Early in 2018, at one of the initial consultations for the now infamous pricing review, providers who were in attendance were split up into smaller focus groups. Each of us was given a few minutes to introduce points that we wanted to be taken into consideration. As we worked around the circle we got to one fellow who told us that he and his partner were not yet engaged with the NDIS and ‘after hearing this I’m wondering why anyone would ever want to.’
That moment has stuck with me through this year as we have once again navigated our way through the twists and turns that are thrown at us as businesses offering services within the NDIS. Yet here we are still are! Businesses trying to navigate the NDIS are among the most resilient of all.
So to welcome in another year – I took a look back through our closed Facebook page – the Disability Community of Practice Australia where so many of us find the support that we need to keep going. Thank you to one and all who contribute to this page, I didn’t realise how busy it is until I spent a few hours going over a year’s worth of posts.
2018 in review!
Confusion reigned with Early Childhood Intervention
My goodness, so many posts about whether people funded against the Early Intervention line could continue to self or plan manage. It seems that information about this is not always consistent from the ECEI Planning partners and then was further confused for people in South Australia and NSW with the introduction of the NDIS Commission and new provider registration requirements.
The bottom line is that families who are funded against the Early Intervention item can absolutely self or plan manage their funds as long as they meet the standard criteria that is applied to everyone.
If anyone is told anything different from a representative of the NDIA – please pass it along so that we can make sure that it is cleared up.
The New Price guide brings changes to travel and random changes to plans and service bookings
The 2018 – 2019 price guide brought a few changes – the highest impact went to the changes made to the way travel could be billed. The rules for support workers and therapists were brought into line with a 20 minute limit of claimable time between clients with exceptions for those living in areas deemed to be MM4 or MM5 regions where 45 minutes can be claimed.
Confusion continues about whether this can be charged ‘each way’ if only a single visit is being completed and there is no answer for those people seeking home or community based services who live far beyond the 20 or 45 minute radius and have no Provider options any closer. Or perhaps they want to exercise their right to choice and control and use the support that’s best for them rather than who is the closest.
While there is a narrative persisting implying that providers are being somewhat greedy requiring reimbursement for travel the reality is that for businesses to maintain viability they simply cannot continue absorb the loss of time spent in the car on an ongoing basis.
Let’s not forget the changes that were made by the Agency to plans to account for price increases (that didn’t always make sense) and the automatic service booking changes which created more admin headaches for everyone.
We win on Swallowing but the Health – NDIS title fight continues
I could hardly believe that my initial posts about the campaign to push the need for NDIS to continue to fund swallowing assessment and support went as far back as February! This was my first experience with a highly structured, organised and targeted campaign and it reinforced my view that ADVOCACY GROUPS NEED TO BE CONTINUOUSLY FUNDED!
The Council for Intellectual Disability know what they are doing with this stuff – and I would highly recommend that anyone supporting people with ID join up which will help them maintain their core business with their funding being on shaky ground. Huge shout out to Jim Simpson and Rochelle Porteous who were the rock stars behind the effort. Support crew included Dr Bronwyn Hemsley from UTS and Pip Cullen (OT and business owner) who connected us with families who played a pivotal role in raising the issue with the public. We were also well supported by the Sydney Morning Herald and The Guardian. Thanks to everyone who signed the petition.
The NDIS / Health issue was also progressed through an AAT decision regarding support for a person with insulin dependent diabetes. We are creeping slowly towards a place where there is a sense of agreement with COAG and the states and we can only hope that this speeds up as more people find themselves stuck in the middle with Planners and LACs making guesses on what is OK to be funded under the Scheme.
The ECEI Partners change in NSW
The initial transitional arrangements for ECEI finished up in June 2018 and the new ECEI partners for NSW were eventually announced. It seems it took at least 2 months (if not a little longer) for the switch over to be completed and reports of children waiting extended periods for assessments and plans have been emerging. The former partners are now engaged in their own reorganisation to be able to continue as viable businesses within the Scheme.
The 3 month Plan
Lots and lots of posts in our past years feed about people receiving 3 month plans. Whether this was to do with the new ASD eligibility criteria, the group of kids moving out of early childhood or some other mysterious reason it played havoc with administrative processes for businesses.
The early review
Many businesses were caught out with plan reviews being called early with limited time for review reports to be supplied in time and unspent funds in old plans. This must affect the NDIA data on unspent funds and it brings forward the administrative burden to business including new service agreements and service bookings and completing any un-invoiced claims through the old plan. It does make it more challenging for businesses to try and predict the ebb and flow of their workload which can domino to planning staff leave etc. I think we’re at ‘assume a plan review could happen within three months of the end date’ territory.
AT continued to be a constant bugbear
My goodness so many posts about issues with AT – the process, the lengthy waiting time for approval, the times that a piece of equipment arrived sans an essential part because someone along the convoluted approval route decided it constituted a ‘restrictive practice’ and neglected to contact the person prescribing the equipment for more information.
A new system is being rolled out and it remains to be seen whether this will streamline the process. Personally I have just been asked for quotes for a communication device for a 2 year old at the beginning of a new plan because I flagged it as a possibility over the next year. I have completed no trials and I probably wouldn’t have for at least 6 months. I haven’t resolved what I’m going to do about this one yet!
I think no one was delighted with this decision, and while it seems to be true that calls are answered more quickly the jury is still out as to whether information provided is any more accurate.
The Independent Pricing Review report is published
Well wasn’t this a smack in the face for the allied health sector! I attended one of the consulting sessions and have to admit I did not see this coming. A recommendation for the introduction of tiered pricing based on complexity with a 40% cut from the current rate for the less complex group. There was also a push to fund more Allied Health Assistants rather than a qualified therapist.
There was no mention about how LACs and Planners would be trained to be able to identify complexity and according to the NDIA response they would be implementing the changes in just a few months. Good bye budgets, business plans and forecasts for businesses. The comparison data used to justify the cuts was based on populations which bear little to no resemblance to people who are eligible for the NDIS.
Clearly the NDIA are looking to reduce the spend on this item.
There is frequently online discussion about the therapy rate being high at almost $180 / hour. Personally this is what I pay my own sports physio privately and seems to be the market rate.
Following considerable backlash and thanks to a concerted and somewhat organised team effort via the professional associations the implementation of this recommendation was delayed and is undergoing a further ‘review’ over the next month with a decision to be announced in March 2019. This should give providers enough time to crunch their numbers and determine whether continuing with their NDIS registration is a viable option.
Onwards to 2019 for this one.
We all breathed a sigh of relief as this important announcement took place.
Payment and portal issues – the rocks in everyone’s shoes
Judging by the amount of posts from people trying to track down failed payments this continues to be an admin nightmare for businesses although at least successful uploads result in fast payment via the portal which is great.
Working with some Plan Managers is presenting businesses with some challenges too and we are awaiting the development of some consistent guidelines from the Agency.
So many reports – with almost the same recommendations
The Centre for Social Impact released their report on Market Stewardship with interesting evidence for how the Agency could support the market to develop. Hmmm.
The Joint Standing Committee report on the Market Readiness contained 29 recommendations.
The NSW Parliamentary Inquiry into the Implementation of the NDIS provided a further 23 recommendations. The NSW Government response is here.
To my mind what still remains absent in all reports and discussions is the language and content relating not just to the vague term of ‘market’ but to the specific challenges and needs of ‘business;’ which the reality for every single provider.
The NSW Ombudsman’s report on Reviewable deaths revealed ongoing issues with managing swallowing and mealtimes resulting in illness and deaths by choking and respiratory complications.
Adam Bowes nails it
Thanks to the fabulous video by performer Adam Bowes, all of our frustrations made their way to the mainstream.
The Introduction of the NDIS Commission and the price of being an NDIS Provider
Finally a national approach to Quality and Safeguards which was welcomed by most was introduced in July 2018 along with a brand new set of Practice Standards against which every single business providing services within the NDIS must now comply.
The level of compliance required of each business is dependent on their business structure (sole trader / partnership vs company structure) and the complexity of the supports that they offer.
For those requiring the higher level of compliance – preparation and cost of the eventual audit required to demonstrate compliance is extensive and expensive.
There is now effectively a ‘registration fee’ to be a registered business within the NDIS.
In another reminder that the government agencies are not in the mindset of businesses, an email was circulated from the Commission that among other recommendations for registering businesses to register as a sole trader rather than a company. This carries legal, tax and administrative risks and I highly recommend that any changes to business structure are to at the very minimum discuss this with your accountant.
National guideline for ASD diagnosis released
Following an initial error in uploading then quickly deleting a document relating to a tightening of ASD eligibility for the NDIS, a new national diagnostic guideline for those people with ASD was released.
You’re all still standing!
Congratulations! You are all amazing. I’m quite sure that I have still not managed to capture everything, so many things have happened this year that have a direct impact to business and all out of your control.
I find it quite incredible that you all keep punching on. It’s true that we have lost some great people along the way and we will miss their talent and skill enormously. If we continue to support each other and use sensible evidence based business practice we will be able to continue our passionate work supporting people with disabilities and build successful businesses along the way.
Happy New Year to you all.