Disclosure Log

Document 22

For Official Use Only

Pricing Reference Group, Item: Item-Number: Document Number Date: March 12th, Year: [Year]

Matter for Noting - Annual Price Review — Summary of Submissions

Purpose:

• To inform Pricing Reference Group on main concerns raised from submissions to APR.

Recommendations:

• Note major concerns related providers’ participation and other parties who submitted their views during APR process;
• Develop a more detailed summary report as part draft findings document due next month (March).

Background Information:

A total number of ninety-six (96) valid submissions received before February’s closing date; forty additional late entries accepted shortly after deadline submission period concluded. Figure below illustrates response distribution across different chapters within Issues Paper:

Chapter-wise Breakdown:

• Core Supports (Chapter #): Received nearly quarter share responses with most comments regarding Disability Support Worker Cost Model issues,
• Capacity Building (Chapte r5) second highest concern mostly therapy-related complaints despite minimal service claim cancellations (θ%); Plan Management (#6) also popular topic focusing mainly low pay claims among plan managers,
• Travel (#10), group-based supports (#4), participant flexibility & provider administration (#2), establishment fees (#11) each garnered less than 10 percent overall feedbacks respectively. Geographical challenges faced by participants living in outer regional or remote areas were noted, while non-pricing issue discussions constituted under 10%.

Disclosure Log

Pricing Reference Group - March 12th, Item 3.2

Figure 1: Issues addressed in submissions

Issue	Percentage
Core Supports	>20%
Capacity Building	~8-10%
Cancellations	<7%-<8%
Plan management	<7%-~8%
Non-Pricing	<7%-<8%
Travel	<5%-<6%
Groups	<5%-<6%
Flexibility/Admin	<5%-<6%
Establishment fees	<5%-<6%
Regional loading	<5%-<6%
Geographical	<5%-<6%

Figure: The chart above shows issues related to different categories and their corresponding percentages.

Increasing flexibility for participants & reducing administration (Chapter 2)

Common pricing administrative issue:

a) The Support Catalogue is too large and complex; many providers asked if category codes could be rationalised; b) Payment delays were complained about but are not considered as direct price-related issues per se, c) One provider suggested removing all price limits would reduce the burden of administering prices, d) Increased fungility was called out especially regarding transport. Activity-Based Transport should alleviate concerns with this aspect from July onwards in 2020., e) A participant’s guide request aimed at better budget utilization by providing more clarity on available supports.

Core Supports Chapter (

3rd chapter) Three-quarters’ responses focused heavily around DSW efficient cost model, covering over a hundred aspects within it.

DISCLOSURE LOG

FOR OFFICIAL USE ONLY

Pricing Reference Group | Item: Item-Number

|:–||- 5.2 & Submissions argued that the 10% allowance for overheads in the model was too low; commonly cited figures are between [20%,], or [to], [25%;]. Although there's wide range estimates from [15%, ]through to[35%.]; 5.3 & Many submissions stated an assumption, where permanent staff is at least twice as much (80%); casual workers make up no more than one-fifth (20%). Some said it would have been better if they were reversed.Until recently, these assumptions wouldn't matter overly because actual cost per type has remained similar. However, Fair Work Commission decided on December last year (year not specified) increase relative costs employing casual workers during weekends and public holidays; 5.4 & Assumed utilisation rates within models above a90%` threshold were also criticised being unrealistic due higher training costs associated with increased use of casual labour. Instead around 80% seems realistic; 5.5 & Several claimed supervisor-to-worker ratios used by this model were also considered insufficiently high, 5.6 Conversely fewer providers claim Temporary Transformation Payment(TTP), Agency originally expected. This indicates existing price limits sufficient many providers prefer undercut less efficient competitors without claiming TTP. For example All About Caring submission: “our organisation generally had issues hourly rate NDIS set for types services we provide; we did need charge the TTP nor travel component between service to service.”; 5.7 Other issues raised unclear when applying high intensity price limits, some respondents do not apply them finding too difficult 5.8 A couple submissions requested Price Guide uses same shift definitions as SCHADS Award.;

Group-based core supports Chapter-Number)

Common theme trying calculate ratio was challenging Ratios can change daily basis especially when actual may unknown until day itself;

Request alternative allowing group providers Non-face face time instead fixed allowance pricing formula present.

Allowance capital cost centres claimed inadequate particularly more specialised groups larger ones. Submissions called clearer guidance on cancellations (Agency proposing introducing program bookings whereby participants book block sessions pay all even if they don’t turn up should help with regard cancellation.)

Capacity building supports Chapter Number)

Several providers wanted consumables be claimable capacity-building therapists most common proposal separate Consumables budget item.

Disclosure Log

FOR OFFICIAL USE ONLY

Pricing Reference Group - Item 3.2 | Date: March 12th , Year : 2020

Section 6.1

Interestingly there are more comments about price limits for therapy services compared with core support services as mentioned under Chapter Three. The therapists who have an award arrangement get paid varying rates during evenings weekends or public holidays delivery service . Many submissions indicated they do not offer Capacity Building outside Monday through Friday from nine am till five pm because it is financially unviable given current pricing limit versus staff cost.Furthermore capacity building often benefits most at home / in community which frequently occurs out side mondays and Fridays between ten hours a day time period.

Section 7.5 Most Therapy providers claimed that indexation on price limits currently inadequate.Submission argued gap narrowing between current arrangements increases costs under Award EBA agreements was negative many instances actual cost delivering service against price limit.

Section 7.6 Not unexpectedly, common response was that Capacity Building prices too low.Little concrete evidence furnished to support this other than time above stated.

Section Plan Management (Chapter Six)

Most respondents argue funding insufficient plan management.Most also argue flat monthly fee does reflect different participant needs.The fixed monthly service fee doesn’t account complex plans running over year new participants requiring additional effort.Suggestions changes included transaction volume based pricing loading rate $over one hundred thousand dollars combination of monthly fees plus additional fees based value ####### Section 8.3 One provider requested twelve dollar per participant when the guide changed. ########## Section Another common request if Participant switches managers claim second establishment fee against their plan should be allowed as will facilitate switching both competition satisfaction . ############### Section Providers complained indexation rates for plan management services are insufficient compared with other professions increase equates two dollars per month or twenty four annually. ################# Section Plan Managers said they should bill travel non face-to-face time capacity building training in administration and supports, ########################### Section However comments about building capacity within plan management were notable absence noted less than percent had such capacity building on their plans.

Chapter Seven Classifying Regional Remote Areas

A couple providers requests towns losing remote classification under Modified Monash Model MMM2019 allow transition lower price levels up to a period months.

Disclosure Log

FOR OFFICIAL USE ONLY

Pricing Reference Group - Item 3.2 (MR25/01967 FOI) Date: March 12th Item: 3.2

Section 9:

a few submissions questioned whether disability services could use MMM system effectively; it works passably in cities but inadequate elsewhere. bone provider noted thin markets don’t always match classifications; some exist even where there are no other regions. costs outer regional areas dealt better through commission rather than raising price limits slightly, increase time/distance limit is also a priority.

Cancellation rules Chapter 9:

predictable providers argued that cancellation periods should be increased while participants argue they need to shorten them. one submission put this eloquently “Where exactly do you find replacement participant? It’s not like calling plumber.” some CRM pays less, creating bad debts for providers who often empathetically charge nothing if clients fall ill and under one percent claim cancellations indicating many choose free service instead. aparticipants found complex with high costs of travel which can cause friction between parties involved due low understanding or traffic issues leading to claims exceeding maximum allowed distance impacting on choice and control over delivery. many respondents have ceased delivering beyond claimed distances as such would impact negatively on their business operations.

Disclosure Log

Pricing Reference Group - March 12th, Item: Item

Establishment Fees Chapter [Chapter]

Of those responding all agreed on cost associated with establishing support.

• All respondents agree it’s appropriate but two felt current rules were fair while others argued claimable whenever participant changes provider or has updated plan.

Consensus:

• An amount should cover all supports including multi-disciplinary services like supported employment etc., which are complex in terms of client setup;

Main issue identified regarding price limits being how total apportionment affects first vs second plans/providers; most providers believe this is consistent across different setups so amounts reflect accordingly,

####### One NSW provider noted due early NDIS rollout participants have already exhausted their entitlements making establishment fees irrelevant for them.

Disclosure Log

FOR OFFICIAL USE ONLY

DOCUMENT 23

ndis Delivered by the National Disability Insurance Agency

National Disability Insurance Agency (NDIA) Pricing Reference Group Minutes

• Date: Thursday 12 March 2020 | Time: 1030 -- -1250 | Attendees | |-| || Chair || Position || Liz &47F-personal General Manager Provider and Markets &&&[PricingReferenceGroupMembers]&& Independent Member Graeme AM Jim PSM Julie PSM [-ParticipatingobserversnominatedbyNDA’sCEO]& Participating observers nominated by NDIA’s CEO | Position | David Cullen Chief Economist Sarah Scheme Actuary [-Secretariat]& Secretariat | Position Scott Director, Price Regulation Unit . Formalities

DeclarationofConflictsOfInterest By:Chair For:Noting Format:`Verbal ThePricingReferenceGrouPNOTEDthatGraemelAT-Pers is:

• a member oftheBoardoLifeWithoutBarriers; • amember othe Board of Summer Foundation; •amember ofte Board Joblife Employment; •a memberthe Board AttitudeFoundationand •aparticipantofthenationalDisabilityInsuranceScheme( NDIS).

ConfirmationofMinutesByChairsForDecisionFormatPaperThePricingReferenceGroupENDORSED the minutes oftheprevious meeting (PRG-20200220 Item 1.3).

Updates

UpdatebytheChair By:Chair For:Noting Format:VerbalTh e Pricing Reference Group NOTED th principles as set out in ’ PRG-201200220 `Specialist Disability Accommodation’ were agreed to b yNDIABoard.

TTP Market Benchmarking SurveyUpdate By:Scott For:Noting Format:`Verbal Th e Pricing Reference G roupNOTEd key findingstodate forT TPBenchmarkingsurvey.

The Pric ing Referenc e Gr oupNOTE D thatTT PBenchmarki ngSurveywouldhaveagrace period until Junefor providerscomplianc conditions.

Disclosure Log

Pricing Reference Group - Meeting Minutes | March 13th and April 7/6/2025

Annual Price Review

Provider Presentations Discussion

The Pricing Reference Group DISCUSSED provider peak presentation session held Wednesday.

• By: Chair
• For: Discussion Format: Verbal discussed

Summary of Annual Price Review Submissions

Discussion: The PRG discussed preliminary findings from ‘PRG - Item 3.2’.

• By Scott
• For discussion Format Paper-discussed

Efficient Cost Model for Disability Support Workers

Discussions included a paper on efficient cost model disability support workers’ costs, with David Cullen’s input noted as well.

• By David Cullen/Scott
• Format: Paper-discussed

Establishment Fees – Initial Findings

Initial discussions covered establishment fees arrangements in place at the time (item not specified).

• By Dominic
• Format: Paper-discussed

Major Items

Modified Monash Model and Geographical Reclassification

Agreed to recommend through CEO adoption MMM classification system future updates released Health Department. Decision agreed upon by group. note further consideration around isolated areas adjustments required.

Agency.

Insurance

Disability

National

Released information:

The act that was

Disclosure Log

Term of Reference for the APR	Discussion
ηλeta κ &ν&ξ &ο &μ &ό &ύ &ώ &Ϗ &ϔ &Ϛ &ϛ &ϝ &Ϟ &ϟ &ϥ &϶ &Ϻ &ϻ &ϼ &Ͻ &Ͼ &Ͽ &Њ &Ћ &В &И &Й &К &Л &М &Н &О &П &Р &С &Т	Margin

• Model Assumption 2.0%
• λeta κ ; Average .5%| | Overheads |
• TTP survey indicates overhead assumption is only major risk Model assumption: 10.5% Average: -7.7% Standard Deviation: Skew (very balanced) Kurtosis (- very concentrated about the average)|

Disclosure Log

Term of Reference for the APR	Discussion
	The cost overhead assumption in the Cost Model should not be changed at this time – parameters will need reconsideration when future economic conditions have resolved itself.
	Permanent/casual staff ratio assumptions within the model must change from current levels;
	Minor amendments are needed:
o Change award loading assumptions per Saturday and Sunday with recent Fair Work Commission decision taking effect July 07/2020,
o Increase Long Service Leave uptake recognition portable arrangements introduced some jurisdictions (up to full).
	TTP reduced as planned on June 30/2020; continue pressure towards improved efficiency through further reductions over next year, including a reduction down to $650k effective January 04/2021.
	Review methodology price controls group-based supports derived from those used one-to-one services.
	General agreement providers consulted that they now ready move standard hourly rate plus right charge non-face-time support.

Recommendations

• Align hour limits between groups and individual service rates.
• Allow billings for non-face-to-face supports by provider or group.
• Simplify Price Guide only publishing 1:1 hourly rates. If offers other ratios apportioned accordingly rather than billing directly based upon it. | Determine indexation arrangements capacity building supports therapy included in these reviews. || A review of prices should be conducted every two years starting Annual Price Review. Prices indexed annually thereafter using AWI. || DSW indexation applied all services delivered by DSWs; || Maintain current link to AWI for therapy services; || Follow up with TAC about benchmarking study done by them. | || Should different time/day-specific pricing apply certain types of capacity-building services (e.g., therapists)? || This matter requires examination within the next twelve months focusing on best practice interventions ECEIs etc.. | || Determined whether indirect consumables provided participants as part cost recovery possible? || Already built into hourly rate, || Use analogy tools trade make clear we are not talking specific participant items e.g wound dressings just scissors tape used nurse.

Agency.

Insurance

Disability

National

Released information:

The act that was

Disclosure Log

Term of Reference for the APR Discussion Review establishment fee arrangements Establishment fee is still set at the same level as when scheme commenced.

• Establishment fee payable once; providers need establish clients in system every plan Addressing issue helps address complaint about overhead allowance being insufficient costs absorbed into overhead RECOMMENDATIONS The Price Guide should be amended from July so that: o Establishments are indexed each year with indexation rate for Disability Support Workers o A lower-level establishment claimable second and subsequent plans recognize provider’s establishing service booking etc o Establishment fees billable any who provide significant amount personal care/community access participant (say more than hours a month) Planning arrangements take account to pay establishment fees subsequently established value

Estimated impact of proposed 2019–20 Annual Pricing Review and other changes

Summary of Key Results

The following table summarises the impact of each pricing change in projected participant costs.

Section	Proposed price change	Impact (%)	Impact ($ million)

IMPACT OF PROPOSED NEW SUPPORT ITEMS ON PROJECTED 2020-21 PARTICIPANT COSTS

| Impact (%) | Best | Low | High | |-|-|-| |# Proposed new support items Estimate Scenario Scenario |

Psychosocial recovery coaches support items # Agency.

New hearing support items # Insurance

Total impact of all proposed new support items # National

Annual Price Review (APR) - Ongoing Scheme Assessment (OSA)

Released: Page text

Proposed 2019-20 annual price review

Non-labour costs for provider travel³

It is proposed that on July 1st 2020, providers will have access to claims related with non-labor expenses associated within transportation arrangements linked directly towards each participant’s location. These are additional charges beyond worker time when traveling between participants or capacity building providers returning back after completing all tasks at hand.

<div class=‘table’ style=

Disclosure Log

travelling further distances more likely toll roads etc The second sensitivity scenario shows impact increasing average annual costs %50.

Proportion providers claiming travel

• Providers are assumed claim non-labour costs provider travel at different rates according support type being delivered This because all will travel provide participants e.g therapy provided clinic participants bear cost whereas providers likely claim their when in home.
• Reliable data currently available determine proportion who claim reliable so range reasonable assumptions have been made represent best estimate low take-up high take-up scenario .
• Support types that eligible claims provider travel SIL SLES etc assume has zero percent providers claiming travel summary assumption table: | Assumption | Best Estimate | Sensitivity: Fewer providers claim for travel | All providers claim travel higher cost | | — | — | — | — | | Annual non labour per worker $1,250$1,250$1875| | Claim rate Non Labour Costs Attendant care (non-SIL) 90% Community & social activities Individual Group based Therapy supports* - individual group-based * Includes early childhood intervention supports Results below estimated increase Scheme as result allowing providers to claim the non-labor costs of provider travel is between million and million ($m ) FY2020/21. Estimated cost impact Fy2020/21 cost impact (% total scheme cost) Best estimateSensitivity Low claim rate High claim high cost Note above do not include effect COVID price loading on selected supports If this was included would be reduced Other considerations

Disclosure Log

The data available for this analysis has not been robust and only five days were available to undertake the analysis; hence roboust monitoring after implementation is required to better understand impacts. Risks around these costings are that annual non-labour costs for provider travel will be higher than expected; furthermore there risk providers will change their behaviour once they can claim nolabour travel costs rather absorbing these into overhead For example may choose longer distances or incur more incidental such as parking fees road tolls There also risks related guidelines claiming nonlabour transport Price Guide Providers can significantly higher if have vehicle modified accessibility potential rules exploited if make minor modifications vehicles order claim rate Hence audits should undertaken ensure followed appropriately The benefits changing it encourage more provide deliver supports participants community mainstream environments clinical settings particularly important early childhood intervention evidencebased research shows therapeutic delivered home improving outcomes children clinic based Furthermore, generally less cost compared so encouraging increased provider travel reduce overall Scheme long term It recommended work done better understand how providers both labour claims nonlabour costs travel monitor changes over time This could through TTP surveys improve on payment claims provider travel # Efficient Cost Model The assumptions parameters underlie NDIS Cost Model Disability Support Workers (cost model) reviewed Annual Price Review following recommendations:

• Changing award loading Saturdays Sundays line recent Fair Work Commission decision takes effect 1 July already costed OSA6 Permanent/casual staff ratio assumption in the from with of Benchmarking Survey Increase Long Service Leave to uptake recognising introduction portable arrangements jurisdictions. decrease assumed workers compensation premium percentage observed health and sector. Note this equal average across cost model for Disability Support Workers has been reviewed for the 2019–20 Annual Price Review, and the following changes have been recommended: Award Loading Assumptions for Saturday Sunday Line Recent Fair Work Commission Decision Takes Effect 1 July Already Costed by the OSAA See file note attached Appendix B Estimated impact proposed changes SCHADS award dated September 2019.

• Increase the assumed overheads percentage from 10.5% to (12)%to better align withtheestimatedoverheads officient providersinthesector.

---

• Increase thsupervisionratiofromt11 t o15linewiththetTTPBenchmarkingSurvey.

• Increasetheprovisionofallowances(other than travel allowances)forsupport workersandsupervisorstfomO%totl%base salary,in linewiththeadveragelevel observedinthettP Benchmarkingsurvey. The temporary transformationpayment(TTPloadingwillalsobereducedascurrentlyplannedfrom7 .5% to $6$on July onJuly 2020 , inorder continue pressures towards improved efficiency.The impact onscheme costsfork each changescost model havebeen estimated based actual cash payments made for supports deliveredby disability supportworkers over year.This payment information is used todertake care price limits, noting that inkindpaymentshave been excluded analysis.Itisassumedthatinkindpaymendsonot havematerialimpactdespite large proportion of them being related attendantcare as pricesfor thesesupports haver already agreed Full Scheme bilateral agreements The table below shows proposed changesto efficient costmodel areestimato increase total scheme costs by million ( )FY the assumptionchange largest impact costs increases worker to line manager supervision ratio from which decreases scheme costs by Thisincrease reflect results TTP benchmarking survey also noting nonface-to-face claiming rules permit some interactions between supervisors and staff be claimed directly when they relate specific direct care needs participant | Estimated incremental cost impact | FY/(21)cost ((impact ($m)) | %oftotalScheme costs | |- |- -| | Changes award loading | redacted | .36% | Change permanent/casualstaffratio assumptio n | - redacted- |.28% | Changelongserviceleaveuptakesumption | 184 | .0.85% | Changer workerscompensation premium assump tion | -.176 |-.9%.82- | Change overheadloading assumptions | +204+ |+.95%-. | Changedsupervisionratiosassumptions | --373-- |---1.-74-% | Changenon-travelstafallowanceassumpti on | 96 |.45% totalimpact | $71$ | `% of total Scheme costs:``0.33%%```In addition, the impact reducing ttp loading estimated million ( )FY payments during year However this not included estimate scheme above as payment reduction already allowed projections sustainability AnnualPriceReview_201920_OSA_Revie w_v2 Page 163 o f(1049)“ has_redactions“: false, “has_table”: true, “is_low_confidence”: false, “wording_changes”: {

Disclosure Log

Geographical classification - Modified Monash Model\nchanges

The NDIA uses the Modified Monash Model (MMM) to determine regional, remote and very remote areas. In general, price limits are ( +{40}% ) higher in remote areas and {50} %higherinveryremoteareas.Thereisno additionalloadingappliedforsupportsinmetropolitanareassregionalcentresorregionalarasGeographiclocationsforthepurposeofpricingcurrentlybasedonthe2015 MMMandnotthemost recentMMM.ThePRUarerecommendingtoupdatetheNDIAs MMclassificationsinc accordancewithth e2019MMMclassificationreleasedfromthedepartmento fHealth.Thenetimpactmovingtomethemmm2019 classific ationise stimatedtobeadecreaseintotalplanbudgetsofo.{0}{0}% or$.milionred uctionprojectedparticipantcostsforthef year).There isonebehaviouralaspecttoconsiderforc thischange.Thoseparticipantsinar easwhoarcurre nty receiving funded supports with ther emoteorver y remoteloadingsaccording t ommm 2015 willhave theirgeograph ic location changedton on-remoteara under m mmwill likely receive a reductioninth edollaramount oftheir fundingoplan review. Thepriceofs upports shouldalsoreduc by thesamepercentage amountasthefund ing.However,thereisan riskthatthrougheither participantorp lanner behaviours,the planrevieww illtry to adoptthesame dollarvalue ofs upport frompreviousplans.

Group ratesProvidersgroup-basedsupports currentlyuse grouppricespublishedinthen DISPriceGuidetocharge participantsforsuppor tsThe ratiosofworkers toparticipantsincluded inthe priceguideare{1:2},{3}, {4}and{5}, andwheretheactualsupportratio differsth eproviderscan discussanda greeonpricingwith th ep articipant.Providerso fgr oup-basedsupp ortsa renotpermittedtobillfor non-face-to-faceservic es ast he hourlypricelimits forthesesupportsin cludean allowance forn on -face-t face services.Currentlythis equatestoa dditionalsevenminutes perhourforeachparticipantint h egroup.Itisproposed thatfromJuly( +{} ) , then following changes be made t o pricingforg roupbasedsuppo orts:

Group prices will no longerbe included aslineitemsi nther PriceGuide.Instead,p rovid erswillclaimat ther hourylprice limits fo r:(+{{}} :1), apportion thecosts between themumber ofparticipantsinthegrou p. Providersogrup based supportswil labe ableto billfonon- facet tofacesu pportsThesechangeswillsimplifythead NDISPr ice Guide,ands w illalign pr icin grulesfo ri ndividualag rouppro vidersbyallowinggroup providerstoc hargeforn onfaceto faceservices. it hasbeenassumedthat this wil nothaveam aterialimpactons chemecost sasthe proposedch anges simplyremovetheproxy costsfn onfa cetofacessuppor ts fromthegr ouppricesandallowsthe provider toc laimthemasa separateexpense.However,t hereisan risktha tg ropprovidersmaycl aimfornon-face-

AnnualPriceReview_201920_OSA_ Review_v27Page{164}o f {1}{0}

Source page

to-face supports in excess of assumed seven minutes per hour per participant which would result in an increase to overall Scheme costs. Sensitivity scenarios are provided below showing increases as additional non-face-to-face support for group-based activities: costs rise with extra hours spent on such services: 3-5 minute increments cost between $65 million and $)108m over FY’20/21 financial period, group rates sensitivity analysis shows payments ($m): Total projected scheme costs = 21%, Group based support payment = `.7% impact from more time at non face-to-face service delivery: disability insurance schemes show a range of potential impacts depending upon how much longer people spend there; some capacity building price limits indexed annually using AWE growth rate; however DSW’s have different indexing rules, calculated differently than therapy professionals (using labour & capital costs). potential impact if all CB items were indexed under DSW pricing instead is shown here.

Disclosure Log

Impact Of Change In Indexation Rates For Capacity Building Supports Delivered By DSWs

| % of annual payments (CY;{2019})| Gap in indexation rates between {DSW} and therapy | -0.{5}% | +0.% | |-:|–:-||-::–::-| | Support items delivered by Disability Support Workers ({DSWs})¹| +3.% |-0._{0}.7% || | plus support items that may also be delievered by {DSWS}^{<a href=“#fnref:{footnote}:” id=“fn”:“>2}| +8.% |-0.._{0}.9% &&&

Note:
the impact of $<$em>$+$0..${6}$%$ is considered as 'best estimate'.

• If price limits were 0.$-$_{0}.5$-% lower than the therapy, then participant costs would decrease from a range to ${0.}{7}-<{0}>$. This scenario reflects approximate indexation rate calculated based on recent inflation rates.
• The cost increase if DSW prices are higher at an additional percentage point will be between ${0} and ${7}.{7}, which represents approximately $1.{3}-{7}.{7} ext{ million for }\left(20-{0}\right)-{1}${ projection year).

The analysis indicates this change in indexing has no significant effect.

DISCLOSURE LOG

amounts have remained unchanged since Scheme inception and is only payable for participants new to the Scheme (i.e., on their first plan). However, providers have overhead ext{cost} swith everyparticipantnewtoservicesservices-regardlessofplan- number-astheyneedestablisheclientsinthesystem(e.g.setupservicebookings).Extendingtheestablishmentfeetobeavailableforanyprovider^10regardlessoftheparticipant’splannumberswouldhelpaddresscomplaintaboutoverallowancebeinginsufficient^11. tomodelimpactthisrecommendationthree scenarioswereconsideredinachescenariothemajorityor82%allactiveparticipantsonsubsequentplansCore-DailyActivitiesCapacityBuilding-SocialCommunityand Civicassumedreceive overhoursupport.However, thisisconservative assumption; there will be some double-counting as participant may receive both CoreDaily Activities Capacity Building Social Community Civicofteselectedparticipanconside

• ** 2 change provider with a new plan anotherchange during same (“Low” scenario) -5 change provider witha newanother2.5duringsame(“Medium”scenario) -** * 10 change provider with anewanother5during samem(“High”scenariotableshowsthatestimated impact on annual participancosts ranges from to (ors million for the projection year). IMPACT OF EXTENDING THE ESTABLISHMENT FEE TO NEW CLIENTS ON SUBSEQUENT PLANS Projectedparticipant costs Low Medium High Impact (%) Impact ($million) Note:the “Medium” scenar is considered best estimate.” Thefollowingtableshows thatthetimatedimpactannual participantscostsrangesfromto($$fortheprojectionyear).Thus,theimpactofthis recommendation participant costsexpected immaterial.

Program based supports ItproposedthatthenDISPriceGuidebe amended Julyallow providersenterinto contractswithparticipants provision of programsuppto weeks.Whereaparticipant doesnotattendprogram(part programtheyarebilledas though they did attend-thatis, this not cancellation as long asprovider had capacity deliver support.decreasesadministrative burdenprovidersallows them better manage workforce.^10Supplying over hours week personal care and community access supports participant.^ `^These are currently absorbed overhead providers. AnnualPriceReview_201920_OSA_Review_v2 Page fo 49

Disclosure Log

It is not yet clear what the guidelines will be to determine whether a support classifies as a ‘program of support’ however it is expected that it will cover most group-based Core – Assistance with Social and Community Participation supports and may also encompass supports provided in an Australian Disability Enterprise. Payments for these supports made up approximately 7% of total Scheme payments in the to December . It is not expected that therapy supports would classify as a program based support. it is expected that this change will have no material impact on Scheme costs Under current Price Guide, providers have been able pass cancellations other people i.e instead charging rate they could charge rate participants who attended In case proposed change simply divert cost cancellation from those cancelled However there risk until now providers chosen absorb costs rather than pass them onto others If new rules relating Program Based Cancellations result increase scheme costs This has not been due lack data timeframe available analysis.

Disclosure Log

Proposed New Support Items: Psychosocial Recovery Coach Support Items

Background:

At the October COAG DRC meeting on September 3rd [year], agreement was reached regarding introducing new support items related to ‘Psychosocial Recovery Coaching’. Six such items are planned additions starting July first year. The support items will adhere national pricing caps subject remote loading conditions; however they won’t include temporary transformation payments or COVID-19 loadings. Competencies require tertiary qualifications and two years’ experience within mental health-related work without requiring allied professionals status. The PRU assumptions suggest daytime hourly price limits at $78.17 compared to $63.03 for Disability Support Workers delivering Level Three services daily, while Allied Health Professionals have a limit set higher than both these categories combined ($98.06). It is also proposed that an Activity Based Transport item be added under relevant category as well due to potential risks involving Coordinators in same registration group with recovery coaches who cannot bill activity-based transport currently.

Disclosure Log

self-management, lower plan management costs, and contribute to social and economic participation and higher levels of throughput for people with psychosocial disabilities in the Scheme. This would mean that the introduction of the proposed support items should help reduce long run outlays for these participants. While the PRG paper’s anecdotal discussion does not mention any evidence-based outcomes, the approach has strong support from the community mental health sector and state and territory governments.The recovery approach is particularly suited to the episodic nature of mental illness over a person’s lifetime and other literature suggests recovery rates¹⁷of over50%. Itis therefore importantthatthefundedsupportsandoutcomesforparticipantswithapsychosocialdisability¹⁸aremonitoredovertime.Thiswillassistinassessingevidence-basedoroutesassociatedwitheusepsychosociaerecoverycoaches.Inaddition,thismonitoringwould assistinthearlydetectionofoanybehaviouralimpactsassociatitheimplementationofthesenewsupportitems.Thereisanexpectationtha roleofpsychosocialrecoverycoachswouldreplace support coordinatorsfoparticipantswitspsychosocial disabilityhowever there may beother behavioural factorswhichmeanaduplication othatrole especially given thoses will beseparate supportsitemsintheNDISPriceGuide.Monitoringwilhelptobetterunderstandthesebehave ous.UnderCOVID-19environment,andgiventherelativeimmaturityoft he market¹⁹,theremaynotbesignificantinitialtake-upofthesesupports in thesehortertermfromJuly2020. The main control mechanism relatingtofinancial sustainability is ability to limit plan supports totypical Support Package of participants particularly relation capacity building component.Given that TSP guide rather than rule this approach risk mitigation would need monitored.Based above discussion, expectation change cost-neutral shorter term with expectations financial costsavings medium longer term.Howeverthis likely depend behaviours planners providers potentialparticipants.Potential positive impact overmediumlongermispremisedonachievement longter outcomes adoption recoveryapproachand shouldmonitored.Noformalcosting proposal undertaken although once experience say months time formal costing appropriate.## Hearing support items The PRU has proposed introduction8 new support item related provision hearing aids audiologistsupports NDIS Price Guide from July 2020.To assistincostingimpactfollowing information provided:

• Advice Director –Hearing Team Subject Matter Experts and suggests about additional participant gethearingsupportsnDNIDISPplus Footnotes:Recovery here refers person no longer having mental ill-health symptoms not taking psychotropic medications are limited only one several domains.Including those participantspsychosocial disability secondarydisability.Anecdotally market delivery psychosociaerecoverycoachingsupporthasnotbetter developed probably less welldeveloped generalmarket for suppor delivered by disabilitysupportworkers. AnnualPriceReview_201920_OSA_Review_v2

DISCLOSURE LOG

potentially another 2,000 to* *3,***000 who are currently privately funding their hearing needs as they are not eligible for the Commonwealth Hearing Services Program ‘HSP’. There will also likely be some participants unknown that may request supports above what can be provided by HSP. In addition, the following points are noted:

• Currently about 1,*5,****00 active participants have a primary disability and these participants an average package $15k although on average utilised approximately .6.
• The HSP included within scheme due to ‘cash out at June . The in kind offset estimated over million for financial year should used any direct increase plan costs implementation new support item codes.*
• Table shows projected number future participants with impairment according Office Scheme Actuary latest projections These expectations additional identified between July and June .*

DISCLOSURE LOG

If there were to be higher numbers of participants with a hearing disability accessing the Scheme, then it is likely that the average cost of the new supports will be low relative to current plan sizes. The key risk is that the number of participants with hearing impairment entering the Scheme is higher than expected.The adherence to internal guidance around managing the eligibility criteria for people entering the Scheme with a hearing impairment should be closely monitored.Costings indicate that if an additional\n \t \n5{,}000to { }$10{{ , }}000participantswereentertheSchemewithahearingimpairmentthenthiscouldequatesto\nanadditional $0.{ }% {{}} % to ${}{ .}%ofSchemecostduring${{} }2023-{-}$In terms oftprojected participant costsfor thenearestyearthiswouldbe${}{ }millionto${}{ }. million.

Appendix A – Methodology for estimating non-labour costs for provider

travel

The table below shows the assumed travel time per day and percentage of time spent travelling based on a $1,250 annual provider travel allowance. | Assumed travel time per day | a | b| c | d| e | f| g | h| i | j| k | l| m | n| o | p| quidated travel allowancenull provider travellallowanceevel ttional Disability Insurance Agency. nual provider travel alloaave cost of travel per kmAverage km travelled per yearAssume average speed kmpheverage hours traileage working hours per yeannumber working days per yearsupport time spent travelling (5÷6) day Average annul provider traverAllowance$1,250assumed cost otravel per km$085average km traveled per yeaer(1+2)1，471asumed averag speedkmph40average hours travaled peeryear37average workeg hours peryearege minutes travaeled perdayNumber workingdaysperyear% supporttime spenteing to claim thenonlabourcosts ofprovidertraive: Only support types that are eligiblefor providertravels included inthe analysis. These arere:Attendant care(non-SIL),Deliveryof health-related supportsOther assistance with daily lifeCommunity & social activitiesTherapysupports(including ECEI). Calculate the average cost per hour for eachsupport type based on non-remote pricesinthenNDISprice guide(note this istheprice guideneffective from 1 Marchto prior to COVID price loadings). Averages costs persupporype are determinedbasedonthedistributioneach individual suppo line item associatedwiththat supporttype over period JanuaryDecember. Adjust averages costs forth proportion participants living remote areaspayment loadingand very remotes paymentloadingThisis based distribution total paymentsby MMM classificationoverperiodJanuary December Calculated annual costs worker by multiplyingaverages cost perhour by averagedworkinghours year This isthe TTP provider survey total Scheme costs calculated byMultiplying percentage increase per support typetheproportiontotalSchemepaymentsforsupporttypetdistributionactual payments over JanuaryDecembertaken under Freedom Information Act released document20 Note most capacity building will be eligible providers travel(exclude SLES and plan management fees) resulting increases assumed represented changes therapy which represent8% of all eligiblecapacitybuilding paymenAnnualPriceReview_201920_OSA_ReviePage Page 73 of 49

DISCLOSURE LOG

• Adding together the estimated increases across each of the relevant support types.

Appendix B - Estimated Impact Of Proposed Changes To The SCHADS Award Filenote

ImpactofchangesToSCHADSAward_201 This document was released under the Freedom of Information Act (FOI) 1982 by the National Disability Insurance Scheme.

Disclosure Log

Appendix C – Indexation of support items within Capacity Building

TABLE 1: CAPACITY BUILDING (CB) SUPPORT ITEMS DELIVERED BY DISABILITY SUPPORT WORKERS

Support Item Number	Support Item Name	Support Item Description
09_007_0117_6_3 & Skills Development In A Group & Training for the participant in a group of two or more to increase their independence in daily personal activities.
09_009_0117_6_3 & Individual Skills Development And Training & Individual life skills development and training including public transport training and support, developing skills for community social and recreational participation.
09_010_0125_6_3 & Community Participation Activities & Participation in community based activities that build skills and independence.
11_024_0117_7_3 & Individual Social Skills Development & Social skills development with an individual;for participation in community and social activities.
15_037_0117_1_3 & Individual Skill Development And Training Including Public Transport Training & Individual training provided at home for general life skills increasing independence.
15_038_0117_1_3 & Training For Carers/Parents & Training for carers parents caring person disability. \[TABLE 2: CAPACITY BUILDING (CB) SUPPORT ITEMS THAT MIGHT ALSO BE DELIVERED BY DISABILITY SUPPORT WORKERS
Support Item Number	Support Item Name	Support Item Description
-	:-	–
07_001_0106_8_3 & Level I :Support Connection & Assistance participants implement plan by strengthening ability connect broader systems supports understand purpose funded supports participate community .
Level II Coordination Of Supports Further qualifications experience required to strengthen participant’s design their builds support emphasis linking the broad system of across complex service delivery environment Coordinating is focus supporting participants direct lives not just services may include resolving points crisis developing resilience network.\
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DISCLOSURE LOG

| Reference | Description and Details | |-| |07_003_0117_8_3| CB and Training in Plan and Financial Management by a Support Coordinator
Capacity building and training in plan administration and management with participant to strengthen their ability undertake tasks associated wihth mgmt of supports.

| Providers are assist participants build capacity undertake all aspects pland admin & managemnt including: engaging providers; developing service agreements maintaining records claiming payments from NDIA paying providrs.|

	Description	Detailed Explanation
08_005_0106_2_3	Assistance With Accommodation And Tenancy Obligations	Suport is provided guide prompt or undertaking activities ensure participant obtains retains appropriate accommodation May include assisting apply for rental tenancy or take ontenancy obligations.
09_006_0106_6_3	Lifet Transition Planning Incl. Mentoring Peer-Support Indiv Skill Develop	Etablishing volunteer assistance within the participant's home community develop skills For instance, assitance attending appointments shopping bill payin taking part social activites maintain contact others.
10_016_0102 5 _3	I ndividual Employment Support	This support can be applied to any working age participant (including students reaching working age) with employment goal.
10_017_0102-5 - _3	Employment Preparation and In a Group of 3	These suport can be offered in group environment.
13_030_01024_ -<_3	T ransition Through School And To Further Education	P rovision skil training advice assist arrangements orientation help person disability move from school further education.
14_031_01278 _3	C B Training Plan Financial Management by a Plan Manager

AnnualPriceReview 201920 OSA Review v.2
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Disclosure Log

Appendix D – Proposed psychosocial support items

Description	Detailed Explanation
| Capacity building & training plan administration management participant strengthen their ability undertake tasks associated mgmt supports. | Providers are assist participants build capacity undertake all aspects pland admin managemnt including: engaging providers; developing service agreements maintaining records claiming payments NDIA paying providrs.|
Assistance With Decision Making, Daily Planning Budgeting	p roviding time limited support to assist develop maintain daily budget include assisting planning purchases (including COVID-19 loading).

Support Item Number	Support Item Name	Support Item Description
07_101_0106_6_3 & Psychosocial Recovery Coaching - Weekday Daytime & Assistance for participants to foster hope, build capacity and resilience, by working collaboratively with participants,
families and other services to identify, plan, design and coordinate supports.
07_102_0106_6_3 & Psychosocial Recovery Coaching – Weekday Afternoon/Evening &
07_103_0106_6_3 & Psychosocial Recovery Coaching- Saturday & Assistance to maintain engagement through periods of increased support needs due to the episodic nature of mental illness.
07_104_0106_6_3 & Psychosocial Recovery Coaching- Sunday & Psycoshodical recovery coach work requires both lived and learnt experience. They must have tertiary qualifications in peer work or mental health (minimum of Certificate IV In Mental Health Peer Work)or equivalent training;and a minimum two yearsofexperienceinmentalhealth-relatedwork.