There Are Warning Signals That Suggest the Gap Between Demand and Supply Will Grow If Providers

NDIS Issues Register, March 2017

IssuePrices

Aligning prices with the actual cost of supply is by far the highest ranked issue impacting on providers’ capacity to supply services in 2017.[1] The National Disability Insurance Scheme (NDIS) needs to be delivered within a $22B budget, but it can’t be delivered at the current pricing. Inadequate pricing threatens to erode quality of service and generate market failure. No one wants this to happen.

There are warning signals that suggest the gap between demand and supply will grow if providers cease the provision of supports which they believe are under-priced. This is highlighted in the intermediate evaluation report on the NDIS, conducted by the National Institute of Labour Studies (NILS), and explored in greater depth in NDS’s 2016 State of the Sector report.

In response to providers’ concerns about inadequate prices for personal support and community participation during the trial, the 2014NDIA-NDS Joint PricingProject developed a Reasonable Cost Model (RCM). The NDIA lifted prices in July 2014 but these were less than thepriceswhich the model generated. The Agency did however accept National Disability Services’ (NDS) recommendations for a cancellation fee, costing of travel outside the hourly price and the introduction of an establishment fee.

In the subsequent two years, NDS negotiated full indexation and a delay in the transition to the ‘efficient price’, while assumptions underpinning the RCM were tested. This saw increases to the hourly price for one-to-one support by 3.9% in NSW, Victoria, Queensland and Tasmania and 1.9% in other states and territories.

Prices for most other supports increased by 2% in 2016/17. Increases for other supports to note include:

·  the monthly fee for financial intermediary services rose from $31.49 to $96.25,

·  supported independent living prices in all areas were increased by 3.9%, and

·  remote and very remote loadings increased slightly to 18% and 23%.

The announcement that prices were deregulated for participants who were self-managing their plans was welcomed and NDS continues to encourage the NDIA to extend this flexibility to other participants.

Unfortunately progress on other important pricing matters stalled. Despite interest from the National Disability Insurance Agency (NDIA) in participants with complex support needs, a higher price level has not been established. NDS has also made the case to introduce a weekend and public holiday rate for Short Term Accommodation.

Some providers would like to utilise therapy assistants for a portion of the total therapy budget to maximise value for money, but providers advise it isn’t viable - the current price ($40.92) is below the one-to-one support price ($42.79 in VIC/NSW/QLD/TAS & $43.58 in WA/SA/ACT/NT).

What NDS is seeking

·  Use of the assumptions underpinning the RCM to set the price for personal support and community participation

·  A mechanism established for setting group prices

·  Prices set that reflect the complexity of support (based on the skills required)

·  Prices for short term accommodation that reflect increased costs on weekends and public holidays

·  Review of the therapy assistant price

·  Prices that reflect jurisdictional and geographical difference

·  An improved cancellation policy

·  Extension of price deregulation

Status

·  The NDIA has released information about the review of NDIS prices for the next financial year. NDS summarised the review process and timeline and highlighted some concerns in a NDS News Update.

·  NDS launched the Industry Barometer which will provide benchmarking products to service providers that contribute data.

·  NDS continues to make the case for an increase in the higher intensity rate and the introduction of an additional higher rate for personal support and community participation and has compiled evidence from providers to use in ongoing negotiations.

·  The intermediate report on the evaluation of the NDIS, conducted by the National Institute of Labour Studies (NILS), highlights the risk that the gap between demand and supply will grow if providers cease the provision of supports which they believe are under-priced. This risk is explored in greater depth in NDS’s 2016 State of the Sector report.

·  The recent Australian National Audit Office (ANAO) report proposes that the NDIA role in price setting and price regulation is a conflict of interest and should be investigated by the Productivity Commission in its review of scheme costs – summarised in a NDS news update.

·  The 2016-17 NDIS price guide (effective 1 July) has been released - summarised in a NDS news update.

·  TheSpecialist Disability Accommodation Decision (SDA) Paperhas been released and outlines prices for capital costs in addition to the supported living prices outlined in theNDIS price guide - summarised in a NDS news update.

·  NDS has been invited to represent the sector on the steering committee of theNDIA Financial Benchmarking project.

·  Price deregulation was introduced to self-managing participants as of July 2016.

·  The NDIA continues to encourage a small number of participants in groups for community participation as reflected in the 1:2 and 1:3 staff participant ratios.

IssuePlanning

There is enormous pressure on the National Disability Insurance Scheme (NDIS) to accelerate the development, approval and activation of plans as the scheme expands. Expanding the NDIS from approximately 30,000 active participants in trial to approximately 460,000 at full scheme (typically with each subject to annual review) using the current approach to planning would over-stretch the National Disability Insurance Agency’s (NDIA) capacity.

Under pressure, the Agency is currently approving 450 plans per day, and in 2018-19 it will need to approve 850 plans and review 1,100 plans per day. Experience so far shows that the quality of planning by the NDIA remains inconsistent.
While the NDIA needs to determine eligibility and set individual budgets, life planning and coordination would be more appropriately done outside government. The local knowledge, practical experience and connections necessary for effective life planning and are mostly found in community-based organisations. NDS is pleased the NDIAs Partners in the Community program has outsourced some functions to non-government organisations.

The NDIA has implemented a range of strategies to improve the quality of planning including staff training, internal ‘virtual’ planning expertise task cards and reference packages. However providers continue to report the following concerns:

·  people are being contacted via telephone for initial information and later informed that this information was used to develop their plan,

·  participants’ are not given the opportunity to review plans before they are finalised

·  first plans are often missing essential support items such as supported independent living (SIL) and equipment,

·  providers lack of opportunity to provide feedback during a first plan/plan review often results in support gaps, and

·  the delay in funding for quotable items (in some cases taking months).

What NDS is seeking

·  State/territory governments to provide the NDIA with a list of supports that existing clients currently receive.

·  Adequate support coordination funding in plans, particularly for participants with complex needs.

·  Clear explanations of plan content to people with disability and their families to ensure they understand the types and level of support they can purchase.

·  Timely response and funding allocation for quotes and plan reviews.

·  An alert function to help providers track when a plan has been reviewed.*

·  A reporting function for providers to identify participant plan review dates.*

Status

·  NDS continue to be concerned about the quality of plans that are being developed and regularly monitor this.

·  Bruce Bonyhady, the outgoing Chairman of the NDIA, hasacknowledgedthat the quality of plans is one of several challenges facing the Agency in implementing the NDIS.

·  The NDIA has indicated they are trying to streamline the quoting (administrative) process.

·  The NDIA has introduced contingency funding for people with Motor Neurone Disease to minimise the need for a review due

·  The NDIA developed a Reference Package for people with Multiple Sclerosis.

·  The NDIA has outlined the key roles of LACs and the arrangements in each state and distinguished the roles of planners, Local Area Coordinators (LAC) and Early Childhood Early Intervention (ECEI) Partners.

·  From 1 July 2016, the NDIA implemented a streamlined planning process to assist with bringing a large number of people into the scheme.The guided planning process (called First Plan) intends to enable rapid entry to the scheme, with planners using set questions and allocating individual budgets using reference packages as benchmarks.

·  Despite the NDIA encouraging participants to share their plans with providers, this is not common practice and requires a form to be manually filled in and sent to the Agency by the participant. NDS is working with the NDIA to simplify the process of sharing plans.

·  The NDIA is agreeing to longer term plans for some participants. The guarantee remains in place that plans may be reviewed at any time the participant’s circumstances change significantly.

* Also noted in the NDIA Portal Issue

IssueEmergency Response

Emergencies arise in everyone's lives; they are unpredictable and cannot be planned for. People with disability and their families need to be able to draw on immediate disability support when these emergencies arise, such as when a family relinquishes responsibility for the care of their child at 9pm at night; or when an elderly parent caring for an adult family member with disability is hospitalised and the person with disability cannot be left alone. While some people with disability will already be a participant of the NDIS, others will not but will still need assistance immediately.
Under state and territory-funded disability systems, arrangements exist for organisations to respond when emergencies arise at any time. While there is capacity for emergency short term accommodation under the NDIS, there is no national 24/7 response system in place and accessing funded support is limited to people with an NDIS plan.

The NDIA has extended its operating hours, however it is closed between 11pm-8am Monday to Friday, weekends and public holidays. Referring people to Lifeline outside these times is inadequate, particularly in response to a significant emergency or crisis.

The NDIA has revisedthe support coordinationrole which now involves an expectation that providers are available 24/7 to respond to a crisis, however not every participant has this support funded in their plan.

What NDS is seeking

·  An emergency response service to be established by the NDIA during the transition period that:

o  provides emergency support for people living in NDIS sites regardless of whether or not they are a participant;

o  is accessible via a national 24/7 phone line;

o  can be escalated to a regional response if required (i.e. regional service providers are identified that can coordinate 24/7 emergency support); and

o  is tested and refined for full implementation.

·  Appropriate supports are available immediately, with arrangements for plan reviews or NDIS eligibility to be prioritised by the Agency on the next business day after the emergency response has been implemented.

Status

·  The NDIA Contact Centre (1800 800 110) has extended its operating hours to 8am - 11pm local times, Monday to Friday.

·  NDS has prepared an emergency and crisis response system paper to inform the NDIA’s thinking. An important consideration is whose responsibility it is when a person presents who is not currently in the service system and is not necessarily eligible for supports.

·  In itssubmissionto the Independent Review of the NDIS 2013 Act, NDS recommended:

o  the NDIA establish an emergency response function as the NDIS begins full implementation from July 2016

o  the Act should provide for an emergency response for a person with disability prior to their eligibility as a participant being determined.

·  NDS sought feedback from providers delivering support coordination to identify implications of the NDIA expectation that they should be available 24/7 to respond to a crisis.

·  NDS has gathered examples of circumstances requiring an emergency response within trial sites to inform our negotiation with the NDIA.

·  NDS highlighted the lack of a central coordinated emergency response with the NDIA in May 2015.

IssueNDIA Portal

The Department of Human Services developed a new ICT system, to be phased in over three years, with the foundations operational on 1 July 2016. Sitting alongside the participant and provider portals will be an e-market, an electronic marketplace where providers and participants can interact.$143M over four years has been committed for the system.

Well over a thousand providers are experiencing delays with their registration application to provide supports under the National Disability Insurance Scheme (NDIS). Most of these are new registrations (i.e. they are from providers not yet working within the NDIS), with a smaller group trying to extend their existing registration to provide new supports.The delay in resolving the registration backlog is concerning, not least because thousands of registrations are expected as the transition to the NDIS continues across Australia.

Providers are experiencing difficulties arising from the slowness of the portal and regularly getting error messages which often requires logging onto the website again and entering the data again. Adding to providers’ frustration is the inability to get a response or a resolution from the provider support telephone or email contacts.

Providers are also reporting a range of issues around plan errors which requires additional administration for providers and in some cases no certainty of funding. Providers only become aware of these errors either when they are informed of a plan review (often with a different funding amount), or when they receive an error report following a payment request.

The National Disability Insurance Agency (NDIA) has an expectation that providers will continue to deliver supports until the plan (funding) or portal is resolved, which means providers are carrying a debt until the NDIA resolve the issue, and in some cases there is no guarantee the plan (funding) will be adjusted. This issue arises when:

·  plan dates and/or funding amount on the portal does not match the plan posted to the participant;

·  some plans are being made inactive during a review and providers are unable to claim; and

·  some plans are missing funding for key supports.

What NDS is seeking