Update 13/12/18: The NDIA have now changed their answer to this question. Read more
A recent update to the Provider Toolkit has made it clear that the NDIA expects that Support Coordination funding is not to be used to attend plan meetings. This position was articulated in the following frequently asked question:
As a Support Coordinator you can assist participants to understand how they will engage and participate in NDIA processes. A Support Coordinator’s role is not to act as an advocate in NDIA processes. Attending planning conversations, internal or external review meetings and hearings, including the Administrative Appeals Tribunal (AAT), as well as engaging in advocacy support cannot be undertaken using funded supports from a participant’s plan.
The Department of Social Services funds organisations to provide advocacy support services to assist participants when engaging in NDIA processes. The Disability Advocacy Finder is an online tool to help find NDIS Appeals providers and disability advocacy agencies across Australia.
In essence, the NDIA is saying that they believe attending plan review meetings is not a reasonable and necessary support because it fails Section 34 (f) of the NDIS Act, which states:
(f) the support is most appropriately funded or provided through the National Disability Insurance Scheme, and is not more appropriately funded or provided through other general systems of service delivery or support services offered by a person, agency or body, or systems of service delivery or support services offered
The logic here is that the NDIA sees attendance at plan review meetings as advocacy, which is a DSS funding responsibility. Support Coordinators are still free to attend the meetings (if invited by the Participant) but the Participant’s NDIS funds should not be used to pay for the Support Coordinator’s time.
It’s important to note that it’s not the responsibility of the NDIS to fill the gaps of other service systems. So while it’s totally unrealistic to think that advocacy groups would have the capacity to adequately support hundreds of thousands of Participants through plan reviews, that doesn’t negate the fact that it is still not an NDIS funding responsibility.
This is not an entirely new position. The NDIA have been saying for years that Support Coordinators are not Advocates or Case Managers and that they should not support Participants to appeal their Plans. It’s unsurprising they’re reiterating this point now – after all, it’s easy to imagine why they wouldn’t want to pay for the support that helps Participants increase their package sizes.
But where does this leave Participants who want to use their funding to support their plan review? The simplistic answer is that Support Coordinators can still be paid to write reports that support planning decisions, as well as build the Participant and their informal network’s capacity to advocate for themselves in meetings. Both of these things are absolutely necessary and in our experience, often overlooked parts of the Support Coordinator role.
But the complex answer is that Support Coordinator reports are often not read and that the anxiety of the planning experience can be overwhelming for even the best prepared Participants and families.
We seriously question the NDIA’s position that Support Coordination before the meeting is considered “capacity building” but during the meeting it is “advocacy”. Some of Support Coordinators most important roles could be considered advocacy, whether that be addressing service delivery issues with providers or working with mainstream services to overcome the Participant’s barriers in accessing them.
Support Coordinators might want to explore forming working partnerships with advocacy organisations. You can reduce the time the advocate needs to spend on each case by thoroughly briefing them on the Participant’s circumstances and the ideal outcomes of the meeting. Ideally, this will increase the number of Participants that advocates are able to support.
In an ideal world, Support Coordinators would be totally unnecessary at plan meetings because Participants and families would be supported to be ready, Planners would guide them through exploring their needs and consider all the evidence provided. For Participants without informal supports, advocates would be available and fully resourced to support them through the process.
But it’s no secret that we do not live in an ideal NDIS world and that the anxiety that many Participants and families experience in these moments can impact not just their planning outcomes but their health and wellbeing. For $96.04, the Agency can utilise Support Coordination to ensure Participants get the best outcomes possible from a complex to navigate Scheme. What could be better value for money than that?