recommendation: the 20 minute travel cap be lifted to 45 minutes and the same rule be applied to therapists as well as attendant carers. It is our understanding that travel to the first and last visits of the day cannot be claimed. Travel beyond 45 minutes could not be claimed.
The implications: This gives some capacity to better cover costs of travel for providers. However to ensure that their time is able to be claimed providers may try and schedule their first and last visits of the day close to home base which will reduce person-centredness in terms of scheduling appointments. The 45 minute limit may still reduce the number of providers willing to travel to more extreme distances especially if they can’t group a few visits within the same geographical area.
Our concerns: other comments related to this recommendation: that the Agency actively reduce the incentives for Providers to travel (if there is a local option) which inherently reduces choice and control for Participants. Ideally a local market develops however there is no guarantee that services are of an appropriate quality or that they would be the provider of choice for the Participant.
Aligning pricing with complexity
The Issue: Currently there is a 5.5% higher rate which is applied to plans for individual support (attendant care) where the person is deemed to have more complex needs. However there is currently no clear definition of complexity and the higher rate does not allow for ongoing training and development needs of the worker.
Currently the complex rates are applied inconsistently across Plans. Providers are having to request reviews of plans to have the higher rate applied. Providers are paying staff at a higher rate than they are able to claim from the NDIS which is affecting viability. Providers do not have enough funds to train their staff. Participants with complex support needs may be finding it difficult to find providers to support them.
The new recommendation is for a tiered system, including a standard rate, a rate of 5.5% higher for mildly complex needs, 10% higher for very complex needs and a quotable item for extremely complex needs. This should provide better funding for providers to train and maintain skilled staff which in turn should improve access to the right skills and experience for Participants. There is also a recommendation to apply the complexity and fee loading to group programs held within a centre.
Our concerns: how complexity will be determined, what levels of evidence will be required to prove complexity, what skills will the people making the complexity decisions have, how will higher skill levels of workers be determined and proven, whose responsibility will it be to monitor worker skills and competencies, how will workers with necessary skills be able to be found.
There is also a reference to the ‘categorisation’ of Participants. Yuck.
Managing Behaviours of concern
The issue: extreme behaviours of concern (including Participants who are under justice system orders and previous offenders no longer subject to orders) are not specifically catered for within NDIS pricing. Providers working with people who are exhibiting extreme behaviours of concern have tended to be highly skilled and specialized with comprehensive knowledge of the legislative environment. There is a high degree of risk for workers and a degree of criminal liability if a person in a providers care reoffends. Currently the conflict of interest rule prevents a provider from offering Support Coordination as well as direct support. Support coordination is also not funded consistently at the Specialist level.
The recommendation: A consistent process be developed with a quoting system for providers to enable sufficient funded support for someone exhibiting extreme behaviours of concern. Allow providers to provide Support Coordination as well as direct support.
Implications: appropriately funded plans with an opportunity for provider input regarding holistic and perhaps even preventative support.
Our concerns: some businesses may end up prevented from engaging in this work if direct referrals become the norm; potential for extended waiting times as quotes are reviewed and negotiated; Who will complete the quote and does the person responsible have to sign off on it, will the quoting party be paid for it; how will specialist providers be identified?
Pricing for Respite services
Current issue: this service is funded at a standard daily rate without regard to penalty rates and intensity of support required for the person. Many services have either reduced their offer or closed altogether.
The recommendation: bring pricing in line with high intensity rates; add overnight allowances; add some capital allowances to enable growth of infrastructure
Implications: this should enable businesses greater capacity to provide ongoing respite across the weekends and evenings leading to a greater access for participants to this service and viability to businesses
Restructuring attendant care rates for group activities
The current situation: the price guide only caters for groups of up to 3 people; there is no surplus in the rate to account for additional paperwork and organizational time when managing a group as opposed to an individual;
Recommendation: a restructuring of the rates to include some additional funds for the extra responsibilities of a group; some guidance for charging for groups larger than 3.
Implications: guided practice with regard to billing for group activities; some additional funds to cover paperwork and preparation
Our concerns: will there be some structure around how big a group can be, what the staff / participant ratio's should be and the suitability for attendance at that group? There are potential risks for someone who needs more intensive support being placed within a large group with minimal available support.
Tiered pricing for therapy and psychology
The current issue: the report states that participants, providers and other stakeholders requested differentiated pricing for different services to better match market rates. Travel and cancellation issues exist for therapy support.
The recommendation: That participants be categorized on the basis of complexity and that the allocated therapy price be determined against that level. The lowest rate would mean a significant reduction on the current NDIS price. There is a slight increase for supporting someone with more complex needs. Psychology rates see a slight drop for a standard referral and an increase to support someone deemed to have a complex need. There is also a slight change to the ability to claim for cancellations.
Implications: the NDIS would reduce the spend on the therapy budget. Therapists would have to decide whether they accept referrals at the lower rates and if they do how they can deliver those services and ensure that their business is viable.
Our concerns: the quoted ‘ comparable schemes’ are not comparable to the NDIS. The current NDIS rate IS the market rate. Therapists may de-register from the NDIS market if their business is not viable with the new rates and only see people who are self managing their Plan. Participants will be further ‘categorized’ which will likely require more assessment and evidence and further label them. The skills and knowledge of the people determining complexity level may not be sufficient. Choice and access to providers may become very limited.
Introduce tiered pricing with therapy assistants
The current issue: the NDIS is trying to reduce the therapy budget by using less qualified workers to carry out the work. The report states that this could provide better value for money.
The recommendation: there be two levels of pricing for therapy assistants. One level for a support worker type role whereby the assistant is supporting the delivery of therapy services within a capacity building framework. Level Two would involve a qualified therapist completing a ‘treatment plan’ and a consultation would then be carried out by someone more qualified than a support worker but less qualified than a therapist.
The implications: people would receive their therapy support from someone other than a therapist at a lower cost to the Scheme. This could be used efficiently to make a therapy budget go a little further. It is possible however that if this is funded on a line of it's own it will be funded with a capped of number of hours just as therapy is now with no guarantee that this will mean additional opportunity for therapy input.
Our concerns: the challenges for someone less skilled and experienced to identify where changes need to be made to programming; possible lack of funding for supervision and review by a qualified therapist; finding professionals who can work in this role
So that kind of sums up the key points from the Independent Pricing Review.
To let the NDIS know that you want to be involved in the upcoming consultation email marketandsector@ndis.gov.au by Saturday 14th April 2018.