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Private billing rates

This section analyses a data set of 1,791 private billing rates for several NDIS-related weekday in-room therapy services. The private billing dataset was compiled by the NDIA by scanning provider websites across Australia. Prices for weekend, initial consultations and telehealth consultations were excluded from the dataset, as well as some outliers⁴⁹. The sample has been derived from the private billing analysis conducted in the 2021-22 Annual Pricing Review (4,014 in-scope observations). The NDIA tried to replicate the same sample during the 2022-23 Annual Pricing Review (2,857 in-scope observations). For reference to last year’s analysis, 1,167 observations dropped out of the last years sample of 2,857.

For greater representation in certain segments of the sample, observations were expanded in certain states (NSW, SA, NT and ACT) to ensure there was enough observations for significant results. This led to over 200 provider websites randomly sampled for relevant pricing, with many not having available or comparable pricing. In total, this provided a sample size of 1,791 observations for the 2023-24 period. The sample size is still considered sufficient for the purpose of pricing benchmarking. In the absence of a requirement to publish pricing or a database of comparable, time-based therapeutic sessions, these hinder the long-term viability of this sampling method. The NDIA intends to consider measures to improve this process in coming years.

The private billing rates were converted to effective hourly rates based on the length of consultation, for more direct comparison to the applicable NDIS price limit. About 30% of the sample included billing rates from non-metropolitan areas (considered as Modified Monash Model (MMM) areas 4 to 7).

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⁴⁹ The study excluded outliers where the value of hourly rate was either greater than Quartile 3 +1.5Interquartile or was smaller than Quartile 1 – 1.5Interquartile.

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In the analysed sample of therapy services, the most frequently represented therapists were Physiotherapists, making up 20.5% of the dataset, followed by Psychologists at 15.4%, Clinical Psychologists at 10.1%, and Dietitians at 8.9%. For most therapy types, the dataset includes at least 80 observations, with the exceptions being Art Therapists (26 observations), Music Therapists (39 observations), and Social Workers (45 observations).

The diversity and overlap in pricing across different therapy types are illustrated in Figure 32, showing the range and commonalities in billing rates among the various services. There appears to be some multi-modal distributions for several types of therapies, where there is a cluster of prices in the sample around different price points.

Figure 32: Distribution of Private Billing Rates by Therapy Types

The distribution of sample observations geographically leaned more towards VIC, 34% of the sample, and QLD, with 27%, indicating an underrepresentation of therapists from NSW, which accounted for only 20%, compared to its share of the

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NDIS market (31% of total NDIS therapy claims in the six months to December 2023). The NT was the only state or territory with fewer than 30 observations (12).

Figure 33 shows the distribution of private billing rates across different states and territories, revealing substantial overlap and variance. From the analysis, certain states, and territories, including the NT and TAS, exhibited a variety of trends in pricing distribution.

Figure 33: Distribution of Private Billing Rates by State and Territory

State	WA	VIC	NSW	QLD	NT	SA	TAS	ACT

Table 21 shows an overview of the distribution statistics for the private billing rates sampled. On average, the effective hourly rate for therapists providing in-room services on weekdays was $195.6, with a median rate closely following at $194. The data set revealed a wide range of billing rates, from a minimum of $85 to a maximum of $396.

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Figure 34 and Figure 35 compare the average private billing rates for various therapy types to the current NDIS price limits. The findings indicate:

• The average billing rates for clinical psychology and psychology in all states and territories exceed the NDIS price limits.

• Therapies such as Speech Pathology, Audiology, Occupational Therapy, Dietetics, Social Work, Exercise Physiology, and Counselling have billing rates that are 90% or more of their NDIS price limits.

• Conversely, Art Therapy (78.7%), Podiatry (81.4%), and Music Therapy (85.6%) show average billing rates that fall significantly below their NDIS price limits.

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5.6 Mean, Median and 75th percentile billing rates

Comparing the NDIS price limits with the mean, median, and 75th percentile billing rates for therapy types reveals important insights into the alignment between NDIS price limits and market-driven billing practices.

5.6.1 Psychology

The relevant NDIS price limits for Psychologists are set at $214.41 for VIC, NSW, QLD, and ACT (state grouping 1), and $234.83 for WA, SA, TAS, and NT (state grouping 2).

The statistical analysis shows that Psychologists have an average billing rate of $228.6, and Clinical Psychologists have a higher mean rate of $260.3. These amounts for this sample exceed the NDIS hourly price limits for Psychology supports, for both different state and territory groupings.

The median billings rates for Psychologists and Clinical Psychologists were at $228.0 and $255.0, respectively, which exceed the NDIS hourly price limits for Psychology supports, for most state and territory groupings.

The 75th percentile billing rates for psychologists and clinical psychologists are $254.2 and $284.4 respectively, indicating that a significant portion of billed appointments exceed the NDIS price limits.

This upper quartile of billing rates suggests that the private billing rates are frequently higher than the NDIS price limits. The benchmarking results indicate that the market rates for Psychology services, at the mean, medians and 75th percentile are now higher than the NDIS price limits.

5.6.2 Other therapy types

The following section discusses Audiology, Physiotherapy and Speech Pathology (selected due to sample being the next closest to the NDIS price limits). Note, $193.99 is the NDIS price limit for Audiology (national), Speech Pathology (national) and Physiotherapy (VIC, NSW, QLD, and ACT – state grouping 1). It is $224.62 for Physiotherapy in WA, SA, TAS, and NT (state grouping 2).

The means of private billing rates for Audiologists, Physiotherapy, and Speech Pathologists are $194.5, $202.7, and $192.7, respectively. For Physiotherapy, it has means of $197.0 and $220.9 for state groupings 1 and 2, respectively.

This is compared to the median billing rates for Audiology, Physiotherapy and Speech Pathology of $190.0, $200.0 and $193.3, respectively. For Physiotherapy, when considering the state groupings, the medians are $194.0 and $224.6 for state groupings 1 and 2, respectively.

At the 75th percentile, observed rates within the private market for these supports is $210.0 for Audiology, $240.0 for Physiotherapy, and $194.0 for Speech Pathology,

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Regressions

Regression analyses were undertaken to understand the relationship between therapy types, geographic regions, and billing rates, and to determine how these variables influence the price variability within the private therapy market. Table 22 details the results of the regression analysis. The dependent variable in all model regression models is the hourly private billing rate in dollars.

The analysis explores the similarities between some of the therapy groups. A series of Tukey’s range tests⁵⁰ were undertaken to group therapy types with similar means of private billing rates. The test found that Audiology, Dietetics, Occupational Therapy, Physiotherapy, Speech Pathology, and Social Work share comparable billing averages (Group 1); while Art Therapy, Counselling, Exercise Physiology, Music Therapy, and Podiatry share similar means. Group 3 comprises of both Psychology and Clinical Psychology, which are distinct but are considered together for analytical simplicity. These grouping forms the basis of Model 3, which will be explained further below.

⁵⁰ A Tukey range test is a statistical tool used to compare the means of different groups to determine if they are significantly different from each other, while accounting for the fact that multiple comparisons are being made.

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Note: The baseline (Constant) for Model 1 is Occupational Therapy. The baseline in Model 2 is Occupational Therapy in Metropolitan Victoria and in Model 3 it is Group 1 therapies (Audiology, Dietetics, Occupational Therapy, Physiotherapy, Speech Pathology, and Social Work) in Metropolitan Victoria.

Regression results of three specifications are presented in this section. The modelling begins with each therapy type as variables, (Model 1). The base (or omitted) variable is Occupational Therapy, meaning the constant coefficient reflects the mean Occupational Therapy private billing fee. The coefficients attached to each therapy type reflects the fee relative to Occupational Therapy (for example, the coefficient attached to Art Therapy is -25.5 and hence the average billing rate for Art Therapy is $155.1 (180.6 minus 25.5)).

Model 2 builds upon Model 1 by including state/territory and regional indicators, with Occupational Therapy, Metropolitan and Victoria being the base variables that reflect the coefficient on the constant term. Model 3 keeps the geographical indicators but replaces the individual therapy variables with the groupings found using the Tukey difference in means tests discussed previously.

Model 2 is preferred over Models 1 and 3 for its slightly higher explanatory power, with an adjusted R-squared⁵¹ of 0.352, indicating it explains 35.2% of the variations in private billing rates. The results suggest that the average hourly rate of $178 for Occupational Therapists in Metropolitan Victoria (Model 2), with Audiologists, Psychologists, Physiotherapists and Speech Pathologists appear to have exceeded the applicable NDIS price limits (statistically significant at 0.05 level).

A deep dive into the regression results revealed a meaningful statistical difference between both Clinical and Non-Clinical Psychology nation-wide. The results showed significant statistically difference consistent across applicable states and above its price limits. This adds significance to the previously discussed means, medians and 75^th percentiles comparisons between the different types of therapies.

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⁵¹R-squared is a statistical measure that represents the proportion of the variance for a dependent variable that is explained by an independent variable or variables in a regression model.

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The NDIA acknowledges that there are many uncaptured variables that would assist a greater explanation of private billing rates. This, however, is difficult to obtain through website scrapping alone.

Consultation feedback

The APR received 178 provider submissions, feedback from 13 professional bodies, one union, and 142 participants. A predominant theme was the suggested increase in the costs of delivering therapy support services, cited by approximately 87% of providers. These cost increases spanned across wages (including adjustments to meet Allied Health Awards and professional development), business expenses such as rent, utilities, office supplies, and insurance, as well as recruitment and retention challenges. The Ability Roundtable, incorporating an Allied Health Cost Model by Deloitte Access Economics, suggested a large difference, with a 12.9% variance between projected costs and the current NDIS Price Limit for major allied health disciplines. Professional bodies advocated for a price limit increase reflective of cumulative indexation since 2019 and suggested automatic indexation from 2025, claiming thin margins on which many small-scale therapy support businesses operate.

Regarding the provision of therapy and early childhood supports to both NDIS and non-NDIS participants, most providers catered to a mix of clients, with the proportion of NDIS participants ranging from 25% to nearly 100%. Despite the varied client base, appointment durations were often standardised, tailored to client needs rather than funding source, although complexities associated with NDIS participants sometimes necessitated longer sessions. Pricing approach varied, with most providers charging at the NDIS price limit, yet some reported differences in charges between NDIS and non-NDIS clients, attributed to the complexity of NDIS participants or additional administrative burdens. Unique costs associated with early childhood supports for NDIS participants were identified, including the need for team-based approaches, specialised skills, and extended appointments, which highlighted the complexity and intensity of services required. Professional bodies echoed these sentiments, emphasizing the need for specialised training and resources, particularly for providers catering to young children with disabilities.

See Appendix A for more details on common themes raised in submissions to the 2023-24 APR Consultation Paper.

Discussion

The Australian therapy market encompasses a wide array of services provided by allied health professionals, who are typically university-educated with specialised expertise in preventing, diagnosing, and treating various conditions and illnesses. While the NDIS forms an important part of this landscape, allied health services extend beyond NDIS funding. These services are also accessed through various other arrangements, including Medicare subsidies, private health insurance, where it

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is common for out-of-pocket payments to be made by the consumer, other government schemes, and the Department of Veterans Affairs (DVA).

In the 2022-23 financial year, 39% or approximately 10,389,000 individuals accessed allied health services⁵². For comparison 379,296 participants, representing 59% of the total 646,449 Scheme participants in the six months to 31 December 2023 accessed allied health supports using NDIS funding.

The NDIS therapy provider market has continued to demonstrate strong growth (14% growth for the six-month comparison to 31 December 2023 to same period the previous year), with a notable trend away from registered providers to a diversified unregistered provider market. The proxies the NDIA has used as an overview for market health and competition include the HHI, provider entry, periods of activity and inactivity and share of total NDIS therapy payments has suggested the market continues to mature and continues to meet increasing demand in most areas.

The NDIS therapy market operates in a manner that closely aligns with the characteristics of a deregulated, or private market, more so than other NDIS sub-markets. Despite its market-like behaviour, the NDIS therapy market includes regulatory mechanisms, specifically price limits, to assist participants receive value for money. These price limits are closely linked to the dynamics of the private market, ensuring that NDIS pricing remains competitive and reflective of current service costs.

Accordingly, other government schemes and the private billing market serve as suitable comparators to assess the appropriateness of the NDIS price limits. Feedback from consultations and discussions with various government funding schemes has indicated that, despite the relative smallness of users of the NDIS therapy market, it could act as a ‘price setter.’ Evidence of this may be seen in

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⁵² Australian Institute of Health and Welfare (2022), Australia’s health 2022: in brief, catalogue number AUS 241. Australia’s health series number 18, AIHW, Australian Government.

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private billing rates, where the median and 75th percentile rates pricing for certain therapies align closely with the corresponding NDIS price limits.

Although benchmarking NDIS price limits against other comparable government funding schemes may introduce certain inaccuracies, it remains an important process. This ensures that government funding mechanisms do not inadvertently compete against each other for therapy professionals. Key factors to consider when comparing NDIS to other schemes include:

• Risk assessment and pricing models: Some schemes often base pricing on risk assessments and pooled resources, which does not always reflect the costs of individualised support required by individuals, such as NDIS participants compared to the general population.

• Contractual and volume discounts: Prices in other government schemes may be influenced by contractual agreements or volume discounts that are not applicable in the context of the NDIS service delivery that can lead to lower benchmarks.

The 2023-24 APR analysis of other schemes showed that while some have increased their pricing or funding levels, NDIS price limits remain consistent with the majority of therapies provided across these schemes. It is important to note, that there is significant variation in therapy pricing and funding levels among different schemes. Additionally, certain therapies such as Audiology, Art Therapy, and Music Therapy, which are covered by the NDIS, are not typically funded by other insurance schemes, including private health.

The analysis of private billing rates offers a comprehensive view of the diverse range of therapy supports available to NDIS participants, reflecting market-driven costs influenced by direct service delivery, provider expertise and current demand. By gathering a broad dataset of private billing rates from provider websites and adjusting them to effective hourly rates, the NDIA ensures a fair comparison across different therapies and geographic areas. This standardisation is important for assessing whether NDIS price limits align with market rates, thereby maintaining fairness and relevance within the private therapy sector.

The analysis indicates that NDIS price limits generally match or exceed the rates for most therapies nationwide. However, regression analysis highlights statistically significant variances among therapies, which could correspond to differences among therapy professionals such as in qualifications, skills, and experience.

Examining the statistically significant differences and general market pricing metrics, including the mean, median, and 75th percentiles, showed that rates for Psychologists often met or exceeded the NDIS price limits. Additionally, when compared with other government schemes, the NDIS price limits for Psychologists are not at the higher end of the spectrum. This information together suggests there is stronger evidence supporting adjustment to NDIS price limits for Psychologists compared to other types of therapists.

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5.10 Recommendations

Review of the current price limits for Psychologists against private billing rates and other comparable government schemes, it is apparent that the current limits generally sit below the prevailing market rates. The mean billing rate for psychologists is $228.6, with clinical psychologists at a higher rate of $260.3, both exceeding the NDIS hourly limits. The difference is further highlighted at the 75th percentile billing rates, where a significant portion of billed services are charged at higher rates, than current price limits. This gap between market rates and the current NDIS price limits suggests that the NDIA should increase the hourly price limits, with the proposal being to use an indexation methodology of 80/20 split between the Australian Bureau of Statistics (ABS) Wage Price Index (WPI) and ABS Consumer Price Index (CPI).

Recommendation 6

The NDIA should increase the price limits for supports delivered by a Psychologist on 1 July 2024 in line with the weighted movement over the previous twelve months in the ABS Wage Price Index (Australia, total hourly rates of pay excluding bonuses) and the ABS Consumer Price Index (All Groups, weighted average of eight capital cities) over the 12 months to the March Quarter immediately preceding the indexation date (with an 80/20 weighting).

Specifically, this should be for support line items: ‘Assessment Recommendation Therapy or Training – Psychologist (15_054_0128_1_3)’, ‘Early Childhood Supports – Psychologist (15_001_0118_1_3)’, and ‘Specialist Behaviour Intervention Support (11_022_0110_7_3)’.

Review of the alignment of the NDIS price limits for other therapists against the private billing rates and other comparable schemes suggests a general compatibility between NDIS price limits and prevailing market rates. In general, for most therapists, mean and median billing rates closely mirror the NDIS hourly price limits, which are set at $193.99 in most regions, suggesting that the current price limits adequately reflect market norms. Even when considering some therapists which means, medians and 75th percentile billing rates exceed NDIS price limits, the frequency of such instances does not indicate a systemic pricing concern that hinder participants from accessing these services relative to other clientele.

Recommendation 7

The NDIA should not make any further structural adjustments to the pricing arrangements for therapy supports at this time and should not index the price limits for all other therapy-related supports on 1 July 2024.

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Table 25: Registered Providers by Remoteness for Support Coordination Supports, January 2021 to December 2023

Remoteness	January – June 2021	July – December 2021	January – June 2022	July – December 2022	January – June 2023	July – December 2023
Non-remote	2,444	2,787	3,026	3,294	3,469	3,647
Remote	280	299	299	308	324	362
Very remote	168	182	175	187	199	212
Total for registered	2,467	2,810	3,044	3,332	3,503	3,686

Table 26: Unregistered Providers by Remoteness for Support Coordination Supports, January 2021 to December 2023

Remoteness	January – June 2021	July – December 2021	January – June 2022	July – December 2022	January – June 2023	July – December 2023
Non-remote	1,437	2,147	2,712	3,472	4,366	5,242
Remote	36	71	85	121	160	197
Very remote	23	35	47	69	80	98
Total for unregistered	1,455	2,174	2,739	3,518	4,420	5,300

Source: NDIS internal administrative data

Please note a discrepancy in the total number of ‘active’ therapy providers, attributable to two factors: firstly, some providers offer a mix of registered and unregistered supports, leading to their classification in both categories. Secondly, a small fraction of providers with undetermined registration status contributes to total payment figures but is excluded from detailed tabulation, representing less than 1% of the overall financial transactions.

6.5.3 Market share reduction of leading providers shows signs of a less concentrated market

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There is no legislative requirement in similar care and support sectors, the Aged Care Award 2010, and Children Services Award 2010. Further, for providers of therapy supports, there is no apparent requirement for “client cancellations” under the Health Professionals and Support Services Award 2020. This is the minimum Award conditions for many types of therapists delivering NDIS supports.

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From respondents to the provider consultation paper, Figure 50 depicts suggested short-notice cancellation policies from respondents. Over half of the respondents for DSW (52%) and Support Coordination (53%) short-notice cancellation policy claimed they have a 7-day policy. Whereas 76% respondents delivering therapy supports reported they have a short-notice cancellation policy of less than 48 hours.

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7.3.2 Suggested strategies to mitigate short notice cancellation impacts on NDIS participants

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Another perspective comes from a provider of Therapy supports who suggested the critical role of their cancellation policy in business sustainability and service reliability:

“Our cancellation policy has a notification period of 7 days and charges the full rate for NDIS participants … The NDIS cancellation policy as per the price guide, to which we adhere, has actually saved our business. Many families cancel often with little to no warning. Again, the area we provide services impacts this. The seven day policy, seems extreme however we would not be able to run our business at all without this in place.”

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For non-DSW related supports (non-SCHADS related), such as therapy services, lack a standardised legislative or Award requirement for client cancellations. This is the case for other comparable care and support services such as Aged Care and Children’s Services. There is also limited cancellation policies in other Government funding schemes.

Through consultation and research conducted, there is a case that the maximum of 7-day policy may not be necessary for non-DSW supports. There appears to be a greater usage of a 2-day cancellation policy in the sector, particularly among therapy providers, which supports a potential for a shorter cancellation policy. 76% of provider respondents delivering therapy supports to NDIS participants suggest they already have a short-notice cancellation policy of 48 hours or less. This is also supported by the website data analysis conducted by the NDIA, acknowledging the limited sample that had available data for analysis. The NDIA believes there to be mechanisms and methods already being utilised by the sector to assist participants limiting cancellations which could make the reduction in notice period feasible.

Recommendation 11

The NDIA should adjust the 7-day short-notice cancellation policy for non-Disability Support Worker-related supports to two clear business days from 1 July 2024.

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9.4 Therapy Supports

The Provider Consultation Paper asked several questions about providing therapy supports, including changes in the costs of delivering services and questions about the differences between providing therapy supports to NDIS and non-NDIS clients.

There were 178 provider submissions received relating to therapy supports, 13 from professional bodies, one from a union and a small number from provider peak bodies. Through the APR online form and Participant consultation paper, 142 participants also provided feedback on therapy supports.

9.4.1 Changes in the costs of delivering services

The Provider Consultation Paper asked providers about significant changes in the costs of delivering Therapy support services.

Providers

About 87% of provider submissions reported increases in the costs of delivering therapy supports and services. Providers noted increases in wage costs (including increasing staff wages, keeping up with Allied Health awards and professional development costs) and costs associated with recruitment and retention. Providers also reported increases in business expenses such as rent, utilities, office supplies, insurance, workers compensation premiums and travel expenses.

Provider peak bodies

Ability Roundtable responded to the consultation questions on therapy supports and included an updated Allied Health Cost Model for NDIS-funded services from Deloitte Access Economics. The model estimates the respective services costs of 13

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large therapy providers.66 The model indicates that the current NDIS price limits are lower than the actual and projected costs of delivering therapy supports:

• There is a 12.9% difference between the projected fully loaded cost to deliver an hour of therapy supports and the current NDIS Price Limit for the 2024-25 financial year for the four major allied health disciplines.
• For Psychology Services, there is a 16.6% difference between the fully loaded cost to deliver an hour of Psychology supports, when compared to the current NDIS Price Limit for the 2024- 25 financial year.

Professional bodies

Allied Health Professionals Australia submitted that the price limits for therapy should be raised to reflect cumulative indexation since 1 July 2019 and suggested that from 2025, price limits for therapy supports should be automatically indexed.

Allied Health Professionals Australia described rising business costs (e.g. wage market rates, rent and utilities, supplies, fuel, consumables and equipment, travel, insurance and other operational expenses).

“Our members’ therapy support businesses tend to operate at a small scale, and they therefore have limited infrastructure and resources and operate on thin margins. There is little possibility of further ‘efficiencies’ within small and solo practices, without compromising on the amount or quality of service.”

Similarly, Australian Physiotherapy Association noted that its members find themselves struggling to balance the need to support their staff in a context of rising cost of living by increasing wages while trying to keep their own costs under control.

66 These participating provider organisations represent an equivalent of 18% revenue across the therapy supports market.

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9.4.2 NDIS providers offering support for early childhood supports and to non-NDIS clients – prices, appointment durations and fee-setting considerations

The Provider Consultation Paper asked providers if they offer therapy supports/early childhood supports to non-NDIS participants. Providers were asked about the proportion of NDIS participants and non-NDIS participants they service, the typical duration of appointments, and if there are variations in prices. Providers were also asked how they determine the hourly rate charged for NDIS participants and what factors they consider when setting different rates.

Providers

The majority of provider submissions responding to this topic reported providing therapy support services to NDIS clients and other segments of the care and support economy (such as private clients or other insurance schemes). The proportion of NDIS participants serviced by these participants ranged from 25% to almost 100%, with more than half of these providers having a client base that was 70% or more NDIS participants.67

Appointment durations reported by providers were in many cases the same for NDIS participants as non-NDIS clients. Many providers explain that appointment durations are tailored to the needs of a client, regardless of whether they are an NDIS participant or not. Other providers reported differences in appointment duration due to the complexity or reporting requirements for NDIS participants, and a small number of providers indicated that they billed NDIS participants for this non-face-to-face time.

“Our appointment length is determined in accordance with the principles of evidence-based practice, considering a client’s needs/goals, family commitments and research evidence as to the intensity and frequency of intervention. Therefore, there is no

67 Noting that some providers support only NDIS participants.

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distinction in appointment duration based on whether a client is an NDIS participant or private client.”

“30 or 60 minutes non-NDIS. 60 minutes for NDIS clients who are usually more complex with multiple co-morbidities and increased liaison time with involved parties including other therapists, SC, equipment suppliers, builders etc.”

Provider submissions outlined a range of pricing practices. Most providers reported charging NDIS participants at the price limit, while a small number reported charging below the price limit.

Many of these providers charge non-NDIS participants the same fees as NDIS participants. Other providers reported a price difference between NDIS participants and non-NDIS clients, with some charging more for NDIS participants and some charging less. Reasons for charging different prices varied widely. For example, some providers reported:

• NDIS participant complexity or additional administrative costs associated with providing services to NDIS participants as a reason for charging NDIS participants more.
• The lack of change in NDIS therapy support price limits over the last five years as a reason for charging non-NDIS clients more than NDIS participants.

Professional bodies

Feedback from professional bodies relating to differences in appointment durations was mixed. For example, the Australian Psychological Society stated the median duration of psychological appointments for its members is 60 minutes for both NDIS participants and non-NDIS clients.

The Orthotics and Prosthetics in Australia noted that while some considerations for fee-setting are the same, there are also NDIS-specific aspects:

“The main difference is the report writing component for NDIS participants which is significantly more time burdensome and almost triple what is required by most non-NDIS clients.”

9.4.3 Unique costs in providing early childhood supports for NDIS participants

The Provider Consultation Paper asked providers about unique costs of providing early childhood supports for NDIS participants.

Providers

Providers outlined a range of unique costs of providing early childhood supports, with 85 (or 33%) of provider submissions responding to this question. Most providers

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describe this group of NDIS participants as more complex, compared to other early childhood clients who are not eligible for supports under the NDIS.

When describing early childhood supports for NDIS participants as more intensive and requiring more time, the following additional activities and costs were noted:

• collaboration and liaison as part of team-based approaches, with an appointed ‘Key Worker’68
• delivering supports in natural environments, such as at home or in school settings, which requires travel that can exceeds established caps
• specialist skills and professional development needs, often resulting in a need to pay higher salaries
• mandatory reporting obligations, such as writing reports related to funding allocation decisions, risk assessments, reporting to the NDIS Safeguards Commission and making Child Safe notifications.

Professional bodies

Professional bodies noted similar costs of providing early childhood supports for NDIS participants. For example, the Australian Physiotherapy Association described liaison and communication with the care network, support to the family, the expertise and complexity required, extended appointments, the service environment and administrative load.

Dieticians Australia also noted other unique considerations when providing early childhood supports, such as the requirement for specialised training materials and resources, and tools designed specifically for young children with disability:

68 Under the eight principles of best-practice early childhood intervention, a family works together with professionals to form a team around the child, communicating and sharing information, knowledge and skills. One main person, called a key worker, works with the family. NDIS, Early Childhood Approach – a guide for professionals, p 4.

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“Many children with disability require specialised nutrition and dietetic support. The progression can be significantly prolonged, some requiring lifelong assistance. This necessitates a flexible and long-term funding approach, acknowledging complex feeding needs of each individual child.”

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