) Calvary Health Care Bethlehem
24 March 2017
Review of NDIS Costs
Productivity Commission
GPO Box 1428
BARTON ACT 2600
Dear Productivity Commission
RE: Review of NDIS costs
Hospitality
Healing
Stewardship
Respect
Calvary Health Care Bethlehem (CHCB) provides specialist expertise in clinical management, treatment and assessment of progressive neurological diseases. The Statewide, Level 5 service is based on the principles of neuropalliative rehabilitation and sees people with progressive neurological disease from early diagnosis. With a focus on wellness and active engagement in life, the multidisciplinary team work collaboratively with patients and their other local health care providers as partners in care. As a State wide provider CHCB has a role in leadership, liaison, research and education and support for other services.
CHCB have had approximately 10 patients transition to NDIS supports to date. We are registered as a NDIS provider but have not launched provision of services. Our feedback is related to our experience to date.
Calvary Health Care Bethlehem Feedback
Section 3: Scheme Boundaries
The intersection with mainstream services
Is the current split between the services agreed to be provided by the NDIS and those provided by mainstream services efficient and sufficiently clear? If not, how can arrangements be improved?
The split is mostly clear. In cases where a health condition causes disability and that condition is not static but progressively declining, there will be a need for both health and NDIS to provide services. How this model is achieved in an integrated, person centred way requires further development.
Is there any evidence of cost-shifting, duplication of services or service gaps between the NDIS and mainstream services or scope creep in relation to services provided within the NDIS? If so, how should these be resolved?
We have been involved in one case where a gap was identified: the NDIS plan seemed inadequate to meet the therapy support needs for equipment prescription and home modifications, and the Community Health Service who had previously provided that sort of work no longer was able to do so because the plan was insufficient to cover their costs. CHCB were asked to provide services instead as a health service, but the woman was outside our home-visiting catchment area.
How has the interface between the NDIS and mainstream services been working? Can the way the NDIS interacts with mainstream services be improved?
NDIS planners need to be aware of what mainstream supports are being provided within health for a participant. The NDIS planner needs to work with the participant and the health providers to negotiate what will continue to be provided in health and what supports will
476 Kooyong Road, South Caulfield VIC 3162
Calvary Health Care Bethlehem Ltd
ABN 81 105 303 704
P: 03 9596 2853
www.bethlehem.org.au Page 1 of 3
Continuing the Mission of the Sisters of the Little Company of Mary
be provided under NDIS to ensure they have access to the right level of care, there is no duplication of effort or service gaps. Service models need to be integrated between mainstream supports and NDIS to ensure a holistic approach for the participant.
Section 4: Planning
Is the planning process valid, cost effective, We have evidence that the planning process does not reliable, clear and accessible? If not, how could it always provide the necessary supports to implement the be improved? plan, for example provision of suitable equipment required, and also inadequate therapy supports to assess, prescribe, order and train the participant in use.
The planning process does need to ensure it includes information from health professionals in the provision of supports for people with progressive conditions who may be adjusting to their diagnosis and the rapidly progressive nature of their condition and may not be in a position to advocate for their future needs.
How should the performance of planners be Quality measures need to be in place to confirm if the plan monitored and evaluated? provides supports that meets the participant’s goals adequately and monitor gaps. This could include feedback from the NDIS participant to the NDIA. It would also be important to monitor equity of plans across the country. There could also be a feedback opportunity for NDIS support providers to comment on their perception of the appropriateness of plans that have been developed.
Reasonable and Necessary Supports
Are the criteria for participant supports clear and For people with progressive disorders, the person’s needs effective? Is there sufficient guidance for assessors can change more rapidly than expected, so there needs to about how these criteria should be applied? Are be sufficient flexibility in the plan being reviewed and there any improvements that can be made, amended to accommodate unforeseen needs arising. This including where modifications to plans are needs to happen in a timely manner. required?
To what extent does the NDIA’s budget-based The development of reference packages where applied is approach to planning create clear and effective appropriate. Where a package is found to be outside this, criteria for determining participant supports? To a review by an independent panel including relevant what extent does it lead to equitable outcomes for consumers and professionals could assess the plan for participants? What improvements could be made? advice to ensure equity of access to supports. Individual health planners are not necessarily in a position to ensure supports are appropriate or equitable acting alone.
What implications do the criteria and processes for Capping certain items is a straightforward way to achieve determining supports have for the sustainability of sustainability (either caps in hours of support that can be scheme costs? provided or cost of equipment items). There also needs to be an opportunity to challenge those caps for exceptional
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circumstances with a clinical review process.
Will providers be ready?
Are prices set by the NDIA at an efficient level? The prices for some aspects of the NDIS price guide are too low to achieve viable business models for providers.
What are the barriers to entry for new providers, The main barriers are around price for the provision of how significant are they, and what can be done some services where the workforce industry standards about them? (EBA) are above the NDIS Price Guide – for example provision of maintenance therapy by an allied health assistant, support coordination provided by a social worker, psychologist, occupational therapist, and group and centred based activities as defined in the guide to suitability.
These are issues for CHCB transitioning to NDIS.
The statewide model of care for people with progressive How will the changed market design affect the neurological disorders is based on collaboration between degree of collaboration or co-operation between providers to ensure the right level of care is provided at providers? How will the full scheme rollout affect the right time. To ensure person centred, proactive care their fundraising and volunteering activities? How that enables people to meet their goals and maintain their might this affect the costs of the scheme? independence, the model needs to ensure integration and good communication between providers. This may be undermined with multiple clinicians from different organisations, without a collaborative approach. There is some risk that clinicians may not have the level of expertise for complex conditions and models that ensure appropriate support need to be considered, within a competitive model. In a competitive market collaboration is challenging.
The pricing for the fee for service does not meet the How ready are providers for the shift from block workforce costs, provided in the block funding. This will be funding to fee-for-service? monitored to ensure feasibility of the service.
Yours sincerely,
Name: Maryanne McPhee
Position title: Manager, Statewide Progressive Neurological Disease Service
cc (if applicable)
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