A new NDIS Price Guide is in effect as of 1 February 2019 and the changes that have been made are not exactly what we were expecting…
There are two key areas of change in this update:
The introduction of a Very High Intensity pricing tier. This was recommended by the Independent Pricing Review and announced in December of last year. While this change was expected, its execution is surprising (details below).
Minor changes to capacity building and training in plan and financial management, making the definitions and price consistent regardless of whether it is delivered by a Plan Manager or Support Coordinator.
Very High Intensity Pricing Tier
The introduction of a third pricing tier for people with particularly complex support needs was introduced in the Independent Pricing Review. It was recommended then that it be linked to the complexity of a Participant’s support needs so that, for example, somebody with “severe behaviours of concern” would receive funding at the highest level. However, the actual implementation of the pricing tier is linked not to the Participant’s support needs but the wage of the worker. The levels are listed below with the VIC/NSW/QLD/TAS price for Assistance With Self-Care Activities - Weekday Daytime for comparison:
Level 1 (“standard”) – where a shift is undertaken by a worker who is classified at SCHADS Award 2.3 or below (or the equivalent): $48.14 / hr
Level 2 (“high intensity”) – where a shift is undertaken by a worker who is classified at SCHADS Award 2.4 or 3.1 (or the equivalent): $50.73 / hr
Level 3 (“very high intensity”) – where a shift is undertaken by a worker who is classified at SCHADS Award 3.2 or above (or the equivalent): $52.98 / hr
The obvious benefit of this third tier is that it creates another step on the vocational pathway for Support Workers and recognises the skill they bring to their work. It also encourages providers to support Participants who they might otherwise not have.
However, while it might seem evident that a person with higher support needs would be supported by a person with a higher skill level, this shift in focus to the worker raises some concerning questions about Participant choice and control.
We are left wondering to what extent Participants will actually be able to choose who supports them. We know that many organisations struggle to match people with their desired workers and we have to wonder whether Participants will now be out of pocket when shifts are filled by potentially overqualified workers.
Most troubling of all, the NDIA have made the confusing statement that “it is anticipated that in most cases the total cost of the mix of supports that participants can purchase will not increase as a result of the changes.” For those of you playing along at home – yes, this means that the NDIA estimate that people with complex support needs will not spend more on support, despite the cost per hour increasing. This can only mean that they imagine people will purchase fewer hours of support.
The statement continues, “The number of plan reviews is therefore expected to be limited” and advises that any review request will be subject to their standard prioritisation process (i.e. good luck getting one before your scheduled plan review!).
This comment begs the question, who decides which Participants should be supported by higher skilled workers? If it is the Participant, will the Planner then need to agree to put the required funding in the Plan or does the NDIA somehow expect that Participants who want more trained workers will find a way to pay for this within the same budget?
Providers and Participants both have some fairly significant work ahead of them now to understand how this change impacts existing plans. This includes rewriting service agreements, recalculating budgets, aligning rostering and invoicing systems so the correct rate is charged and having reliable mechanisms in place to make sure that unexpected shift changes don’t have an adverse effect on a Participant’s budget.
Overall, the introduction of a very complex pricing tier is a very welcome addition to the NDIS Price Guide. So far, the details of its implementation has been surprising (to put it mildly) and we expect that the NDIA will have some clarifying work to do in the not distant future.
Temporary Support Overheads
Finally, one more detail to add to these changes. Temporary Support of Overheads (TSO), for those of you who don’t sleep with the Price Guide under your pillow, is a 2.5% loading that was applied to standard intensity personal care and community access supports in July last year to compensate providers for the cost pressures associated with NDIS transition. It is a temporary measure that is expected to be reduced next financial year and removed after that. The good news for providers in this Price Guide update is that the TSO has now also been applied to “Level 2” supports (i.e. high intensity) and the new tier, “Level 3” (i.e. very high intensity).
This means that for all supports delivered from 1 February, providers can charge the higher price. It is unclear if Participant Plans will be scaled up to account for this loading in the meantime so while this is good news for providers, it remains unclear who is really paying the price in the meantime.