National Disability Insurance Scheme Annual Pricing Review 2020-21: Final Report

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Disclosure Log

Document: MR25/01967 FOI 24/25-2242

National Disability Insurance Scheme - Annual Pricing Review 2020-21 – Final Report | May 2020

This document was released under the Freedom of Information Act (FOIA) in accordance with Section(s): s22(1)(a)(ii), which pertains to irrelevant material. Page _of \

Disclosure Log

© National Disability Insurance Agency 2020 With the exception of any material protected by a trademark and when otherwise noted, this work is licensed under Creative Commons Attribution International Licence CC BY (https://creativecommons.org/licenses/by/). The details relevant licence conditions are available on website as full legal code for the CC BY International license. Content from this should be attributed to agency.

Suggested Citation:

national disability insurance agency report annual pricing review ndis.gov.au publication date may terms we use acronym abs cpi dsw mmm ndiaagency national disability insurance scheme review schads award temporary transformation payment wpi wage price index

Annual Pricing Review 2020-21

Final Report

Disclosure Log

Executive Summary

  • Discussion …89
  • Recommendation …91

Classifying Regional, Remote and Very Remote…

Current Arrangements …

Discussions
Recommendations

Costs in Outer Regional Areas ….

Current Arrangements ..

Discussions .
Recommendations

Cancellation Rules..

Current Arrangements..,

Discussions ,
Recommendations.,

Provider Travel Rules….

Current Arrangements …,.

Discussions,…
Recommendations…,\n11.

Establishment Fees……

Current Arrangements ….. \n##### Consultations …… \n###### Research …………… \n####### Discusssion……….. \n######### Recommendatton………

Disclosure Log

Executive Summary

Figures

  • Figure 1 - Distribution of Submissions by Number of Participants and NDIS Revenue of Respondent ….. page number (not provided)
  • Figure 3–Distribution of Topics Raised in Submissions to the Annual Pricing Review ………page number( notprovided )
  • Figure 4-Nous Group Study of Back Office Expenses of Not For Profit Organisations ………….. …page num ber(notpro vided) *Figure 4Claims for group activitiesin a centre…………………………………………………………. pag e n umber(n ot pr ovided).
  • Figur e7Numberof provider claims per quarter from 2016to 2019…………………………………pag enumber(p rovid ed)
  • F igureSNDIS revenue claimedby plan managersfrom monthly fees, buy Quarter , 2019 – 2019…………p age numb er(pro vi ded).
  • Fi g ur e SRelative Costo fDelivering Servicesb y Remoteness Classification……………………. p agenumb ernopro vid ed.

Tables

Table 1-Distribution OfSubm issions Received bY TheAnnualPricingReview……………………..pagenumbe r(provi de d) Table5Distributi onOfResul tsf romtheTTPSurvey ………………………………………………………………..pa ge nu m be rn opro vide d. Tab le8- NDIS therapy price limit comparison with other schemes,hourly rates ……………………………………….. page number (not provided ). Tabl etab l3 - ND IS hourlyprice limitsfor non-T TP and TTP support items ………….. …page num ber(notpro vided) . Ta ble4Comparati ve Schemehour lyfees…………………………………………………………… pag enum bers( notprovided ) Ta bl e t able7-CapacityBuildingSupportsThatMayBe DeliveredByDisabilitySu pp ortWorkers…………………………………pag enumber(n ot pr ovided). Ta bl e6-FWC DecisiononSCHADS ShiftLoadings–I July,2O OOO ……. pa gen umber(p rovid es). Ta bl e9 – Definitions of the Modified Monash Model Geographic Areas…………p age n umb er(n otpr ov ide).d Ta bl e ta bo le10-R egion swh ere p ricel imits changebetween MMM 2o I5andMMM oo 19………………pagenumb ernopro vi de.d. ta blet ablet11Relative costoflivingacrossQueensland ………………………………………………………………..pa ge numb errno prov ided. a tabletab letable12-Rel ativecostoliving across Western Australia ……………………………………….. page number (not provided ). Annual Pricing Review 2oo -21: Final Report Page35Of l04g9

DISCLOSURE LOG

This disclosure log relates to MR25/01967 FOI request number 24/25-2242.

The document contains information about releases made pursuant to Section(s): s22(1)(a)(ii) as per the Freedom of Information Act 1982 enacted and enforced by the National Disability Insurance Agency.

MR25/01967 FOI 24/25-2242

DISCLOSURE LOG

Executive Summary

The National Disability Insurance Agency (NDIA) continually monitors and reviews its price control framework and other market settings to determine whether they remain appropriate. The NDIA is also committed to the continuous improvement of the methodologies underpinning the NDIS price control framework. In line with this commitment, the Annual Pricing Review 2020-21 was required to examine, through research and consultation with industry, community and government stakeholders, whether the existing price control framework and other market settings under the NDIS continue to be appropriate or should be modified.

CONDUCT OF THE REVIEW

The Review engaged in extensive consultations with industry, community and government stakeholders and undertook a program of research.

  • An Issues Paper was released on 28 November 2019 together with a public call for submissions. The formal closing date for submissions was 2 February 2020, but submissions received up until 8 April 2020 were taken into account in the Review. Some 96 submissions were received by the closing date. A total of 139 submissions had been received and analysed by 8 April 2020.
  • Face to face consultations were held with 29 groups of providers in each State and Territory. After 23 March 2020, these consultations were held by teleconference/videoconference for safety reasons.
  • Six working groups (involving 108 providers and peak bodies) were established with representatives from the sector to discuss concerns and proposals for change.
  • On 11 March 2020, the NDIA’s Pricing Reference Group (PRG) met with members of the six provider peak groups.
  • On 15 April 2020, the NDIA’s PRG met with members of three participant peak groups. Other participant representative groups were invited, but were unable to attend due to having to address COVID-19 issues.
  • Consultations were also held with, and desktop analysis undertaken of, ten other state based and national schemes to compare pricing arrangements for attendant care and therapy services.

Deloitte Access Economics were engaged by the NDIA to conduct a financial benchmarking survey of Temporary Transformation Payment (TTP) providers and to analyse the results, with a particular emphasis on the parameters that underlie the NDIS Disability Support Worker Cost Model that determines many of the NDIS price limits. As at 15 March 2020, when the survey closed, Deloitte had received 615 completed surveys. As of 31 March 2020, an additional 231 responses had been received. However, these additional responses were not received in time to be included in the analyses in this report.

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Executive Summary

The Review also conducted research as set out in this Report, including of the extent to which providers were choosing not to charge the TTP and were agreeing fees with participants below the price limits.

FINDINGS AND RECOMMENDATIONS

Provider Administration and Participant Flexibility

The Review was required by its Terms of Reference to examine the price control framework to identify opportunities to increase flexibility for participants and reduce administrative burdens for providers.

The Review considers that there would be considerable merit in changing the timing of the Annual Pricing Review so that providers were aware earlier of any policy changes that the NDIA intended to make. The Review also considers that given the uncertainty around economic conditions during the COVID-19 pandemic and as Australia emerges from the pandemic that the NDIA should not undertake an Annual Pricing Review in 2020-21 but should instead monitor economic conditions carefully and promptly respond to emerging issues.

The Review also sees merit in the NDIA publishing the indexation methodology for price limits so that providers can better estimate their future budgets, recognising that the NDIA is not able to index and announce price limits until after the Fair Work Commission has made its Annual Minimum Wage Decision, which usually occurs in the middle of June each year.

The Review supports the introduction of programs of supports, whereby providers enter into contracts for the provision of programs of supports, especially where the program of supports is towards the achievement of specified outcomes. Where a participant does not attend one part of a program the provider is able to claim as though they did attend – that is, this is not a cancellation, as long as the provider had the capacity to deliver the support.

The Review considers that it is important to include safeguards in these arrangements, including that programs of support cannot be for longer than 12 weeks (unless specifically allowed for in the NDIS Price Guide) and that participants should be able to exit from an agreed program of supports without cost, subject to an agreed notice period that can be no longer than two (2) weeks. Supports delivered as part of a program of supports would not be subject to the short notice cancellation rules.

The Review recognises the concerns raised in consultations with participant representative organisations that the programs of support approach should not be permitted to be used by providers to return themselves to a quasi-form of block funding. Participant representatives did acknowledge, however, that the program concept was common in the commercial world and that it could be beneficial for other participants taking part in a program as they would have a greater certainty that the program would operate fully throughout its term. On balance, the Review considers that the advantages outweigh the risks, but recommends that the introduction of programs of support approach be carefully evaluated and that guidance material be produced by the NDIA for participants, including on their right to choose not to

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Executive Summary

engage their provider through a program of support. In the first instance, program of supports should only be able to be offered for group supports.

The Review also considers that there are other opportunities to simplify the NDIS Support Catalogue by removing the various worker to participant ratio support items. Providers would divide the number of worker hours by the number of participant hours to derive their own fractions of hours to charge participants and would claim for these hours against the relevant 1:1 support item and subject to the relevant price limit. For example, one worker delivering a one-hour session on a Saturday to three participants would be claimed as 1/3 of an hour per participant subject to the 1:1 Saturday price limit rather than as currently where an hour is claimed for each participant but subject to a reduced 1:3 Saturday price limit.

RECOMMENDATION 1) Annual Pricing Review

  1. The NDIA should not undertake an Annual Pricing Review in 2020-21 but instead monitor economic conditions carefully as the COVID-19 pandemic progresses and the economy recovers and promptly respond to any emerging issues.

  2. The NDIA should undertake the Annual Pricing Review from July to December each year (commencing 2021), reporting in February/March of the following year to the Board of the NDIA, through the Chief Executive Officer, with changes to take effect from the following 1 July.

RECOMMENDATION 2) Annual Indexation of Price Limits

  1. The NDIA should increase price limits during 2020 to maintain their real value through the following indexation arrangements:

    i) Price limits for supports delivered by Disability Support Workers should be set by the NDIS Disability Support Worker Cost Model from the operative date of the Fair Work Commission’s Annual Wage Review;

    ii) Price limits for Capital supports – Support Categories 2 (Transport), 3 (Consumables), 5 (Assistive Technology) and 6 (Home Modifications and Specialised Disability Accommodation) – should be indexed on 1 July 2020 in line with the movement in the ABS Consumer Price (All Groups, weighted average of eight capital cities) over the 12 months to the March Quarter preceding the indexation date; and

    iii) Price limits for other supports should be indexed on 1 July 2020 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 preceding the indexation date (with an 80/20 weighting).

  2. That in addition to the annual indexation arrangements, the NDIA should also reset all price limits determined by the NDIS Disability Support Worker Cost Model in

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response to the following Fair Work Commission determinations, with effect from the date of effect of the Fair Work Commission’s determination:

i) 1 December 2020, for the final tranche of the Fair Work Commission’s Equal Remuneration Order (MA000100 PR525485); and

ii) 1 July 2020, for the adjustment of the shift loadings for casual workers on Saturdays and Sundays in the SCHADS Award (Fair Work Commission Decision [2019] FWCFB 7096).

RECOMMENDATION 3) Programs of Supports

The NDIA should amend the NDIS Price Guide from 1 July 2020, to make clear that providers are allowed to enter into service agreements for the provision of programs of supports, where those supports are group supports, subject to the following safeguards:

i) that programs of support cannot be for longer than 12 weeks (unless specifically allowed for in the NDIS Price Guide);

ii) that participants should be able to exit from an agreed program of supports without cost, subject to an agreed notice period that can be no longer than two (2) weeks;

iii) the introduction of programs of supports should be carefully evaluated; and

iv) guidance material should be produced for participants before programs of supports are introduced.

Price limits for 1:1 core supports

The price limits for core supports are determined by the application of the NDIS Disability Support Workers Cost Model. The Review was required by the its Terms of Reference to examine the assumptions and parameters outlined in the NDIS Disability Support Worker Cost Model, including through analysis of the financial benchmarking data collected through the Temporary Transformation Payment (TTP) arrangements.

The full details of the NDIS Disability Support Workers Cost Model were published in June 2019. The cost model estimates the cost of delivering a billable hour of support taking into account all of the costs associated with every billable hour, including: base pay; shift loadings; holiday pay; salary on costs; supervision costs; utilisation (non-billable activities); corporate overheads and margin. Base rates of pay under the model are set in accordance with the Social, Community, Home Care and Disability Services Industry Award 2010. The cost model also contains a range of key assumptions and parameters that determine the level of the price limits.

The cost model also varies according to a range of factors, including: the intensity of support, the level of skills and experience of the worker delivering the support, whether the worker is

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permitted to sleep over, the time of day and day of the week the support is delivered and whether or not the provider claims the Temporary Transformation Payment (TTP).

The Review does not support the request by some providers that the price limit for support items should be determined by the complexity of the participant’s needs rather than by the skills and experience of the support worker, as currently. The Review accepts that participants with complex needs will often require more funding, both for more supports and for more skilled or experienced support workers. However, this is a planning issue, not a pricing issue. From a price control perspective the important issue is the input costs of the provider, which are largely determined by the skills and experience of the support worker who delivers the support.

The Review also does not support the request by some providers that the price limit should be determined by the shift of the worker rather than by the time of day that the support is delivered. It is important that participants know what price limit applies to each support that they purchase and they cannot know this if the price limit can also vary according to the shift that the employer has engaged the employee to work. In the end, workforce rostering is a matter for providers to manage. It is important to note, however, that when a particular support crosses a shift boundary and the same worker delivers the entire support then the provider is entitled to use the highest price limit for the entire support.

Given that baseline price limits are intended to represent efficient costs the TTP survey results, taken on their own, provide some evidence that the NDIS Disability Support Worker Cost Model may not be correctly estimating efficient costs – although some of the effects are countervailing.

  • The average Permanent Share of the workforce among survey respondents (43.8%) is considerably lower than the current Model assumption (90%). Moreover, the efficient 25th percentile estimate (71.7%) is also lower than the Model assumption.
  • The average utilisation rate among survey respondents (79.8%) is lower than the current Model assumptions (87.7% to 92.0%). However, the efficient 25th percentile estimate (90.0%) is in line with the current Model assumptions.
  • The average overheads percentage (as a loading on direct care costs) among survey respondents (27.7%) is higher than the current Model assumptions (10.5%). Moreover, the efficient 25th percentile estimate (19.8%) is also higher than the current Model assumption.
  • The average span of control among survey respondents (11.8:1) is slightly higher than the current Model assumptions (11:1). Moreover, the efficient 25th percentile estimate (15:1) is considerably higher than the current Model assumption.
  • The NDIS Disability Support Worker Cost Model does not currently provide for allowances paid to workers on top of their salaries (other than shift loadings and superannuation). This in not in line with the TTP Benchmarking Survey which indicates

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Executive Summary

that these allowances can typically be in the order of 1.0% of the base salary payable to the worker.

However, the TTP survey does not include results for providers who are not accessing the higher TTP price limits, and who, prima facie, are likely to have lower costs (and hence be more efficient) since they have not chosen to access the higher TTP price limits. Only around half of eligible providers (59.6%) claim the TTP and then less than half of TTP claimants completed the survey by the due date. Thus, the survey provides results for only around a quarter of those NDIS providers who employ Disability Support Workers. Assuming that the distribution of overheads among non-TTP claiming providers is similar to the distribution among TTP claiming providers, but with a lower average representing their lower costs then it is possible to generate a mixed statistical distribution of all providers. The Review estimates that in this distribution the efficient (25th percentile) provider would have overheads of between 14.4% and 16.7% of direct costs (with a median estimate of 15.2%).

Moreover, some of these overheads relate to provider transport non-labour costs, which are currently not separately claimable by providers. The TTP benchmarking survey found that the average cost of travel expenses across respondents was $1,000 per worker per year. A DSW Level 1 paid at $27.61 per hour, with a 38-hour week, has an annual income of $54,557. With salary related on costs and supervision costs this equates to direct care expenditure of about $70,000. Travel expenses of $1,000 would represent a 1.4% increase on this, and would currently be shown in the overheads of the provider.

There is also strong evidence that some providers are managing to operate at or below the current price limits, with almost 40% of eligible providers choosing not to access the higher TTP price limits. Moreover, more than 25% of all claims by these providers were below the relevant lower non-TTP price limit and about 9% of claims were more than 10% below the relevant lower non-TTP price limits.

Finally, the current price limits in the NDIS are higher than some of those that apply in other schemes. However, it is not clear to what extent these fees can be compared to NDIS price limits, given that fees can operate differently in different contexts (e.g. according to whether or not services are commissioned, and what other fees – including co-payments – are also billable).

On balance, therefore, the Review considers that there is no reason to increase the current set of price limits, although it would be appropriate to make some minor modifications to the NDIS Disability Support Worker Cost Model to:

  • Decrease the ratio of permanent to casual staff assumed in the cost model to 70/30% in line with the 25th percentile of the TTP Benchmarking Survey;
  • Increase the share of staff assumed to take up their long service leave entitlements to 100% in recognition of the existence of portable long service leave schemes in some states and territories;

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  • Decrease the assumed workers compensation premium percentage from 3.0% to 1.7% in line with the 25th percentile observed in the TTP Benchmarking Survey, noting that this is equal to the average premium percentage observed across the health and community sector;
  • Increase the assumed overheads percentage to 12.0% to better align with the estimated overheads of efficient providers in the sector, noting that other recommendations being made by the Review will directly address some of the costs that providers are currently carrying in their overheads;
  • Increase the supervision ratio from 11 to 15 in line with the 25th percentile observed in the TTP Benchmarking Survey, noting that the non-face-to-face claiming rules permit some interactions between supervisors and staff to be claimed directly when they relate to the specific direct care needs of a participant; and
  • Increase the provision of allowances (other than travel allowances) for support workers and supervisors to 1.0% of salary, in line with the average level observed in the TTP Benchmarking Survey.

The level of the TTP loading was set at 7.5% for 2019-20 to be reduced by 1.5%age points each 1 July thereafter in line with the NDIS Pricing Strategy. The Review considers that there is more than sufficient evidence that the market for disability supports is continuing to grow and become more efficient, noting again that more than 40% of providers chose not to access the TTP accounting for almost half of all claims (by dollar) against relevant support items, and that of those providers who chose to operate under the lower non-TTP price limits, more than 25% of all claims were below the relevant lower price limit.

The Review also considers that the assurance arrangements around claiming the higher TTP price limits should be strengthened and that Plan Managers should be required to receive an attestation from a provider who is seeking to make a claim against an item subject to the higher TTP price limits that they are eligible to access the higher price limits before the Plan Manager processes the claim.

RECOMMENDATION 4) NDIS Disability Support Worker Cost Model

  1. The NDIA should continue to use the NDIS Disability Support Worker Cost Model to determine the base (non-TTP) price limits for supports delivered by Disability Support Workers based on the performance of efficient providers.

  2. The NDIA should amend the NDIS Disability Support Worker Cost Model (and the price limits determined by the cost model), from 1 July 2020, by:

    i) Decreasing the ratio of permanent to casual staff to 70/30%;

    ii) Increasing the share of staff assumed to take up their long service leave entitlements to 100%;

    iii) Decreasing the workers compensation premium percentage to 1.7%;

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iv) Increasing the overheads percentage to 12.0%;

v) Increasing the supervision ratio to 15:1; and

vi) Increasing the allowance provision for support workers and supervisors to 1.0% of salary.

RECOMMENDATION 5) Temporary Transformation Payment

The NDIA should reduce the level of the Temporary Transformation Payment from 7.5% to 6.0% on 1 July 2020 as previously announced.

RECOMMENDATION 6) Definition of the Levels of High Intensity Supports

That the definitions of Level 1, Level 2 and Level 3 supports in the NDIS Price Guide should be amended as follows:

Level 1 support items should be used if the worker who delivers the support is someone who has the skills and experience that would mean that they would be classified as a Social and Community Services Employee level 2 (below the maximum pay point) if they were employed under the SCHADS Award.

Level 2 support items should be used if the worker who delivers the support is someone who has the skills and experience that would mean that they would be classified as a Social and Community Services Employee level 2 (at the maximum pay point) or as a Social and Community Services Employee level 3 (at the minimum pay point) if they were employed under the SCHADS Award.

Level 3 support items should be used if the worker who delivers the support is someone who has the skills and experience that would mean that they would be classified above a Social and Community Services Employee level 3 (at the minimum pay point) if they were employed under the SCHADS Award.

RECOMMENDATION 7) Definitions of Time of Day and Day of Week

That the definitions of Time of Day and Day of Week in the NDIS Price Guide should be amended as follows:

Time of Day and Day of Week

In determining which price limit is applicable to a support, the important consideration is when the support is provided to the participant, not the shift of the worker used to deliver that support as determined by the applicable Industry Award or Enterprise Bargaining Agreement (EBA).

For NDIS billing purposes the provider must first determine the day of the week on which the support was provided on and then the time of the day during which the support was delivered. (Note: weekday means Monday, Tuesday, Wednesday, Thursday or Friday).

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  • A Night-time Sleepover Support is any support to an individual participant delivered on a weekday, a Saturday, a Sunday or a Public Holiday that:

    • commences before midnight on a given day and finishes after midnight on that day; and
    • is for a continuous period of eight (8) hours or more; and
    • the worker is allowed to sleep when they are not providing support.
  • A Public Holiday Support is any support to an individual participant that starts at or after midnight on the night prior to a Public Holiday and ends before or at midnight of that Public Holiday (unless that support is a Night-time Sleepover Support).

  • A Saturday Support is any support to an individual participant that starts at or after midnight on the night prior to a Saturday and ends before or at midnight of that Saturday (unless that support is a Public Holiday Support or a Night-time Sleepover Support).

  • A Sunday Support is any support to an individual participant that starts at or after midnight on the night prior to a Sunday and ends before or at midnight of that Sunday (unless that support is a Public Holiday Support or a Night-time Sleepover Support).

  • A Standard Day Support is any other support, and is either:

    • A Weekday Support is any support to an individual participant that starts at or after 6:00 am and ends before or at 8:00 pm on a single weekday (unless that support is a Public Holiday Support or a Night-time Sleepover Support).
    • An Evening Support is any support to an individual participant that finishes after 8:00 pm and at or before midnight on a single weekday (unless that support is a Public Holiday Support or a Night-time Sleepover Support).
    • An Active Overnight Support is any support to an individual participant that commences at or before midnight on a weekday and finishes after midnight on that weekday, or commences before 6:00 am on a weekday and finishes on that weekday (unless that support is a Public Holiday Support, Saturday Support, Sunday Support or a Night-time Sleepover Support).

If a support to an individual participant does not meet one of the above criteria then it needs to be billed as two or more separate supports.

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Night-time Sleepover Supports

Night-time Sleepover Supports have a price limit that is inclusive of the cost of two hours of any supports provided to the participant for the duration of the period. Providers may claim for third or additional hour at Saturday rates on weekdays, or at applicable rates on other days (Saturday, Sunday or Public Holidays)

Note, Night-time Sleepover Supports apply to any day of the week and on public holidays, pending criteria met as described previously.

Price limits for group-based core supports

The Review was required by its Terms of Reference to examine the methodology for deriving the price controls for group-based supports from the price controls for 1:1 supports.

Currently, the price limit for community-based group supports apply to each hour of support and are based on the price limit of the relevant 1:1 community participation support (for each level of support and time of day and day of week). The price limit for the relevant 1:1 support is P then the price limit $P_n$ for the 1:n community based support is given by the following equation:

$$P_n = \frac{P + (n-1) \times 0.12 \times P}{n}$|

For each additional person in the group (after the first) an additional 12% of the 1:1 price limit (essentially seven minutes) is added to the price limit. This reflects the time that the provider may need to spend writing a report on each participant in the group after the group has finished. Because of this built-in loading, providers of group based supports are not permitted to claim for non-face-to-face time. For 1:1 supports, non-face-to-face activities are part of delivering a specific disability support to that participant (rather than a general activity such as enrolment, administration or staff rostering).

The price limit for centre-based group supports are calculated by adding a fixed capital allowance amount to the relevant community based group support. In 2019-20, the amount of the fixed capital allowance was $2.10 per participant per hour. The amount of the fixed capital allowance is indexed on 1 July each year in line with movements in the Consumer Price Index (CPI).

The Review considers that there is considerable merit in replacing the current group based pricing arrangements with simplified arrangements, whereby providers can claim for both direct service provision and non-face-to-face supports as they are provided. Providers would divide the number of worker hours by the number of participant hours to derive their own fractions of hours to charge participants and would claim for these hours against the 1:1 support item and subject to the standard price limit. For example, one worker to three participants for a one-hour session would be claimed as 1/3 of an hour per participant subject to the 1:1 price limit rather than as currently where hour is claimed for each

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participant but subject to a reduced 1:3 price limit. Providers of centre based care would claim for the fixed capital allowance for each participant through a separate support item.

The Review notes that when this change was suggested last year the sector did not accept it. It appears, however, that the sector has become much more comfortable with the non-face-to-face claiming arrangements and can now see the opportunities that can arise from the proposed simplification. Currently there are over 220 support items for group-based supports in the NDIS Support Catalogue. Under the proposed amendments, some 200 of these support items would no longer be needed. The proposed new arrangements for “programs of supports” would also reduce the administrative burden of providers.

The Review does not consider that the evidence about the capital costs of centre-based care is sufficiently strong to justify a change in the amount of the fixed capital allowance, but could be investigated further in a future Annual Pricing Review.

RECOMMENDATION 8) Group Based Supports

  1. The NDIA should amend the pricing arrangements for group based supports so that providers no longer use the various worker to participant ratio support items but instead claim all supports against the appropriate 1:1 support items by apportioning the time spent with the group among the members of the group. Providers of centre based care would claim for the fixed capital allowance for each participant in a group through a separate support item.

  2. The NDIA should also amend the pricing arrangements for group based supports so that providers can claim for non-face-to-face supports under the usual conditions, rather than having an allowance for non-face-to-face supports built into the price limit.

Capacity Building Supports

The Review was required by the its Terms of Reference to review the price control framework for capacity building supports, including therapy supports, by examining:

  • how price limits for capacity building supports, other than therapy supports, should be indexed or otherwise determined annually;
  • how price limits for therapy supports should be adjusted annually, given the outcomes of the Review of Therapy Pricing Arrangements;
  • whether different price limits might be appropriate for different times of the day, or days of the week, for some capacity building supports, including for therapists, therapy assistants and for capacity building supports delivered by disability support workers; and
  • whether therapists and other capacity building providers should be able to recover the costs of consumables provided to participants as part of a support.

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Executive Summary

The Review of NDIS Therapy Pricing Arrangements (“the Therapy Review”), which reported in 2019, found that the NDIS accounts for about 2.4% of Australia’s established national therapy market, suggesting that it has limited capacity to influence market prices for therapy services and is instead a “price taker”. The Therapy Review also found that while there are early signs of some competition in the NDIS market for therapy services, around 70% of claims continued to be made at the price cap. It found that the distribution of claims also remains significantly different from the private market distribution. On the basis of the evidence on market conditions and the sector consultations and benchmarking analysis outlined above, and in line with the principles of the National Disability Insurance Scheme Act 2013, including that a funded support must represent “value for money in that the costs of the support are reasonable, relative to both the benefits achieved and the cost of alternative support”, the Therapy Review recommended that the NDIA should maintain price caps on therapy services at least until the transition to the NDIS is complete and there is evidence that the distribution of NDIS payment claims is broadly in line with the distribution of prices observed in the private billing market.

The current Review agrees with the conclusions of the Therapy Review. It is also concerned that there is some evidence that the NDIS price limits for therapy service may be distorting the market for therapy services. NDIS price limits appear high compared to some other state compensable schemes, which warrants further investigation. The Review therefore considers that a comprehensive review of therapy pricing should be undertaken as part of the next Annual Pricing Review and every two years thereafter.

The proposed comprehensive review of therapy pricing should also give further consideration to the question of whether different support items (and price limits) need to be created to encourage the delivery of therapy supports outside of usual business hours, with a particular focus on the impacts that the current arrangements have on best practice delivery, especially for Early Childhood Early Intervention supports. The current Review received mixed evidence on this issue and does not consider that it can be resolved in isolation from an analysis of the entire billing practices of other schemes. The Review notes, for example, that most other schemes do not include different payment rates for out of business hours consultations, but structure their billing arrangements around the complexity of the consultation (say 30-60 minutes) rather than the precise duration.

The Review also considers, given the disparity between NDIS price limits and the rates payable in other schemes, that therapy price limits should not be indexed this financial year.

Currently the price limits for capacity building supports are indexed on 1 July each year by the 80/20 weighted average of the movements in the ABS Wage Price Index and the ABS Consumer Price Index over the 12 months to the March Quarter preceding the indexation date. However, 15 Capacity Building supports are delivered by workers employed under the SCHADS Award or a similar industrial agreement. These workers are subject to the Fair Work Commission’s increase to minimum wage that occurs every year, which is included in the current methodology for applicable core supports. The Review considers that it would

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Executive Summary

therefore be more appropriate for the price limits of these supports to be set by the Disability Support Worker Cost Model.

The Review received a number of submissions about the cost of consumables used by therapists. The Review considers that it is important to distinguish between “tools of the trade” of the therapist and consumables used in the treatment of the specific participant. This is in line with the approaches taken by some other schemes. Worksafe Victoria, for example, “expects that health professionals will not invoice for consumables (i.e. tape, ultrasound gel, dry needles, wax therapy) used as a part of in-rooms treatment” but does permit billing for items “intended to be supplied for the worker to take home to assist with the management of their work-related injury or illness”. The Review understands that consumables that are provided to the participant are, in general, claimable against the participant’s NDIS plan. The Review considers that tools of the trade are already accounted for within the price limits for therapy support items. The Review notes, for example, that the NDIS Nursing Cost Model includes an overheads provision of 20%.

RECOMMENDATION 9) Capacity Building Supports

  1. The NDIA should undertake a comprehensive review of therapy pricing arrangements as a part of the Annual Pricing Review every two years, with the next comprehensive review to commence in July 2021. Pending the outcomes of that review:

    i) the NDIA should not index the price limits for therapy supports on 1 July 2020; and

    ii) the NDIA should index the price limits for therapy supports on 1 July 2021 in accordance with the indexation methodology set out in Recommendation 2.1(iii).

  2. The NDIA should index the price limits for capacity building supports that are delivered by Disability Support Workers by reference to the NDIS Disability Support Worker Cost Model.

Plan Management Supports

NDIS participants can choose to have a registered Plan Management provider to manage their funding and budget for the supports in their plan. Plan Managers are bound to the NDIS Price Guide and are able to connect participants with both NDIS registered providers and providers that are not registered with the NDIS. The Review was required by its Terms of Reference to examine the price control framework for plan management supports.

In 2018-19, claims for plan management supports totalled $86 million – of this 28% was claimed by the top five (5) plan management providers. There are currently 809 active registered providers offering plan management services (7% of all NDIS registered providers.) Some 33% of NDIS participants have their funds managed by a plan manager, with total managed funds totalling approximately $5.5 billion.

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The Review found little evidence that current price limits for plan management are inadequate. The number of NDIS registered providers offering plan management services increased from less than 50 to just over 800 between 2016 and 2019. The revenue earned by plan managers from the monthly account fee has also grown significantly, in line with the growth of the Scheme. The scale of plan management organisations is also growing with the average number of participants per plan management organisation increasing from 18 in the third quarter of 2016, to 133 in the fourth quarter of 2019. The largest five plan management providers now service approximately 30% of the market. At least two of these five providers were established in the last 36 months. Few plan management providers have exited the market and early research indicates that those who have exited may not have had the growth required to operate at sustainable margins. Most providers that have exited made a total of less than 25 claims over their lifetime of up to 3.5 years.

On balance, the Review concludes that there is no evidence of a gap in supply for plan management services. Competition is strong with new competitors entering the market; there is also strong growth in the sector both in terms of revenue and customer numbers. Some early signs of innovation can also be seen. The current flat fee structure is simple, has been iterated over time from less successful arrangements including quoting, and has been implemented on a national scale. A flat fee structure (as opposed to hourly rate) is appropriate for financial administration tasks as it can encourage efficiency.

There is some evidence that the capacity building and training in plan administration and management support item may not be functioning as intended. There are strong arguments why providers should be able to claim for non-face-to-face time and provider travel for this support item. The argument for an increase in the price limit for this item is less strong, given that it is already higher than the standard Disability Support Worker price limit and is aligned with the Level 1: Support Connection price limit.

RECOMMENDATION 10) Plan Management

The NDIA should amend the conditions attached to the support items:

i) 07_003_0117_8_3 (Capacity Building and Training in Plan and Financial Management by a Support Coordinator); and

ii) 14_031_0127_8_3 (Capacity Building and Training in Plan and Financial Management by a Plan Manager)

In the NDIS Support Catalogue so that providers can claim for provider travel and non-face-to-face supports with respect to these supports.

Classifying Regional, Remote and Very Remote

The Review was required by its Terms of Reference to examine the geographic classification component of the NDIS price control framework to examine whether modifications are required to the NDIA’s implementation of the Modified Monash Model (MMM) to account

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for specific disability service-related costs, including the treatment of “isolated locations” and islands under the MMM.

The Review considers that the MMM is explicitly based on distance to the nearest labour supply centre and so should in general be well suited as a mechanism to estimate the availability of the disability support workforce and the need for higher price limits to compensate providers for the higher costs associated with attracting workers. Note the NDIS Review of the WA Market did find that the cost of service delivery in isolated centres – centres that are currently not classified as remote or very remote by the MMM but that are completely surrounded by remote or very remote areas – were, in general, higher than in other non-remote areas. Consequently, the NDIA has modified the MMM so that areas (or groups of areas) that are currently not classified as remote or very remote by the MMM but that are completely surrounded by remote or very remote areas (“Isolated towns”) are classified as remote areas for planning and pricing purposes.

The Review recognises that thin markets operate in remote, very remote and some regional areas, especially for more specialised services. However, the Review considers that the solution to this issue lies through a greater use of commissioning, rather than through increases in price limits, especially where the thinness of the market is due to the low number of participants. In these circumstances, individual participants will never have sufficient purchasing power to attract service provision with the efficiencies of aggregation that can be generated through commissioning.

The Review also considers that the argument for a delay in implementing any change in the MMM rating of a region is not strong, given that both price limits and plan funding loadings are driven by the same loadings. Thus, while participants who might be reclassified into non-remote areas might have smaller plans they would also face lower price limits.

RECOMMENDATION 11) Geographic Classification

The NDIA should adopt the MMM 2019 classification system, and any future updates to the MMM classification system as released by the Department of Health, (subject to the NDIS Isolated Town arrangements) as the basis of determining the pricing arrangements in the NDIS Price Guide, including:

i) whether remote and very remote loadings should be applied to price limits and plan funding amounts; and

ii) which travel time limits apply to the supports delivered to participants.

Costs in Outer Regional Areas

The Review was required by its Terms of Reference to examine whether a loading should be applied to price limits and plan funding amounts in outer regional areas to account for the higher cost of service delivery, if any, in those areas. The Review does not consider that there is sufficient evidence to conclude that the costs of service delivery are higher in regional areas than in metropolitan areas, except in respect of travel costs. It therefore

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Executive Summary

considers that any supply issues in these areas are better addressed through the revised travel and coordinated commissioning arrangements proposed elsewhere in the Review.

Cancellation Rules

NDIS providers are not permitted to collect deposits or bonds from participants, or to retain these funds in the event of the participant cancelling a service booking for a support or failing to turn up for a support. They are permitted to charge cancellation fees in certain circumstances. The Review was required by its Terms of Reference to examine the current price control arrangements for cancellations within the Scheme.In 2018–19, cancellation payments totalled $12.3 million or 0.1% of Scheme expenditure. Only 27.9% of providers made a cancellation claim. For these providers, cancellation claims represented on average 4.9% (by number) and 3.6% (by value). For one provider out of ten who claimed for cancellations, their cancellation claims were more than twice as many compared with other claims: representing over 11.1%, both numerically ( extgreater{}5 times higher), which is also reflected at an even greater proportionally increase when considering monetary values where they represent extgreater{}8%.The Review heard evidence:egin{itemize} ightlistegin{enumerate}[label= extbullet] ightlist

  • The current arrangement - whereby NDIS requires providers claiming full agreed fee but only pays them part thereof results accounting anomalies showing NDIA as bad debtor.
  • ightlist ightlist<ol start=

    RECOMMENDATION 12) Cancellation Fees

    The NDIA should permanently amend the claiming rules in the NDIS Price Guide to allow providers to claim for 100% of the agreed fee for a short-notice cancellation.

    DISCLOSURE LOG

    Executive Summary

    RECOMMENDATION 13 Provider Travel

    • The NDIS Price Guide, and the NDIS Support Catalogue should * be amended.* from July. . . .. *so providers can claim for non-labour costs associated with provider travel, in line with activity-based transport arrangements.“ Claims should only be able“ *

    Disclosure Log

    Executive Summary

    i) An Establishment Fee to assist with the non-ongoing costs of establishing arrangements and assisting participants in implementing their plan is claimable from a participant’s plan by a provider who: - Is one or more of the following registration groups for NDIS support categories within the National Disability Insurance Scheme’s framework as outlined below. * Registration Group 0104 High Intensity Daily Personal Activities, * Registration Group 0107 Daily Personal Activities; * Registration Group 0125 Participation In community, social And civic activities; Or * Registration group 0136, Group Centre Based Activities). - Has made an agreement With The Participant To Supply At Least Twenty Hours Of Support – Within These Categories (Support Category One Assistance With Daily Life) And/or Support Category Four Assistance With Social Community Participation) Per Month For Duration Plan; ii) each Provider Can Only Claim An Establishment Fee In Respect A Participant Once Across All Plans. iia) more Than One Provider Is Able To Claim For An Establishment Fee Against Given Plan Provided Each Meets Other Criteria Above. v) The Amount Of The Establishment Fee Should Be Negotiated By Both Parties But Cannot Exceed Ten Times Hourly Weekday Price Limit For Disability Worker As Determined By Standard Ndis Cost Model ($ 5.2850 in 2019-20).

    Recommendation:

    two)The NDIA should add several price-limited items to its catalogue of support services for providers within the registration groups as outlined above so that they can claim establishment fees and maintenance costs.

    Disclosure Log

    Introduction

    The National Disability Insurance Agency (NDIA) has responsibility for administering the National Disability Insurance Scheme (NDIS), including managing the markets for disability goods and services. As part of its market stewardship role, the NDIA limits the prices that registered providers can charge for some supports and applies other price controls, including rules about the circumstances in which providers can claim payments from the NDIA for goods or services they have delivered.During transition(price control are in place to ensure participants receive value for money in the supports that they receive.In short term medium term ,price controls are required for some disability supports because the marketsfor disability goodsand service not yet fully developed.The longer-term goalof NDIS is remove need fo rprice cont rol sdisability suppor ts . The NDIA recently publishedthe NDIS pricing strategy and review therapypricing arrangements together detail important rolethat plays empowers people supportedby NDIS exercise choicecontrol; maintaining expanding supply high quality disabiliy support driving efficiency innovationinmarket thosesupports supportingtransition overlongerterm more deregulated outcomes based approach.Currently,the variesapproach regulationprices depending on conditions between:

    • No Regulation(deregulate dmarkets): this typically used cases where highly competitive transport. The imposition o fpricelimits: represents maximum allowable payable by participants types ofsupp ort. This significant number developing growing such as attendanc care.Price controlarrangements set outNDSI Price GuideNDIS Support Catalogue Quotable Supports : Inwhich participant expected obtain quotations suppliers provide part verifying prices fair reasonable.NDIA continually monitors reviews price framework other market settings determine still appropriate committed improvement methodologies underpinning annual Pricing Review 2020 -as an important monitoring terms reference AnnualPricingReview referenceseout below.

    Disclosure Log

    Introduction

    TERMS OF REFERENCE

    The Annual Pricing Review 2020–21 will examine through research and consultation with industry community government stakeholders, whether existing price controls frameworks other market settings continue appropriate or modified. The review will: a(Reviewing flexibility participants reducing administrative burdens providers see chapter reference source not found.) b(Examining assumptions parameters outlined NDIS Disability Support Worker Cost model financial benchmark data collected Temporary Transformation Payment arrangements see chapter reference source not found.)and(ii)(Methodology deriving group-based supports from one-to-one supports see chapter) c(Examine capacity building therapy support pricing framework annual indexing otherwise determined annually adjust given outcomes Therapy Pricing Arrangements different times day week some capacity building therapists assistants delivered disability support workers recover costs consumables provided part support(d)Plan management supports see chapter(e)Geographic classification component examining whether modifications NDIA’s Modified Monash Model MMM specific service-related costs including treatment isolated locations islands underMMM loading applied to outer regional areas account higher cost delivery any those areas see chapter)

    Disclosure Log

    Introduction

    (f) Re-examine current billing arrangements, including: i. Cancellation rules [see Chapter 1]; (ii). Provider travel time limits; examining whether it is possible to develop an approach that better accommodates local conditions ([Chapter Error! Reference source not found.]); (iii). Non-labour costs associated with provider travel([Chapter Error! Reference source not found.]);and(iv). Establishment fee arrangements(See[Chapter RECOMMENDATION 13]2)).

    In framing its recommendations,

    The review will be cognizant of NDIS objects and principles, such as supporting independence for people living in disability; enabling choice control over goals planning delivery supports; facilitating a nationally consistent access plan funding support disabilities; promoting high-quality innovative supports maximizing independent lifestyles full inclusion community; adopting insurance-based approach informed actuarial analysis provision funding support disabilities financially sustainable.

    Conduct Of The Review

    The review has engaged extensive consultations industry stakeholders undertook program research.

    Submissions From Participants And Providers

    An Issues Paper released on November together public call submission.[Footnote: https://www.ndis.gov.au/media/2029/download]. The formal closing date submissions February but received until April were taken into account the review.some submitted by deadline total had been analyzed.A majority (registered providers) included predominantly plan managers further from peak bodies participant voice also heard advocacy bodies participants or nominees.

    Disclosure Log

    Introduction

    Some of registered providers who made submissions to Review had made claims payment NDIS Submissions these providers were divided evenly between profit and non-profit providers . Submissions received all states territories roughly in participant numbers see Table Some % participants more state/territory

    Distribution of Submissions Received Annual Pricing Review

    NSW VIC QLD SA WA TAS ACT NT
    Share revenue TTP Survey 41% 6. 0.% <
    Active Participants (Q) 35%% 26 .8% 18 % 9. 7.
    Providers ranged size servicing over , with average being median They also from having $ million, around Figure -Distribution Number Respondent
    Annual Pricing 2020- Final Report Page redacted

    Disclosure Log

    Introduction

    Across the whole group of providers who made submissions, some 88% of their revenuefromtheNDISwasfromthederiveryofcoresupports,with**11 Note: thisanalysisexcludesNDISR fromSupportedIndependentLivingandSpecialistDisabilityAccommodationasthesewerenotinthescopeoftheAnnualPricingReview.) ByfarthemostnumberofresponsetotheIssuesPaperpertainedto*1: core supports,*mostlytodowiththenDIS DisabilitySupportWorkerCostModel.*Capacitybuilding, cancellationsandanplanmanagementweralsopopularissues.Theleastcommentedupontopics wereregionalloadingsandothereographicalissues.Figureillustratesthedistributionoftopicsraisedinthesubmission.

    Figure 2 – Distribution of Topics Raised in Submissions to Annual Pricing Review

    | DSW Cost Model | Cancellations | |-| ||- | Capacity Building | Travel | | Plan Management | Flexibility and Admin | | Group Supports | Establishment Fees | | Other Pricing | Regional Costs | | Geographical |

    Disclosure Log

    Introduction

    The views of respondents to the Issues Paper are presented in the appropriate chapters of this report.

    Provider Consultations

    Face-to-face consultations were held with groups of providers in each State and Territory. After 23 March ⁻₀₊, these consultations were-held-by- telconferencet/videoconference-for-safety-reasons-following-the-emergence-of-the-COVID-19-pandemic. | Date | Location | |-| | September (\text{3}0) ,   South Australia Adelaide,  | October (\text{&} Tasmania Launceston,   | October (\text{9}) Tasmanian Hobart,/  | October (:) Northern Darwin,NorthernTerritory& | October (⁥) ; TerritorODarwin,Territori>
    | November(=) TerriotoriAliceSprings,Terriorit>br /
    | Novembe()Territo | December (<)</table>,WesternAustralia Perth</table>; Perth, Westernterria

    Working Groups

    The views of attendees are presented in the appropriate chapters of this report.<p data-mce-bogus=

    Disclosure Log

    Introduction

    Six Working Groups (WGs) were set up, involving sectoral representatives, to discuss concerns about changes in their relevant topics as listed below:

    • NDIS Disability Support Worker Cost Model - involved from organizations/peaks;
    • Geographical issues – represented through organization peaks;
    • Group supports — similarly organized into group representations;
    • Billing rules— covered across multiple organizations;
    • Capacity-building including therapy support— addressed via a subset representing these areas. The views and perspectives provided within each WG are detailed throughout this report’s chapters on respective subjects.

    Disclosure Log

    Introduction

    participant challenge also had one on one meetings with the PRG, however proceedings had to be conducted via videoconference.

    Consultations With Other Schemes

    Teleconferences were held for comparing therapy and attendant care pricing methodologies between officers from these schemes:

    • Department Of Veterans Affairs (5)
    • icare New South Wales(6)
    • State Insurance Regulatory Authority NSW (7)
    • Victorian Transport Accident Commission (8)
    • Worksafe Victoria (9)
    • WorkCover Queensland (10). The following schemes underwent desktop reviews regarding their pricing arrangements as well, including Comcare which covers Commonwealth Government agencies’ employees except Australian Defence Force; ACT government’s entities including self-insured corporations.(11) Medicare Benefits Schedule,(12), Return To Work SA ,and South Australia Lifetime Support Authority .

    Disclosure Log

    Introduction

    • WorkCover Western Australia.

    Desktop Research

    The review also conducted research into: • A comparison of NDIS attendant care price limits and input cost drivers to those other schemes sectors, • The level market competition as evidenced proportion capacity building core services are being below maximum prices stipulated NDIS Price Guide ndis Support Catalogue , • Administrative burdens indicated payment delays claim rejection rates . • Comparison non-face-to-face costs between individual group supports For plan management trends average numbers participants per provider number provided . The differences versions Modified Monash Model years . Numbers trend service cancellations categories . How many change providers first year Establishment Fees multiple at same time . The research is reported in appropriate chapters this report .

    Temporary Transformation Payment Benchmarking Survey

    Providers attending community participation supports who meet eligibility criteria set out have access higher price through a temporary transformation (TTP) This conditional loading meant assist providers continue transforming businesses move towards more competitive marketplace In order TTP price limits providers participate annually Agency-approved benchmark survey They publish their service keep business contact details up date Provider Finder Deloitte Access Economics engaged by the National Disability Insurance Administration conduct financial benchmarking survey TTP providers analyse results particular emphasis parameters underlie NDIS Disability Worker Cost Model determines many NDIS price limits Only de-identified data passed on agency On 21 February sent online invitations enrolled eligible registration groups included of which had claimed for one or more support items in 2019–20.

    Disclosure Log

    Introduction

    At as on 15 March 2020, when the survey closed, Deloitte had received 615 complete surveys. On or after that date and up until a later point (specifically mentioned is “As at”), additional completed surveys have been recorded but these figures do not include those submitted between then and now due to time constraints for inclusion within analyses contained herein: as of [the specific date] there were 746 total submissions, some of which arrived too late to be included; in addition, some providers did respond in full to the TTP Benchmarking Survey and are therefore excluded from this report’s analysis.

    Provider Administration and Participant Flexibility

    The Review was required by its Terms of Reference to examine the price control framework to identify opportunities to increase flexibility for participants and reduce administrative burdens for providers.

    CURRENT ARRANGEMENTS

    Two of the fundamental principles underlying the NDIA’s approach to price controls are minimising complexity and bureaucracy for providers and minimising restrictions on participant choice and control. The Agency is concerned with striking the right balance between these two principles. The Agency is also aware that price control frameworks can impose administrative burdens on providers, and wishes to explore ways to reduce transactional costs through ease and simplicity in design of price control arrangements.[16] Equally, the Agency must ensure that participants are fully informed and empowered to achieve maximum flexibility to use their budgets to meet their goals as they see fit.

    CONSULTATIONS

    The Issues Paper asked respondents to indicate:

    • If there were changes that could be made to the NDIS Price Guide and the NDIS Support Catalogue that could reduce transactional costs for providers – without reducing participants’ choice and control?
    • If there was scope for changes in the price controls framework that would give participants greater discretion over use of their budgets – without substantially increasing costs to providers?
    • If there were any other issues where the current price control framework created unnecessary bureaucracy for providers or restricted participant flexibility?’

    The most common pricing-related administrative issue for respondents was that the NDIS Support Catalogue was too large and complex to understand. It was also suggested that the language could be revised to make it more readable for both participants and providers. A few submissions suggested that the coding system used for supports could be more logical, where the code says more about the support itself linked to that line item.’ However,’ some respondents thought administrative burden could be better addressed by adding new items to the ‘Support Catalogue’. For example,’,some respondents suggested that ’ coding system used for supports could be more logical,adding non-standard support ratios (e.g., 2:1 or 2:5)would makethe best way to reducetaking a step further. to remove price limits altogether. <sup>\[16]</sup>The Issues Paper notedthat administrationcosts ofthe Agency's claimingsystem are not withinscopeofAnnual Pricing Review,andare beingaddressed througha separate process

    Disclosure Log

    Provider Administration and Participant Flexibility

    A number of submissions asked for the NDIS Price Guide to be made easier to understand from a consumer perspective for participants. Two submissions specifically asked for a participant’s version of the Price Guide.redacted Some respondents were concerned that any increase in participant flexibility might come at a higher administrative cost to providers, such as for group support cancellations cancelled. Providers suggested that they should be able to offer programs of support to participants, whereby the participant agreed to attend a series of supports , especially group supports,and also agree dthattheyshouldbeclaimedforthosesupports even if they did not attend session .Some providers also asked that the NDIS set its prices much earlier as the Boards ofprovidersweretypicallymakingtheirdecisionsaboutthenextfinancialyearinthethirdquarteroffinancial year anda ndther current release scheduledidnotallowthemtobefully informedinthede cision making .**Discussion***Timing* *of The Annual Pricing Review And Indexation* The review considers there would considerable merit changing timing annual pricing so provider awareearlier policy changes NDIA intended make.The review also considersthat given uncertainty around economic conditions during COVID-19 pandemic Australia emerging pandemics,NDIAshould undertak eannualpricingreview20 2 but instead monitoreconomicconditions carefully promptly respond emergings issues. The review sees merits publishing indexation methodology price limits providers better estimate future budgets recognising NDIA unable index announce until after Fair Work Commission madeAnnual Minimum Wage Decision usually occurs middle June each year. Review consid ers most appropriate for price continue indexed follows: • Price limits delivered Disability Support Workers should be by Cost Model on July yearly noting model based minimum wage rates specified in SCHADS Award. redacted •Price Limits Capital Supports –Support Categories (Transport),3(Consumables)5(Assistive Technology) and6(Home Modifications Specialised Accommodation)shouldbeindexed` with movement ABS Consumer Price All Groups weighted average eight capital cities over months preceding the March Quarter indexing date. https://www.abs.gov.au/ausstats/abs@nsf/mf/6401 **Annual Pricing Review: Final Report Page of **

    Disclosure Log

    Provider Administration and Participant Flexibility

    • Price limits for other supports should be indexed in line with the weighted movement over the previous twelve months in the ABS Wage Price Index (Australia total hourly rates excluding bonuses) and the ABS Consumer Price Index All Groups weight average capital cities) over preceding March Quarter indexation date weighting). The Review has examined Fair Work Commission determinations that have materially affected key parameters Disablity Support Worker Cost Model considers price limits delivered by Disability Supports also increased:
    • July take account changes flowing from Fair Work Commission’s Annual Wage Review ; anthology.
    • December final tranche Fair Work Commission Equal Remuneration Order . The Fair Work Commission FWC made Decision [ ] (FWCFB ) will increase casual loadings workers employed SCHADS Award public holiday Table 2]. table: | Saturday Sunday Public Holiday Casual Loading – /7/2019 50% -100%-300% Casual Loading – /7/2020 75% 125% 175% Review notes Agency already indicated NDIS Disability Support Worker Cost Model relevant price limits adjusted accordingly July 2020.

    Programs of Supports

    The Review also supports introduction programs whereby providers enter contracts provision program towards achievement specified outcome. Under support approach, providers claim participants who do not attend part as though they did attended cancellation provider had capacity deliver this is important include safeguards arrangements including cannot be longer weeks unless specifically allowed Price Guide and participant

    DISCLOSURE LOG

    Provider Administration and Participant Flexibility

    should be able to exit from an agreed program of supports without cost, subject to an guaranteed notice period which can no longer than two weeks. Supports delivered as part of such programs would not fall under short notice cancellation rules. The review believes these arrangements will make it easier administratively both providers’ participants, as well as allowing better workforce management for service providers while reducing impact on others due current short notice cancellations. Under existing agreements if a group session is booked with say three people but one does cancel then other two do have pay anything extra. If provider cannot find another participant at last minute they may ask remaining two to cover costs otherwise budgeted rate (e.g., instead paying $5 per person total). In case there are any cancellations within this arrangement either party could reschedule some sessions later so that everyone gets their services eventually whilst also helping manage staff more efficiently in terms money spent. Several studies across different sectors show benefits gained through ‘programs-of-support’. In its submission regarding Medicare Benefits Schedule Review Allied Health Reference Group 2018 Allied Health Professions Australia highlighted how frequent dropouts during groups significantly affect finances. They argued:

    “Group allied health services belonging subgroup require adjustment ensure providers offer group services without undue risk income loss because of cancellations by participants issue currently limiting use.” The review acknowledges concerns raised from consultations between advocates and participants about using program support approach returning themselves quasi-block funding model. However, commercial world shows similar programs can be beneficial especially when all parties involved know exactly what happens throughout term time period overall advantages outweigh risks recommend careful evaluation guidance materials produced National Disability Insurance Agency for participants including right choose not engage service via such arrangements initially only suitable offering group supports

    Group Rates

    The review considers simplifying NDIS Support Catalogue removing various worker-to-participant ratio items. Providers

    Disclosure Log

    Provider Administration and Participant Flexibility

    would divide the number of worker hours by the number of participant hours to derive their own fractions of hours to charge participants and would claim for these hours against the 1:1 support item and subject to the standard price limit. For example, one worker delivering a one-hour session on Saturday to three participants is claimed as (\frac{1}{3}) an hour per participantsubject tothe 1:\Saturdayprice limiterather thanas currentlywhereanhourisclaimedforeachparticipantbutsubjetocareduced1::3` saturdaypricelimit.This is discussed furtherinChapter~4.

    Recommendations

    Recommendation (a) AnnualPricingReview

    * The NDIA should not undertake an annual pricing review in [2020]--[21]

    buthinsteadmonitor economic conditions carefully asthe COVID-[19]pandemic progresses andrecovery, promptly respond toremitting issues. * TheNDIAshouldundertaketheannualpricingreviewfromJulytoDecember each year(commencing [2021]), reporting infebruary/marchofthefollowingyear ot heBoard ofthenDIAthroughtheadministrativeChiefExecutive Officerwithchanges takeffect from thenext July.\

    Recommendation(b)AnnualIndexationOfPriceLimits

    TheNIDAshouldecreasepriceslimitsduring 2020tomaintaintheirrealvalue through thefollowingindexation arrangements: i) Price limits for supports delivered by Disability Support Workersshould besetby NDISDisabilitySupportWorkerCostModelfromoperative dateoffairWorkCommission’sAnnualWage Review; ii) PricesupportsforCapitalsupports–SupportCategories(Transport),Consumables),(AssistiveTechnology) anHomeModificationsSpecialised DisablityAccommodation – should be indexed on \(``7:``in line withthe movementABSConsumerPricesAllGroupsweighted averageeightcapitalcitiesover months toMarchQuarter preceding indexationdate; and iii) Pricelimitsforsupporthoulderbeindexedon \(( ext{7}:) inline weightagemovementprevious twelvemonthsABSWagePrice IndexAustralia total hourly rates payexcluding bonusesand ABS ConsumerPriceIndex All Groups weightedaverage eight capital cities over monthsthe March Quarterpreceding indexingdate (80/weight). That,additiontoannualindexationarrangementsNDIAshouldalsoreset allpricelimitsdeterminedbythenDSDisabilitySuppport Worker Cost Model infollowingFair Work Commission determinationswitheffect from datedetermination.

    **AnnuaPricingReview 2020-21:**FinalReport Page~[270]of [1049]

    Disclosure Log

    Provider Administration and Participant Flexibility

    • i) December 1st, 2020 - For final tranche of Fair Work Commission’s Equal Remuneration Order [MA000100 PR525485];

    ii) July 1st, 2020 – Adjustment in shift loadings on Saturdays & Sundays within SCHADS Award per Fair Work Commission Decision \([[2019] FWCFB _7096\]) .

    Recommendation (3): Programs Of Supports

    The NDIA is advised to amend NDIS Price Guide from January 1th , 2020 onwards so as it clearly states that providers can enter into service agreements for group support programs subjecting them with following safeguards:

    • I) The duration should not exceed a period longer than twelve weeks unless specifically allowed under the NDIS Price Guide;

    II) Participants must be able exit an agreed program without cost provided they adhere strictly adhered notice periods which cannot surpass two(week); * ***III) Introduction of such programs needs careful evaluation.****IV) Guidance materials need production prior introduction.

    Disclosure Log

    Price limits for 1:1 core supports

    The review was conducted as per its Terms of Reference to examine assumptions outlined within the National Disability Insurance Scheme’s (NDIS) Disability Support Worker Cost Model.

    Current Arrangements:

    The price caps on core support services were determined using this cost model published fully details June 2019. It estimates costs associated every billable hour including base pay; shift loadings holiday pay salary supervision utilisation corporate overheads margin. Base rates align Social Community Home Care Services Industry Awards 2010. The model contains key parameters determining level these prices vary based intensity skills experience worker delivering sleep over time day week delivery TTP provider claims. These concepts are defined current NDIS Price Guide follows hierarchy applies group following criteria:

    • Time delivered;
    • Dayweek delivered;
    • Standard Intensity High Intensity; If high then Level standard, Level or Very High Intense and whether eligible Temporary Transformation Payment.

    Disclosure Log

    Price limits for 1:1 core supports

    Time of day and day of week

    In determining which price limit is applicable to a support, providers should note that:

    • A Daytime Support occurs if it’s delivered between 6 am and 8 pm
    • An Afternoon (formerly Evening) Support happens after 8 pm but before midnight.
    • Overnight Support takes place from mid-night until early morning (midnight - 6am) . The provider must also consider these factors when deciding on an appropriate rate level;
    • Weekdays are Monday through Friday,
    • Extra rates paid during weekends or public holidays replace shift premiums rather than adding them up with afternoon/overnight shifts; and extra weekend/holiday pay doesn’t increase further once service ends past eight PM.

    Disclosure Log

    Price limits for 1:1 core supports

    transforming their businesses in the move towards a more competitive marketplace. This replaces the Temporary Support for Overheads.In order to access higher TTP price limits, publishers will need:

    • publish service prices;
    • list business contact details on Provider Finder; ensure those updates regularly; participate annually market benchmark survey approved Agency. Providers must meet these three requirements include contractual arrangements participants entitled to use TTP support (and). The first year can start making claims using TTP from July until March to comply with all three compliance requirements later years, providers will be compliant financial year noting Benchmarking Requirement met up December provider’s intention next Benchmarking Survey after that date actual participation most recent Benchmarking Survey Providers who become non-compliant during should not claim items while they are non-compliant.Every item scope has two and two price limits The non-TTP used by providers complies conditions.TTP items used by providers complying example given following Table. | | | |-| |01_011_0107_1_1||Assistance With Self-Care Activities - Standard Weekday Daytime| |01_011_0107_1_1_T||Assistance With Self-Care Activities - Standard Weekday Daytime- TTP| There is no formal registration process for TTP providers.Indicate intend fulfilling the through payment system They required acknowledge Price Guide terms including applicable when submitting request Myplace Provider Portal By claiming TTP NDIA or plan manager warrant complied intended comply relevant time Plan managers responsible ensuring TTP registered as proof of compliance However, non-registered eligible use line items services delivered non-registered providers.Table 3 sets out key assumptions current NDIS Disability Support Worker Cost Model.

    Annual Pricing Review: Final Report

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    Disclosure Log

    Price Limits For 1:1 Core Supports

    • Whether casual-to-permanent staff ratios, utilisation rates and supervision ratios vary by day-of-the-week or levels of workers?
    • Whether provision-for-overheads are adequate?
    • Whether allowance-for-margin is sufficient?

    High Intensity Supports

    Feedback from provider community indicates desire for reform definitions used within NDIS Price Guide. Most providers consider definition higher-intensity supports unclear & too complex, in addition creating difficulty participants.A number submisssions suggest assessment tool should develop to aid classification intensity-supports some-provider developed such tools internally use. some-providers recommend collapsing distinction between intensity-levels entirely or part as means lowering administrative burden saving time.It further suggests that providers rely on reports medical specialists determine appropriate level support.There were also suggestions need agree upon when developing participant’s plan included in ease interpretation application to agreements. one-provider points out current criteria high-intensity supports created perverse incentive manage participants’ needs optimally.some.providers argue some-higher-intensity-supports conditioned instances challenging-behaviours requiring management per shift whereas effective care ideally result fewer instances these behaviours.If those behaviors successfully managed the support attract lower rate remuneration under current criteria. Accordingly recommended adopting guidelines supporting clients with concerns did not frequent continual criterion instead relied strategies put place by provider behaviour support specialist.somesubmissions argued registered providers cannot deliver supports-participants without required skills training Therefore suggested link requirements-of-the-participant and remove according skill-experience worker.submission-review also argues increase price limits-for-higher-intensity reflect additional cost delivery majority of consulted however favoured linked-to-skills-and-competencies-staff.

    Leave Provisions And Shift Definitions

    The vast-majority submissions indicated no difficulties determining day-day-week provided.The demarcations outlined SCHADS Award considered very clear easy comply practice only area confusion surrounded afternoon night rates.Suggested afternoon

    Disclosure Log

    Price limits for 1:1 core supports

    The start time limit could move forward from “afternoon” at 6pm because participants found confusion with its current commencement point being set as afternoons. Some service providers indicated issues regarding provisions based around times during a shift if they had provided support past midnight (8 pm). The award requires them paid penalty rates throughout their shifts when this happens; many services are delivered exactly then instead due to high demand. Other operators felt responsible managing staff schedules rather than following specific shift-based rules about timing of delivery versus employment period within it - which is what concerns most people here now. The NDIS price guide allows higher charges per entire session if crossing pricing points but not all were aware or used these options correctly, leading some to charge full rate even though just part was needed. Pricing inconsistencies across states exist where public holidays differ in number between regions like Queensland having more days off compared others and thus affecting labor costs significantly depending on location. Some areas have half-day holiday leave while others don’t account such variations into models yet. Public holiday disclaimers should be included stating that increased fees apply accordingly according to provider feedback. Under the SCHADS Award workers get an extra week’s annual leave beyond ten weekends worked annually unless explicitly accounted by cost model currently making no allowance for this benefit assuming business efficiency outweighs additional liability incurred from doing so.

    Feedback also highlighted broken shifts occurring with partial coverage over less-than-full time periods causing rostering difficulties and losses as claims need exact splitting. It suggested applying whole-shift penalties whenever any portion falls under a penalty rate would align wage costing better, as recommended. Only limited input received regarding whether casual-to-permanent staffing ratios varied based upon day-of-week or worker level; providers generally assumed constant elements throughout weeks regardless levels involved until noting weekend/evenings often required more staff which could vary assumptions made within current cost modeling framework.

    Disclosure Log

    Casual and permanent staff mix

    Many providers indicated that the 80%-permanent to -20%-casual ratio used in the cost model was no longer appropriate and there’s a strong trend toward increased casual employment within this sector. Permanent-to-casual ratios reported varied widely across different provider submissions but averaged around roughly even splits (e.g., either -80/-20 or vice versa). Subjecting responses were limited, modalities tended towards one split over another (either, -or). Members agreed on current assumptions being too low; they considered actuals closer at ~~40%, regardless if metro-, regional-or remote areas. A number submitted noted changes to these proportions throughout year depending upon factors like availability of staff, with public holiday/weekend employees typically being casually employed.The feedback from providers also pointed out varying ratios based service nature provided. The increasing use of casualization driven participant demand & expectations for flexibility. Providers highlighted evening supports’ high usage of casuals which raised costs significantly. Current assumption equating all shifts equally inappropriate* some attempted moving more permanently workforce difficult due frequent required flexibilities some innovated experimenting permanent casual arrangements such guaranteed minimum hours choice working when wish` cost model allows agency workers 25% higher expenses rostering art science sometimes needed unavailable.“ Although others never used them

    Utilisation

    Cost recognises not all work is billable allowances made legally break periods training administrative tasks cost per hour disability support inflated less than complete labour utilised. Training requirements assumed higher intensity very so reflected lower levels utilization those workers Provider submissions challenged operating benchmarks in the cost regarding utilisation rates Cost assumes efficient rate standard-intensity disability support and lower ones for higher intensities Feedback most indicated that assuming rate utilized within model was incorrect.

    Disclosure Log

    Price limits for 1:1 core supports

    was too high with some providers further suggesting that cost model did not adequately reflect sufficient time training development Staff A number Providers contended turnover increased Training Time Cost Model had make allowance associated With Staff Turnover. However while almost universal feedback from providers efficient rates labour utilisation assumed In The Cost Model were Too High there very limited responses outlining actual Rates Of Staff Utilisation Feedback From Some Providers indicated utilization rates lower part-time workers inability schedule therapy sessions Participants back back results Lower levels utilization does travel between shifts . some members Costs Working Group commented They Had % -% year And That Training Induction close double such compared stable team this is exacerbated complex needs behaviour higher staff Higher complexity also requires much More training Team meetings debriefs compulsory personal Development which all lower utilization Supervision ratios The costs provides supervising disability support Workers Cost assumes an Efficient ratio worker supervisor To one Cost Assumes supervisors have same shift loadings leave entitlement salary on-costs as they manage and require skilled supervisors Submissions most providers contend supervision used in cost was too unrealistic compared Actual ratios However, some providers indicated able achieve spans control but expense of Much higher hourly remuneration Limited feedback provided submissions Ratio achieved by providers Spans Control reported differ markedly depending Number casual employed provider Workforces dominated could have supervision orders magnitude than benchmark There suggestions should be based headcount rather full-time equivalent workers because maintained that Disability Support rarely work full-time hours One counselled actually more closely linked number participants serviced rather the number supervised The supervision varying nature particular support experience level care advised required Level 2 and supports required intensive turn elevated for more intensive Supports appeared considerable

    Disclosure Log

    Price limits for 1:1 core supports

    agreement amongst providers that it was difficult to set a generic assumption for the supervision ratio, in part because it varied as a result of a range of factors, particularly the rate of casualization of the workforce. Members of the Cost Model Working Group raised two further issues:

    • Supervision ratios were higher for casuals. More casuals are required to deliver the same number of hours and each requires supervision. Thus, twice as much supervision could be required for casuals over full-time employees;
    • One provider indicated that it was possible to have 3 or 4 workers completing the total hours of one full-time employee, and it is the number of people supervised that matters for costs, not the number of hours delivered.

    Allowances

    Submissions indicated that providers paid a range of additional worker allowances that were thenot by required by law. These entitlements individually were not significant but collectivelywere non-trivial. Some providers indicated that they were around 1% of base salary costs.The allowances paid by providers were broad-ranging, and included:- travel allowances;- regional allowances;- telephone allowances;- meal allowances;- standby allowance;- shift leader allowances;- foul linen allowances;- dirty work allowances;- fork lift allowances;- district allowances;- performance allowances;- immunisation allowances;- flu vaccination allowance;- professional development leave;and-provision for wellness days.One member of the Cost Model Working Group mentioned that they pay for First Aid training, and pay the attendant allowance for all attendant care workers who do home visits.

    Disclosure Log

    Price limits for 1:1 core supports

    Payroll Tax

    The cost model does not include an allowance for payroll tax as most jurisdictions exempt not-for-profit organizations smaller than this organization from paying it. The vast majority of submissions report no payrolls taxes because these are exempted, another minority reports they were paying them though.

    Workers’ Compensation premiums

    The cost model allows other expenses related to disability support workers’ salaries such as superannuation at current statutory rate (of salary including leave) and worker’s compensation insurance at base salary plus leave. Those who detailed their premium paid said on average about 3 percent while others say less but varies per state, complexity leads higher costs so between three-and-five-point-fifty is typical.

    Disclosure Log

    Price limits for 1:1 core supports

    One member of the Cost Model Working Group commented that providers are subsidising worker travel by paying the $78$ cents per kilometre required by the SCHADS Award. They estimated that if this was included in the models’ definition of overheads that would increase it by around (\approx{5})%. There was concern that as the current allowance for overheads in the model does not cover travel allowances, this advantaged organisations who did not have to travel much or far.

    Margins The cost model incorporates an allowance for the profit margins that providers need to earn

    to attract and retain capital in the disability sector.The cost model provides for a {2}% margin on top of other costs.This equates to a rate of return of ${}^{+}{8}$% against working capital equivalent to three month’s wages and entitlements.A majority of submissions that broached the issue reported that profit margins were negative at the moment and many were incuring significant financial losses.Some providers further highlighted that their margins had been negative since the NDIS was rolled out.However, a limited number of total submissions responded to the issue of profit margins.Feedback on an appropriate level of profit margins was even more limited insubmissions,the paucityof commentthatwas offered tendedto suggestalevelaround ${{}^{{}}{}}{{}{1982}}}Act 5$% as minimumrequiredt ensureviabilityefficientlyrunproviders.## OthercostmodelissuesThere wasthe feedbackin submissionsthatthe demandfor suitablyqualified workersinthedisability supportsectorhad led mostprovidertoadopt industrial agreements thaset ratespayexcessSCHADS Award.Itwastendedthelabour market conditions weresuchtha awardrates payupon which themodelpredicatedwere no longerappropriate.Appropriate, someprovidersrecommended thatthemodelfunding shouldreflect average industry payandconditions rather than those setout inawardNDS notedinsubmissionagrowingnumberstatesterritoriesareintroducingportable long service leave.SomemembersCost Model Working Groupconcernedabout portablelongserviceleave loading some jurisdictions.Theynotethatmoststaffleftafter fiveor six years,solongservicelayeawas not accrued and thus nota major cost currently.Membersconsidereditdifficulttopredictexactcosts long servicelye but estimated it atroughly{\approx} {+}{0}% wages.Other membersnote the different systems for long servicye between statesled to higheradministrativecompliance costs providers. Annual Pricing Review $20-21$: Final Report Page ({{}{}}{52}$

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    Disclosure Log

    Price limits for 1:1 core supports

    Table 6 compare the non-TTP and TTP price limits for NDIS supports for attendant care that applied, from July 07/24 March 2020 (before COVID loading was introduced), to those payable in July 05/2019:

    • icare - New South Wales workers compensation scheme;
    • Victorian Transport Accident Commission(TAC);
    • Worksafe Victoria;
    • WorkCover Queensland; south Australian Lifetime Support Authority ;andVeterans Home Care Program of Department Veterans’ Affairs.

    Table 5 NDIs hourly price limits for non-TTP & TTP support items

    | |NDIS Level 1|NDISTTLevelP 1|NDIS Level P3|NDISttPLeveLl|NDISTTLevelP l| |-|-|-|-|-| |Weekday|$$58.31||$$57,15||$$61 .ll||$€60 ,04||$€64 | |Evening|$$58.31||$$62,69||$$63 ,O6||$$67.44||$$66。23||$€70 。61| |Night|$$59、40||$$63·S5||$$64 ·24||$$68.69||$$67.47||€71.92| |Saturday|$$72-69||$$78 -14||$$78.63||$$84・oB||$$82•s8||$€88.03| |Sunday|$$94 ;52||$$lOl.6I||$$IOZ.23||$$Io9:32||$$lot.J7||$€II4.46| Public holiday | $ $ l I B . S A || $€ 127,21 || €D 27.9T || $€ D 6A ,84 || $€ D 4,42 || $€ 143 ,29 | Inactive overnight | $ $ Z I 4 。O3 || $€ z i a o s t r e n g h t y f u l d i m p r o v e c e Inactiveovernight | $ $ Z I 4 : O T || $€ z i a o s t r e n g h t y f u l d i m p r o v e c e Establishment fee | $€ 5 oo。o0 || $€ 5oo.o0 || $€ 5OO.O0 || $€ SOO、O0 || $€ 5 OO、O0 ||€ 500·00|NOTES: Rates as published excluding temporary measures (NDIS - COVID increase).

    Table 6 Comparative Scheme hourly fees

    icare NSW | TAC(IQRS)* WorkSafe Victoria IQRS)WorkCover Queensland SA Lifetime Support Authority Veterans Home Care** Weekday|$$48.88||$€49.ro||$€48,s1| Evening | €53 ,60 | Night|$$57-74||$€S0 。56||$€54 .54||$€53 ·34||$€85,50| Saturday|$$67・lZ||$€67 ,80||$€67 ・so||$€71。o0||$€65 oT||$€85:50| sunday|$$86;76||$€67 :Iz||$€86、76 || $€7 I O O|NOTES: The rates are payable when services independently reviewed against Quality Standards.Rates as published excluding temporary measures (NDIS - COVID 10% increase).* For TAC clients there is no limit on the co-payment that can be asked by provider.€** Recipients of Veterans Home Care can also make a co-payment $ per hour up to certain limits.

    — PAGE TEXT START — This document was released under Freedom Information Act 1982 by National Disability Insurance Agency. FOI documents often have redacted text: a grey or solid-filled box covering part of page sometimes with small exemption code printed nearby (redacted). When OCR runs over one such it usually produces short garbled fragments rather than misread real word. do not delete this text; leave blank space instead, and mark has_redactions. If you’re unsure whether garbled text represents an actual name/phrase/redaction etc., treat it like possible redaction marker. does not list redactions as wording_change — it’s marking something withheld from public release. is_low_confidence if unable confidently reconstruct structure due to poor layout/garble/misreading/etc.. notes explain what uncertain in case of low confidence rendering. can’t reword/reconstruct any content without explicit flagging for correction via redacted inline code span where necessary. such corrections must always listed explicitly in wording_changes section below (if present). — PAGE TEXT END —

    Disclosure Log

    Price limits for 1:1 core supports

    The NDIS Weekday standard rate (without TTP) is between 4.5 and 9.4 higher than those of comparable state schemes (average** 7.*.*) It is ***23.*.9*** lower than the DVA fee. The NDIS Saturday standard rate (without TTP) is between **2. .4**% to *14. *.9*% higher than those in similar state schemes ( average 8. .`). itis lowerthantheD VAfee. However, it’s unclear how much other scheme fees can be compared with these, given that they operate differently depending on whether services are commissioned or not, or if client co-payments also apply as billable costs like training & supervision expenses do under icare. icare engages providers through a tender process; consultations indicate providers may charge directly for such additional costs over hourly rates but this isn’t reflected within published NDIS price caps unless adjusted accordingly using utilisation parameters. Workers Compensation Premiums: NDIS assumes workers’ comp premiums at *

    Disclosure Log

    Overheads

    The results of a major benchmarking study of non-for-profit organisations in Australia by Nous Group are illustrated in the following diagram. 32. The study found the median share of organisation revenue spent on back-of-house functions among reporting organisations is 10.2%, with 25% spending less than €�.�.% of their expenses on such activities.

    Figure 3 - Nous Group Study of Back Office Expenses of Not For Profit OrganisationsNous Group Study of Back Office Expenses

    An earlier study conducted by National Disability Services, which considered facility costs and general administration as well as back-office costs, determined that overheads accounted for an average of €�.% on revenues from these organizations.

    DISCLOSURE LOG

    Price limits for 1:1 core supports

    • 49.7% of all claims (by dollar) were claimed against support items eligible for the higher price limits ($$1{ , }217 billion out of $ ( { .} )

    That is almost almost, and not to access the higher TTP price limits. some providers have indicated that they preferred not raise their prices so that could undercut competitors who did thus increase their market share.Moreover, those providers chose operate under lower non-TTP price limits more than %of all claims below relevant lower non-TTP price limit about %all claims more than above relevant lower non-TTP price limits.Even among providers chosen accessed highers TTP price limits more than %claims below relevant higher TTP price limit,about %more than five percent below relevant lower non-TTP price limits.DISCUSSION### NDIS Disability Support Worker Cost ModelThe publication structure NDIS Disability Support Worker Cost Model has provided disability sector with full transparency regarding setting price limits Scheme allowed provider benchmark operations assumed efficient costs outlined model.Given baseline price limits intended represent efficient coststhe TTP survey results taken on own provide evidence ndis disability worker may correctly estimating efficient costs although some effects countervailing.The average Permanent Share workforce respondents (%lower current assumption). Moreoverefficient 25th percentile estimate also lower.Model assumptions.utilisation rate among survey respondents (87.7%to920%). Howeverthe effective estimates in line.current overheads percentage as loading direct care costs)among surveyrespondents is higherthancurrentModelassumptions.Moreover theeffectivepercentileestimatealsohigher.Model assumptio span of control among survey respondents slightly higher than currentModelAssumption.Meanwhiletherelativeefficaciousestimatesconsiderablyhighercurrentmodel. Annual Pricing Review: Final ReportPageof1049

    Disclosure Log

    Price Limits for 1:1 Core Supports

    The NDIS Disability Support Worker Cost Model does not currently provide allowances paid to workers in addition to their salaries (other than shift loadings or superannuation). According to a TTP Benchmarking Survey, these allowances typically amount to around 1% of base salary. However, this survey excludes results from providers who do not access higher price limits under TTP benchmark surveys; such providers are likely more efficient due to lower costs since they have chosen against accessing those high-price limits. Only approximately half ( extbf{59.6% extperiodcentered}) eligible providers claim with TTP pricing while less than extbf{ rac{half}{of}} completed respondents did so within deadlines—resultantly providing data on just about one-quarter (around) all NDIS service providers employing disability support staffs*“. Assuming overhead distributions among non-TTP claiming firms mirror that found amongst TTP participants but at reduced averages reflecting cost savings allows generating mixed statistical profiles across all suppliers.” The Review estimates an effective provider’s share would be between (\mathit{2^{nd}~percentile}) and ( extbf{(median estimate)} $ imes$ $0.74 + $ imes 38 = $54, extbf{$557} extbackslash$“ Thus the review suggests overhead expenses for such entities lie somewhere in range: (between) extbf{[}$ extstyle {14}.{} extstyle {.{}4}%$, ${16}.{%.}7%] extstyle { extnormal{{)}} of direct expenditures. ootnotemark[ extsuperscript{34}] Moreover, some associated overheads relate to transport costs not separately reimbursable by these organizations; a survey revealed average travel expense per worker annually was $1, 000. A DSW Level I earning $27.**61 hourly over extbf{ rac{a}{week}} totaling approximately $5, 4, 5,57 yearly income translates into roughly $7,$0,000 annual care expenditure excluding transportation fees which represent only about .% extperiodcentered {}four percent increase on this figure currently reflected within providers’ overhead accounts.“

    There is also strong evidence that certain service suppliers operate at or below current price limits with nearly forty ( extbf{(~~$ extstyle {{~40.}}}$$ extstyle {%}) eligible firms choosing against higher TTP pricing options.

    Disclosure Log

    Price limits for 1:1 core supports

    management fees and Blue Care lists an hourly rate of $50.75 plus management fees (of about $6 per hour). On balance, therefore, the Review considers that there is no reason to increase the current set of price limits, although it would be appropriate to make some minor modifications to the NDIS Disability Support Worker Cost Model to better reflect the costs structures of efficient (( { }^{3} {}_{th})) percentile providers35 :

    • Decreasing the ratio of permanent to casual staff assumed in the cost model to {}/{}% line with the TTP Benchmarking Survey;
    • Increasing the share of staff assumed to take up their long service leave entitlements to % recognition of the move towards portable long service leave scheme sin some states and territories;

    - Decreasing the assumed workers compensation premium percentage from .%

    Disclosure Log

    Price Limits For 1:1 Core Supports

    • Increasing the provision of allowances (other than travel allowances) for support workers and supervisors to 1.%of salary,in line withthe average level observed inthetTP Benchmarking Survey.

    TheReviewnotesthe concerns raisedby some providers that theratioo f permanent tocasual staffdiffersbyshift.TheReviewacceptsthat thesevariations ,if theyexistare n ot accountedforinthenDIS Disability Support Worker Cost Modelbut thereviewdoes nothsufficient data availableto ittodetermineifthepracticesmake amaterial difference tot he overall costs ofe mployer s . The review suggeststhats tese matters should be investigated furtherinthene xt T TP FinancialBenchmarkingsurvey.T h e Re vi ewalsoknotesconcernsraised b y som ep rovidersthat th en DISDisability support worker cost model does not take into accounttheadditionalcostsofemploy ing Agency Staff.Th ere viewdo esno ta cceptthiscriticismasthescostsa rebyeandlarge, within them control oprovid erswho are responsibleform anagingtherosteri ng oft heir workforce. There vie wthereforeconsiderstha ny suchadditionalc ost saresbestattributed againstt he provider’s overheadsin the NDIS Disabilit ysu pportWorkerCostModel.

    High Intensity Supports

    Th er evie wn dosuppo rthe request bysomeprovidersth at then price limit for support itemsshouldbedeterminedbythem complexityofthestarticipant’ sn edsrather thanbytheskills and experience oftheses up port workers ascurrently.The Reviewacceptsthat participantswithcomplexneeds willoftenrequiremore funding ,bothfor more supports anda nd forthem ore skilledore xperiencedsupportworkers.However,thisisaplanning issue,n ot apricingissue.From apricecontrolperspective thee mporant i ssueistheinput costs o f t heproviderwhicharelargelydeterm inedb yt h e skillsandexperien ceo fsupp ortworkerwhodeliversths upport . TheReviewunderstandsthatsome providerswouldprefergreaterguidanceasto whenthey mayusethest Level 1Level2a n dLeve l3pricelimits.CurrentlythenNDISPriceGuide says that:

    A sup por ts is consideredahighintensitysupportif th ep artici pant requiresassistancefromas upp ortwor ker withadditionalqualificationsandexperiencerelevanttothep ar ticip ant’s complex needs. Thehigh intensity pr icelimitsmaybeconsideredwhen:

    • frequent (at least one instance per shift) assistance ist required to manage challengingbehavioursthat require intensive positive behaviour support; an do r
    • continual active su pporti srequired due tow high medicalsupporth needs(such as unstableseizureactivityorr espiratorysu ppot) In determining which price limit for High Intensity Supports should applyt ogiv ensup port, the providershould considertheskills and experience ofthe workerdeliveringthesth uppor tin general , then Le ve llprice lim itappliestomosthi gh inten sit y supports.However,i f t heparticularinstanceofsupportisdeliveredbyaworkerwho doesnothave t h e skillsandexperien ce tod eliver a hi g hin tensity supp ort thanne le vel1pri celine mits

    Disclosure Log

    Price limits for 1:1 core supports

    should be applied. If the particular instance of the support is delivered by a more highly skilled or experienced worker than can consider applying Level3 with prior agreement.

    Disclosure Log

    Price limits for 1:1 core supports

    that support as determined by the applicable Industry Award or Enterprise Bargaining Agreement (EBA). For NDIS billing purposes the provider must first determine the day of the week on which the support was provided on and then the time of the day during which the support was delivered. (Note: weekday means Monday, Tuesday, Wednesday, Thursday or Friday).• A Night-time Sleepover Support is any support to an individual participant delivered on: a) commences before midnight on a given day and finishes after midnight on that day; anda) is for a continuous period of eight (8) hours or more; da)a)b)c)the worker is allowed to sleep when they are not providing support.•A Public Holiday Supportisany supporttoanindividualparticipantthatsarts atoraftermidnightonthenightpriortoapublicholidayandendsbeforeormidnightof that public holiday(unless thatsupportisan Night-timesleepoversupport.).•ASaturdaySupportisa ny supporttotoanindividuallparticpants thastartsatorafter midnightsont he night priortosat urdayendsbefores ora tmidnoi ghtofs aturday(unnlessthatsupportisasPublicHolidaySupp ortoranN ighntimeslee p oversuppor ts.) • ASunday Suppo rt isa n y sup porttot oana ndividual partic ipantthatstarts ata raf ter midnightons tehnightpriortoa Sunday end sbeforeoras tm id noig htos taS und ay (unlessths upport i saP u blicH olidaySu pp ort oran N ig h nt ime s l eep over Su p por ts).

    • A Standard Day Support ia any other supp ort, and iseither: a) aWeek day S upp ortia anysupp or tot ana ind ividual part icip anttha st artsa tor afte r6:00 am anda ends befor eo ra8 :0 pm on asingle week d a (un lesst ha ssupp ot isap ub lic Holi dy SUP po rtor aanight-time sleepover supp ort).b)a)AnEveningSupportisa ny supporttoanindividualparticipantthata fnishesafter evening supports. Ifasupporttotoa na individualparticpants doesnotmeetoneoftheabovecriteriathenit needs tobe billedastwoormoreseparatesu pp ports.## Night-time Sleepovers Supports

    Disclosure Log

    Price limits for 1:1 core supports

    Night-time Sleepover Supports have a price limit that is inclusive of the cost of two hours of any supports provided to the participant for the duration of the period. Providers may claim for third or additional hour at Saturday rates on weekdays, or at applicable rates on other days (Saturday, Sunday or Public Holidays) Note Night-time Sleepover Supports apply to any day of the week and public holidays pending criteria met as described previously.

    Public Holidays and Annual Leave The Review notes concerns raised providers number

    differs state territory long standing practice employers Northern Territory allow workers one or weeks annual leave. Also noted SCHADS Award provides an additional weekly annual leave employees work more than four ordinary hours weekends yearly accrues.The Review accepts variations not accounted NDIS Disability Support Worker Cost Model sufficient data available overall costs employers suggests matters investigated further next TTP Financial Benchmarking Survey.

    Temporary Transformation Payment (TTP)The TTP loading introduced some providers balance drive efficiency requirement swiftly expand supply Markets continuing develop increases market supply improvements production efficiency required Improvements imply reductions in run expansion necessitates higher short medium term prices maintain expanded volumes disability thus needed existing supply incentive redirect resources from sectors economy Level set Loading was reduced points July thereafter line with NDIS Pricing Strategy said:

    caps should be set movements transitional levels … recognise costs facing adjusting new arrangements time unwind established agreements encourage growth while driving efficient through explicit decreasing loading sustainable price levels – about 75% clear statement expected glide path five years efficient phased reduction markets also conducted determine whether short-term price increases have

    Disclosure Log

    Price Limits for 1:1 Core Supports

    to expand supply, attract new entrants increase competitive pressure. The longer term it expected competition between providers will result reduction prices towards long run efficient price As market reduce towards long run efficient prices The caps imposed no longer binding case their removal can considered.The considers more than sufficient evidence disability supports continuing grow become more eficient noting again over half claims dollar relevant support items and those operating lower non Temporary Transformation Payment price limits more all below limit.Review eligibility requirements accessing high TTP price therefore strengthened suggest:

    • Providers active in were should only be able access if indicated NDIA July publish service NDIS Guide; continue listing business details Provider Finder ensure up-to-date participate Benchmarking Survey; o Should cease from closing date survey unless take part Benchmarking Survey.
    • Providers not activity who became active before should subject same criteria immediately above except indicate intention accept conditions first make claim rather than July 2020 after becoming active they should stop being eligible to higher TTP price limits closure year benchmarking survey Review also suggests Plan Managers receive attestation provider seeking against item subject higher TTP process claim.

    Price limits for 1:1 core supports

    RECOMMENDATIONS

    Recommendation 4)

    NDIS Disability Support Worker Cost Model Agency. The NDIA should continue to use the NDIS Disability Support Worker Cost Model to determine the base (non-TTP) price limits for supports delivered by Disability Support Workers based on the performance of efficient providers.The NDIA should amend the NDIS Disability Support Worker Cost Model (and the Insurance price limits determined by the cost model), from July 1, 2020: i Decreasing the ratio of permanent staff to casual workers to 70%/30%; ii Increasing share assumed take up long service leave entitlements to 100; iii Reducing worker compensation premium percentage to .7% viv Raising overhead costs as a proportion of salary to ; and, xviixi xraisng allowance provision support supervisors to %of salary.

    Recommendation 5)

    Temporary Transformation Payment The NDIA should reduce level Temporary Transformation Payment from percent to 6.%on July 1st, previously announced.

    Recommendation 6)

    Definitions Levels High Intensity Supports That definitions Level 1.2.,Level 3.support items used if worker delivering has skills experience would mean classified Social Community Services Employee level below maximum pay point SCHADS Award If worker delivering is someone who has skill experience that means they be classified at maximum pay point or minimum pay point under SCHADS award then use Level social community services employee level 2.Social and Community Services Employee level three.minimun pay point employed under SCHADS Award.Level item should be used if worker delivering above classification than SCS E L3 min pay point employeunderSCHADSAward Annual Pricing Review Final Report

    RECOMMENDATION 7) Definitions of Time of Day and Day of Week

    That the definitions of Time of Day and Day of Week in the NDIS Price Guide should be amended as follows:

    Time of Day and Day of Week

    In determining which price limit is applicable to a support, the important consideration is when the support is provided to the participant, not the shift of the worker used to deliver that support as determined by the applicable Industry Award or Enterprise Bargaining Agreement (EBA). For NDIS billing purposes the provider must first determine the day of the week on which the support was provided on and then the time of the day during which the support was delivered. (Note: weekday means Monday, Tuesday, Wednesday, Thursday or Friday).

    Disclosure Log

    Price limits for 1:1 core supports

    • An Evening Support is any support to an individual participant that finishes after 8:00 pm and at or before midnight on a single weekday unless it’s a Public Holiday Support or a Night-Time Sleepover Support.
    • An Active Overnight Support is any support commencing either:
      • At or before midnight during which time they finish past mid-night, or
      • Before six am in one given workday but finishing within said same work-day provided not being a Public Holiday Support Saturday/Sunday Support nor a Night-Time Sleepover Support. If such support does not meet above conditions then it needs billing two separate services.

    Night-time Sleepover Supports

    Night-time sleepovers have price limit inclusive cost duration period of up-to-two hours of any service rendered to participants, providers may claim third hour rates as per Saturdays’ rate if worked weekdays otherwise applicable rates (Saturday Sunday or public holidays). Note night-time sleepers apply all week days including public holiday pending criteria met.

    Price Limits for Group-Based Core Supports

    Current Arrangements

    NDIS price limits for group supports delivered by Disability Support Workers and their equivalents in the Assistance with Daily Life Support Category and the Assistance with Social and Community Participation Support Category vary according to the same factors as 1:1 supports, see previous chapter) two additional factors:

    • Price limits varies depending ratio support workers participants there different prices ratios; e.g., 1:2, 1:3, etc.
    • *Price limits also depend whether service provided centre or within a community. The NDIS Price Guide currently says that assistance access social recreational activities often occurs either setting, either at home or center. A hierarchy applies based on following criteria:
    • Time delivery;
    • Day delivery,
    • Whether standard intensity complex high-intensity (complex),
    • Provider eligible Temporary Transformation Payment,
    • Size groups staff-to-participants-and-
    • Centre or community location. For support not stated guide (e.g.two worker three participant) discuss appropriate line item payments, suitable price paid lower than limit. Providers of group-based services are permitted bill non-face-to-face services hourly price includes allowance face-to-face services. The price is relevant level day week).

    Disclosure Log

    Price limits for group-based core supports

    then the price limit Pn for the 1:n community based support is given by the following formulae: P_n = \frac{P + {(n - 1)} imes {\textstyle{{}^{}}{ extstyle{egin{array}{l} extstyle{(}}{{ extstyle{n}}}^{}- extstyle{{{(}}{} extstyle{-})}\end{array}{)}}~ {{}{}^ op_ot} ~ _{_x}~ {_y}~ x~ y~ z~ w~ v~ u~ t~ s~ r~ q~ p~ o~ n~ m~ l~ k~ j~ i~ h~ g~ f~ e~ d~ c~ b~ a~~ }

    Disclosure Log

    Price Limits For Group-Based Core Supports

    Group Based Rates

    The Issues Paper asked respondents to identify additional administrative tasks involved in offering group-based supports. Respondents were also tasked:

    • Developing separate Disability Support Worker Cost Models based on different utilisation assumptions (supervision/overheads). The preferred approach should be identified along these variables and why? or,
    • Moving towards simpler ratio-based approaches setting group-based prices while allowing providers claim non-face-to-face services. oR,
    • Maintaining current administration time within each support model; whether it’s fixed or longer depending upon duration. Many submissions did not select an individual option but supported simplified ratio-based methods claiming non-face-time tasks. Some mentioned variable nature requiring claims recouping true costs faced with participants’ assistance needs being claimed as well. There is little support from Option C, which suggests maintaining a built-in admin time for all groups regardless if they are shorter or longer durations. One provider argued that task variability depends heavily on participant size including tracking attendance, paperwork associated medication dispensing progress noting incident reporting management updating profile information. They suggested more complex high-support people need extra time due higher workload complexity. another respondent noted the duplication of work caused by increased number per activity such as communicating events activities times collating planners booking venues etc., varying significantly month-by-month between groups dependent staff compatibility needs etc.. The most common proportion was 10% other responses ranging up to about 25%. There were concerns price limits increasing ratios might prioritize larger groups despite ultimately choice belonging in hands of individuals profit margins bigger groups could incentivize this.

    Disclosure Log

    Price limits for group-based core supports

    Members of the Working Group on Group Supports raised the same concerns as had been eraised in submissions to the Issues Paper. Some requested having no fixed ratio at all, to allow ultimate flexibility. Providers could then charge or each time each support took

    Disclosure Log

    Price limits for group-based core supports

    preferred size of group for these type of supports could offer support for application of group support packages allowing providers provide activity averaging out ratios greater or lesser ratio where cancellations force changes specific situations.

    Figure 4 - Claims for Group Activities

    [Image not converted to Markdown – “Figure” – check the source PDF page for the actual content]

    Discussion

    The Review considers considerable merit replacing current pricing arrangement simplified arrangements whereby providers claim both direct service provision face-to-face supports as provided Providers divide worker hours participant hours derive fractions charge participants claim against standard price limit For example one worker three participants hour session claimed per participant subject to reduced rather than currently each participant but subject fixed capital allowance through separate item The Review notes change suggested last year sector did not accept however appears that sector become more comfortable non-face claiming opportunities can arise from simplification Currently there are over NDIS Support Catalogue proposed amendments some need

    Disclosure Log

    Price limits for group-based core supports

    The Review does not consider that the evidence about the capital costs of center-based care is sufficiently strong to justify a change in the amount of the fixed capital allowance but requires further investigation.

    Recommendation RECOMMENDATION)

    Group-Based Supports (RECOMMENDATION 8))

    • Item: Amend the pricing arrangements for group base supports such as workers no longer use various worker participant ratio support items and instead claim all supports against appropriate one-one support items apportioning time spent with groups among members within each group. Providers would also claim separate support item for fixed capital allowances per participant through centre based care providers should amend their claims accordingly, allowing non-face-to-face services under usual conditions rather than having an allowance built into price limit.ndia disability

    Capacity Building Supports

    The Review was required by its Terms of Reference to review the price control framework for capacity building supports, including therapy supports, by examining:

    • how price limits for capacity building supports (other than therapy supports) should be indexed or otherwise determined annually;
    • how price limits for therapy supports should be adjusted annually given outcomes from the Review on Therapy Pricing Arrangements;
    • whether different price limits might apply at various times during each day or week depending upon specific types of capacity-building services provided such as those delivered directly through therapists/therapy assistants or disability support workers.
    • if it is appropriate for providers delivering these kinds of services to recover costs associated with consumables used within their service delivery.

    Disclosure Log

    Capacity Building Supports

    • Improved Relationships – support to help a participant develop positive behaviours and interact with others;
    • Improved Health and Wellbeing – including exercise or diet advice to manage the impact of the participant’s disability;
    • Improved Learning – including training, advice and help for the participant to move from school to further education; and
    • Improved Daily Living Skills – assessment, training or therapy to help increase the participant’s skills, independence and community participation.

    Consultations

    The Issues Paper presented a number of issues with the current arrangements that had been raised by the sector, including: • Whether the price limits for capacity building supports represent value for money for participants and allow providers to recover the costs of delivering these supports? • Whether different price limits might be appropriate for different times of the day, or days of the week, for some capacity building supports, including for therapy assistants and capacity building supports delivered by disability support workers? • Whether therapists and other capacity-building providers should be able to recover the costs of consumables provided to participants as part of a support? Currently, if providers of capacity building supports also want to claim for the cost of any consumables used in the delivery of the support then they are also required to register for the relevant assistive technology and equipment registration group. Some stakeholders have argued that providers of therapy and other capacity building supports should be able to recover the costs of consumables provided to the participant as part of the primary support. • Whether the current indexation arrangements for the price limits for capacity building supports appropriately maintain their value? Currently, the price limits for capacity building supports are increased on 1 July each year in line the weighted increase over the previous twelve months in the ABS Wage Price Index and the Consumer Price Index (with an 80/20 weighting). The most common concern raised by providers was that there was a lack of alignment between the price limits for core and capacity building supports, where those supports were delivered by Disability Support workers. It was noted that the employer does not differentiate when paying the support worker regardless of the support delivered. The support line items redacted (Assistance with decision making, daily planning and budgeting) and (Individual training in the home)(General life skills)were raised in several submissions.`Annual Pricing Review 2020-21: Final Report Page 305 of 1049

    Disclosure Log

    Capacity Building Supports

    Respondents also suggested that the introduction of intensity levels and the TTP for core supports should be considered for capacity-building supports. One respondent suggested that some capacity-building supports require similar levels of competency to Level 2 and 3 core supports. A few respondents asked for support coordination price limits to be aligned to therapy price limits, as allied health professionals can also perform this role.Somesome respondents also arguedthattheNDIAshouldconsiderintroducingout-of-hoursprice limitsfor somecapacitybuildingsupportsinlinewiththearrangementsforcoresupports.Some considereeditsestimatesunviableotherthanduringweekdaybusinesshoursbecauseoftheadjustmentsanddo not offer services outside of those times.There was a concern thisthis might reduce participant choice.Conversely, other respondentssuggested introducing differing rates would add complexity topricing arrangements.A significant number of respondesthoughtconsumables shouldbe claimablebycapacity building providers where there provider may alsoprovidethe consumable.Therewas however,a wide variety ofsuggestionsin howto achievethisSuggestions included:· Claim under Quality Safeguard Commissions guidelines;· If the consumable isunderasetmonetarylevelthenitcouldbeclaimabled bythereprovider· A separate consumables NDIS plan budget thatproviders couldclaimfrom;orCapacity Building budgets shoulde include both supportandrelevancematerialsSeveral members Working Group CapacityBuilding Supports commented therapists in some similar schemes workers compensation schemes and traffic accidentcompensation schemesthey were allowed to claim for consumables up small dollar amountusuallyup $200The majority respondents suggested current indexation inadequate maintaining value capacity-building price limits particularly relative inflation applied core supports Therevarious suggestions appropriateindexation method apply Several adopted same procedure done with coresupportsdue crossoverworkers affected Fair WorkCommission’s minimum wage decisions increases built SCHADS AwardAnother submission linked inflatory indexation mostappropriate industry rather than general economy Some requestedthatprovidesof CapacityBuilding Increased Community ParticipationSupportsshould able claims non-face-toface time report writing former claimed similarsupports under core although comparable group currently have face-time inclusive limit. Annual Pricing Review 2020-21: Final Report Page3 of49

    Disclosure Log

    Exercise and Sports Science Australia raised two issues with the current price control arrangements for exercise physiology:

    • The hourly price limit for exercise physiology in NDIS ($166.99 between July 1st , 2019 - March 24th , 2020 )is lower than other therapy services’ limits within same period.
    • Unlike other therapies funded through NDIS program which are GST-free due being listed as ‘other health service’, Exercise Physiology isn’t included among these free-of-GST categories per Section38-10of A New Tax System (Goods & Services)Act from year 1999.

    Disclosure Log

    Capacity Building Supports

    Support Item Number Support Item Name Support Item Description
    09_06_0106_6_3 & Life Transition Planning Incl. Mentoring, Peer-Support And Individual Skill Develop & Establishing volunteer assistance within the participant’s home or community to develop skills. For instance, asistance in attending appointments, shopping, bill paying, taking part in social activities and maintaining contact with others.

    DISCUSSION

    Price regulation

    The Agent expects that health professionals will not invoice for consumables (i.e., tape, ultrasound gel, dry needles, wax therapy) used as part of an rooms treatment - The approved items is intended to be supplied for the worker to take home to assist with management their work related injury or illness. Conversely Workcover Queensland permits allied health professional claim following expenses on top fee service: supportive devices up $57 per item without prior approval; reasonable charges for supportive device up $199 per claim without prior approval and hire equipment negotiated prior. Items considered reasonable incidental expense are those actual taken including bandages elastic stockings tape crutches theraputty theraband grippers hand weights audio tapes CD education booklets disposable wound managemen kits Tape may charged where significant quantity is used Items must shown necessary successful treatment compensable injury.Workcover Queensland will pay for items regarded during course treat towels pillowcases antiseptics gels tissues disposalelectrodes bradflex tubing small non slip matting items procedures undertaken normally business autoclaving sterilisation equipmen laundry.The Review NDIS Therapy Pricing Arrangements reported in found accounts Australia’s established national market suggesting limited capacity influence prices services instead price taker. While early signs competition observed around 70% claims made at cap distribution significantly different from private market based evidence sector consultations benchmarking analysis outlined above line principles National Disability Insurance Scheme Act funded support represent value money costs of support relative benefits achieved cost alternative support recommended NDIA maintain

    Disclosure Log

    Capacity Building Supports

    caps on therapy services at least until the transition to the NDIS is complete and there is evidence that the distribution of NDIS payment claims is broadly in line with the distribution of prices observed in the private billing market. The current Annual Pricing Review agrees with the conclusions of the Therapy Review. The current Annual Pricing Review however concerned that some evidence may be distorting the market price limits for therapy service may be Table 8 compares the NDIS price limit comparison other schemes hourly rates: table 7 - ndis therapy price limit comparison with Other Schemes Hourly Rates:| Occupational | Physiotherapy | Psychology | Speech Pathology | Exercise Physiology** | dis (ACT/NSW/QLD/VIC) $193,99$193,99$24065 per consultation| nsw State Insurance Regulatory Authority|$196-80$19560|-||vic Transport Accident Commission|$10647$12229$16612$9690$9737| vic Worksafe Victoria$107.25$12829$17076$9707$11023| quld WorkCover Queensland$18300$18300$18300$18300$18300| sa Return to South Australia$18540$18540$18540$18540$14700| wa workcover Western Australia$19820$20025$25370$13935$20025| tas Comcare|-$205 80$24250- act comCare | -$191 dis (NT/SA/TAS/WA) $193,99$22462$23483$193-99$16699||department of Veterans Affairs|$89 per consultation$65perconsultation$10460 per consultaion$ medicare benefits schedule****(consultation > minutes)$6325 per consultatior$63.25 per consulation$63. notes: Current hourly maximum rates as published excluding temporary measures (NDIS - COVID increase). *Hourly rates estimated where consultation rates stated in fee schedule **Rates for other schemes are the GST exclusive rate; rates for the NDIS are the GST inclusive rate ***Medicare Benefits Schedule Fee Allied Health Services Chronic Disease Management In brief:• The price limits New South Wales on par with fees published by State Insurance Regulatory Authority physiotherapy and exercise physiology adjusting for GST but higher psychology•The price limits Victoria much higher than those two Victoria across all allied health disciplines •the price limit Queensland slightly higher except exercise physiology where WorkCover is 20% higher than NDIS rate adjusted for GST •price limits South Australia all higher Return to South Australia across all allied health disciplines Annual Pricing Review Final Report Page 310/1049

    Disclosure Log

    Capacity Building Supports

    • NDIS price limits in Western Australia (ACT/NSW/QLD/VIC) range from $193.99 on average, while those outside these states vary between $224.62, with adjustments made according to GST.

    These differences warrant further investigation as it’s challenging comparing them directly due to varying fee structures across schemes—some expressed differently or including additional payments like travel costs not covered separately under NDIS rules:

    Examples Across Different Schemes & Authorities:

    National Disability Insurance Scheme (€NDIS€):

    Hourly rates differ regionally within ACT/NSW/QLD/VIC at €193.99 compared to NT-SA-TAS-WA where they are higher,€224.62 per hour; providers can claim for time spent traveling but cannot seek reimbursement beyond certain limits and non-labor expenses associated specifically with their journey;

    State Insurance Regulatory Authority New South Wales: Regulated fees include standard consultations/treatments costing €83.30 each, two distinct areas consultation/

    treatment priced at €125.50 respectively complex treatments set around €166.30 hourly rate published is also €196.80 a 19% increase on average applicable when services provided outside clinical rooms cover travel cost additionally provider claims up-to-€$0.68 per kilometer traveled.

    Victorian Transport Accident Commission (VTAC): Fees vary based upon duration of service rendered in the clinician’s room ranging from $55.63 for basic consults extending upwards depending directly patient contact times exceeding forty minutes additional fee charged if performed out-of-clinical space covering travel costs further increased by fifty percent

    Worksafe Victoria:

    Standard Consultation rates stand as low as **€**58.33 while Restricted Consultations involving history examination & treatment specific injuries under prior approval are billed higher at **€*116.67; providers can claim reimbursement for traveling expenses within Melbourne regionally and rural settings according to respective distances covered;

    Workcover Queensland: Level A consultations incur charges starting off at just over **€***58.00, increasing progressively with each level B C D consultation fees escalating significantly reaching maximum levels set around **€*****147. An hourly rate published is also €183.00 time spent travelling may be claimed separately but only at a lower rate than stated above,

    WorkCover Western Australia: Standard Consultation prices start slightly below those found elsewhere, amounting up-to-€*****70.55, whereas treatments across two distinct areas cost more specifically outlined here at approximately **€****89. Additionally an hourly wage of $ 200.€€ .25 has been established which applies equally regardless whether services rendered indoors or outdoors travel costs included in this fee structure

    Return To Work South Australia:

    The standard consultation rates offered by RTWSA fall between **$68.00 - $92.90 per hour depending upon the nature & duration thereof; long consults are charged higher still at roughly **$€*185.“" The document was released under Freedom Information Act 1982 by National Disability Insurance Agency.

    Disclosure Log

    Capacity Building Supports

    • restricted consultation. An hourly rate of $$185{dot}40 is also published.Time spent travelling can also be claimed at lower rates of ($$€€76{dot}€€0 per hour).

      • Comcare (Tasmania) – The guidance for upper limits fees includes:

        • Standard Consultation & Treatment:$€ €68{🛩}{dot}35;
        • Two distinct areas treatment:$€ €102{🛩}{dot}55; and,
        • Complex treatments requiring more than {dot} minutes direct contact:$€ €170{🛩}{dot}90.
      • Comcare (ACT): Upper limit fee guidelines include these amounts: For standard consultations, it’s $€ €80{🇸}{dot}46. For two separate locations or conditions in a consultation, the amount rises to $€ €120{🇸}{dot}24. And finally, complex cases that require over an unspecified duration of time cost$€ €159{🇸}{dot}27 per hour for each service provided by ComCare ACT staff members who are not directly involved with their clients’ care plans but rather provide support services such as transportation assistance during visits at home or other settings where they may be needed on site within hours after arriving from work elsewhere outside normal business hours.

      • Comcare Northern Territory: The upper limits fees set out here apply specifically only when providing Level One Complex Services and Standard Level Two Complex Services respectively, as follows:$hourly rate is $\€€{dot}€ {dot}€ 181 {🛩}{dot}98; while standard level one complex services costs $\$$€ €227{🛩}{dot}49 per hour.

    • Department Of Veterans Affairs: The fee payable to this department under its scheme includes a single consultation charge which amounts exactly ($$65{dot}30).

    • Medicare Benefits Schedule: This schedule sets the following amount of money aside in advance towards paying providers for consultations made through it, namely $€ €63{🇸}{dot}25 per visit.

    The Review therefore considers that an overall review should take place as part of each year’s annual pricing process (which occurs every two years) regarding therapy prices. It also suggests further consideration be given on whether different support items need separate price caps so they can better encourage service delivery outside regular business hours especially when dealing with early childhood intervention cases where best practices are concerned and how these arrangements impact them specifically compared against other schemes’ billing structures. However, it was noted by reviewers during their investigation into this matter found mixed results indicating there isn’t enough evidence available at present time alone without looking more broadly across all existing payment systems within Australia today; hence no definite conclusion could yet been drawn from such limited data collected thus far about what might work well or not depending upon context factors involved therein individually. The current system does allow some variation between standard rates charged based solely off complexity level rather than exact duration spent interacting directly face-to-face but doesn’t necessarily apply consistently throughout entire consultation period regardless if client needs were met fully or partially satisfied beforehand already before leaving premises again later after completing task assigned earlier elsewhere else in community setting environment etc., which may lead to confusion among stakeholders trying figure out exactly why certain charges vary significantly sometimes even though same type services provided under similar circumstances appear identical superficially speaking otherwise according to official documentation published online publicly accessible via internet search engines nowadays anyway…

    The Review notes that many other programs do not include distinct pricing tiers for extended periods beyond normal working day boundaries instead opting simply charge lump sums per session irrespective of actual length taken up altogether whereas others still maintain lower hourly pay rate when covering travel expenses incurred while commuting back home afterwards post-appointment completion amongst themselves internally managed staff members employed specifically just doing administrative tasks related mainly around managing paperwork forms filling out claims submissions processing payments disbursing funds disbursement distribution activities etc. as opposed direct service delivery roles performed by front line workers providing hands-on care assistance support needed daily basis within homes schools workplaces communities settings where people with disabilities reside live learn grow develop their skills abilities independence levels improve overall quality life experience opportunities available through various types interventions strategies implemented collectively across multiple disciplines fields involved together.

    Given the differences between NDIS price caps and those set forth previously, it was decided not index therapy prices this coming financial year noting however they were increased temporarily due 10% COVID Loading effect applied last fiscal period without any evidence submitted showing shortages in supply availability occurring during said time frame whatsoever which might have caused delays or disruptions impacting negatively upon timely access provision thereof among affected clients receiving services under such circumstances respectively accordingly.

    Disclosure Log

    Capacity Building Supports

    which is included in the current methodology for applicable core supports. The Review considers that it would therefore be more appropriate for the price limits of these supports to be set by the Disability Support Worker Cost Model.

    Consumables

    In understanding the issue of consumables, the Review considers that it is important todistinguish between “tools of the trade” of the therapist and consumables used in the treatment of the specific participant.The Review understands that consumables that are provided to the participant are, in general , claimable against the participant’s NDIS plan .The Review considers that tools of the trade do not already account within their price limit for therapy support items .For example,the NDIS Nursing Cost Model includes an overheads provision of $20%$.

    Exercise Physiology

    The Review notes that the NDIS current price limit for Exercise Physiology higher than average rate payable most comparable schemes (see Table above) even accounting GST The Review also noted increase was made by July $75/8$ and July $6/19$.This increase recognized fact that exercise physiology generally not free from tax review does consider need further increase at time whether or not services supplied should be GST-free matter Government scope Annual Pricing Review.

    Recommendation

    RECOMMENDATION 9) Capacity Building Supports * i. The NDIA undertake comprehensive review on pricing arrangements as part annual pricing every two years next such review commence July pending outcomes review: - a.) Indexation limits supports July $34/20$ - b.) Indexation limits supports July $34/21$, accordance indexation methodology set out in recommendation $(iii)$

    • ii: The NDIA should index prices capacity building supports delivered Disability Support Workers reference to NDIS Disability Worker Cost Model.

    PLAN MANAGEMENT SUPPORTS

    The Review was required by its Terms of Reference to examine the price control framework Agency.for plan management supports. CURRENT ARRANGEMENTSNDIS participants can choose to have a registered Plan Management provider to manage Insurancetheir funding and budget for the supports in their plan. Plan Managers are bound to the NDIS Price Guide and are able to connect participants with both NDIS registered providersand providers that are not registered with the NDIS.The NDIS Price Guide currently says that: Plan Management – Financial AdministrationNDSI.Price.Guide.Plan.Management.Financial.Administration.funding applies toregistered.providers whoundertake.financial.administrations.of.a.plan.on.behalf.of.aparticipant.NDIPriceGuide.PlanManagementFinancialAdministrationfunding includesa setup fee.to establishthe payment arrangements.with.providers.and.amonthly processingfee.This support assistsby:giving.increased.control.over.plan.implementation.utilisationwithplanfinancialassistance;managing.monitoring.budgets.over.the.courseof.theplan;managingNDIS.claims.paying.providers.foredelivered.service;maintaining.records.producing.regular.at.least.monthlysstatements.showingthefinanci.position.of.theplan.;providing.access.towider.range_of_service_providers_including.non-registeredproviders.whilst.remaining.in.line.with.the.price.limits.contained.withinthis_guide.A Plan Management - Financial Administrationprovider will possess bookkeeping / accounting skills and qualifications.Theywill have systems inplacefor efficientlyprocessing payments on behalf of a participant. Capacity Building and Training in Plan and Financial Management by a Plan ManagerThis reasonable and necessary support focusseson strengthening th eparticipant’s abilityto undertake tasks associated with the management of their supports. This includess: buidling financial skillsorganizational.skillsenhancing the participants abilitytodirect theirsupportsdvelop self-management capabilities Annual Pricing Review 2020-21: Final Report84Page314 of 1049

    Disclosure Log

    Plan Management Supports

    Plan and Financial Capacity Building providers are expected to assist the participant to develop their skills for self-management in future plans where this is possible. As part of this capacity-building support, promoters will help participants build overall management capabilities within these plans—engaging service providers developing agreements paying them and claiming payments from NDIA while maintaining records.

    Currently available services include:

    • A single (per-plan) establishment charge covering setup costs related to managing funding supports, with current limits at $227.53;
    • Monthly fees needed continuously maintain those same funds’ arrangement structure, currently capped around $102.28 per month; and
    • Training sessions focused on improving administrative abilities, costing approximately $60 an hour as a standard rate. The annual cost caps increase each July based upon inflation rates calculated using both wage price index data provided through ABS Consumer Price Indexes weighted equally between wages and consumer prices over past twelve months. Pricing restrictions apply specifically regarding training expenses: travel or non-face-to-face activities cannot be claimed under any circumstances but short-term cancellations can still qualify if necessary. In 2019-20 fiscal year alone claims amounted up nearly $86 million, representing roughly seven percent participation among all NDIS registered organizations providing such assistance directly. Additionally about thirty-three percent (~{round(101_119/total_participants * 100)}%) of total participants had their finances managed by these plan administrators, totaling close to five billion dollars in overall support management.

    Disclosure Log

    Plan Management Supports

    • Whether the current indexation arrangements for the price limits for plan management supports appropriately maintain their value?
    • Whether plan managers should be able to claim for provider travel and non-face-to-face activities with respect to support item 14_031_0127_8_3, with the agreement of the participant? In consultations and in the Working Group on Plan Management, providers stated that the role of plan managers had changed from simple bookkeeping to much more like support coordination. They said that a major reason for the rapid growth in plan management was that many participants do not have support coordination and Plan Managers are filling thisrole –formuchlessmoney.Additionally,theystatedthatmanyLocalAreaCoordinatorsarenot providingthelevelofsupportrequiredeither,addingtodemandsonplanmanagers. Some members of the Working Group on Plan Management felt that the ultimate goal of planmanagementshouldbegetasmanyparticipantsself-managingaspossibleagreeingwiththetune Review.Othershowevercommentedthatmanyparticipantsdidnotinwanttobecome self-managing–orcouldnothoweverwereusingplann managersonflexibility.All agreedthaftfewoft heirclientshadtransitionedtoself-management.

    Establishment Fee The majority of submissions commented that the plan management EstablishmentFee arrangements appeared inadequatein someformthoughsuggestedremediesvaried.These included:

    • A secondEstablishmentFeeshouldb eclaimableifparticipan tschange pl anm an agersandthis shouldbelimitedto twochangespery ear;

    • Establish ment fee costs could be inclusiveinthemo nthlyfee;anda nd

    *A suggested price limit increase t o$350.Somerespondentssuggestedithe current Establishment Fees were adequate for basic establishment such as th ei nitial meetingenter ingrelated participant information into databases. Many respondents suggest edit h atcurrentfeedo ntakeintoaccount othertasks requiredincludingpayroll servicesourcinginformationfrom planners and support coordinatorsassisting participants understand their NDIS plansplanmanagem entandsettingupservice agreements, service bookingsIT systems.A fewrespondentssuggeste dthe current EstablishmentFeesdoesnot accountfor complexplanslongerdurationplansornewparticipants,suggestingatierdstructure basedoncomplexitybudgetsize.Memb ersoftheworki ngGroup onPlanManagementarguedthatEstabli shmen tf eesshoulde higherf orparticipantsw ho do not havea su pportcoordinatororwhere travel isrequired fora firstface to facemeeting. Annual Pricing Review 2020-21: Final Report Page 3 of 4

    Disclosure Log

    Plan Management Supports

    Monthly Fee

    Respondents generally suggested that the current monthly fee was not sufficient, claiming they provided services beyond what can currently recover within existing price limits. Main concerns raised in submissions include labor costs being up to 70% of their overall expenses due primarily from time spent assisting participants:

    • Updating service bookings;
    • Providing advice guidance consultation,
    • Offering summaries about participant budgets;
    • Presenting invoices into NDIS systems ;
    • Remitting payments directly to providers ,
    • Reconciling payment records regularly each month . Several respondents mentioned ongoing IT system maintenance as well as software updates were part cost factors too. The Working Group argued this insufficiently compensates Plan Managers who often act like lawyers interpreting NDIA legislation (section 34) and correcting invoice errors while teaching others how read NDIS Price Guide correctly create accurate ones. Some submitted times vary based on number processed per individual participant ranging anywhere between small amounts all the way upwards reaching over fifty items every single month one respondent estimated updating booking alone costing $ 21 USD annually for each person involved another said ten hours work needed by those with greater needs. Most agreed a transaction-based pricing structure would better fit than fixed fees. Several proposed tiered-fee structures depending complexity support requirements determined Agency capture majority complex plans. some preferred total plan value approach adding loading rates above certain thresholds reflecting potential complexities transactions e.g., suggesting twenty percent increase beyond initial cap amount reflect these costs accurately. a combined solution was also suggested combining monthly flat fee plus additional charges linked values of their plans, numbers transacted or service provider count.

    Disclosure Log

    Plan Management Supports

    Conversely, there was also opposition to the transaction-based approach with several submissions asking to keep the current fee structure in place. These submissions noted that can add further administration time complexity; monitoring transactions need costs; and it may adversely affect participants. members of the Working Group on Plan Management also discussed whether flat rate best fees, or proportional participant budget or complex plans take longer manage Conversely argued simple if mostly assistive technology. hourly Fee The respondents requested higher price limit for capacity building trainings in plan admin support item Comments included current rate is slightly Disability Support Worker hourly price limit however qualifications considerably higher than worker It one respondent average wage bookkeeper $ per hour Their service charge approximately $70 per some services over $hour Indexation Many commented indexation too low despite same inflationary percentage adjustment other supports Some responses compared dollar value changes core supports One submission suggested Fair Work Commission’s minimum decision be applied management supports Providers attended agreed plan management should indexed CPI Non-face-to-face services majority received suggestions providers claim provider travel Several respondents comment arrangements as coordinators noting cost deliver support Also proposed this change would encourage more face-to-face services participants mentioned might expect training occur own computer not replicated office and managers have option alongside a participant Submission commented providers able claim tasks do require interactions Annual Pricing Review 2020-21: Final Report Page 318 of 1049

    Disclosure Log

    Plan Management Supports

    Many submissions from plan management providers suggested that they should be able to claim for non-face-to-face supports when providing capacity building and training in plan administration and management supports, including:

    • creation personalized resources templates tools;
    • developing budgets or forecasts;*
    • clarifications explanation on budgets spends phone ; and creating specific participants needs.

    Other issues

    Other issues raised respondents included payment portal functionality difficulties updating service bookings required more clarification role manager guidelines support encompass .

    Discussion

    There is little evidence current price limits are inadequate The NDIS registered providers offer services increased less than just between years However number offering significant growth period figure shows .

    Disclosure Log

    Plan Management Supports

    The NDIS revenue earned by plan managers from the monthly account fee has also grown significantly, in line with the growth of the Scheme (see Figure 6).

    Figure 6 - NDIS Revenue Claimed by Plan Managers from Monthly Fees, by Quarter, 2019–2019

    [Image not converted to Markdown – “Figure” – check the source PDF page for the actual content] The scale of plan management organisations is also growing with the average number of participants per plan management organisation increasing from 41 in September 2016, to redacted months. Few plan management providers have exited the market and early research indicates that those who have exited may not have had the growth required to operate at sustainable margins. Most providers that have exited made a total of less than $24$ claims over their lifetime up to $3. years. Another perspective on the adequacy of current price limits can be gained through an analysis using Google Ads data which showed costs for clicks were $ ext{S}$., with . searches. There are more search engine pages offering services related to plan management compared to other businesses online advertising indicating high levels competition. The cost per click was indicated as being willing to pay customers based upon conversion rates. There’s some innovation emerging within this industry including allowing instantaneous payment during service provision or integrated mobile applications enabling easy access information regarding supports.

    Disclosure Log

    Plan Management Supports

    Early findings indicate that most Plan Managers are likely to charge the price limit for services, despite increased competition. There is no evidence of a gap in supply for plan management services; strong competition exists due to new competitors entering the market along with significant growth both financially and customer-wise within this sector over time showing early signs innovation as well, The current flat fee structure has been implemented on national scale from less successful arrangements including quoting iteration over time which encourages efficiency appropriate financial administration tasks.

    Classifying Regional, Remote and Very Remote

    The Review was required by its Terms of Reference to examine the geographic classification component of the NDIS price control framework to examine whether modifications are required to the NDIA’s implementation of the Modified Monash Model (MMM) to account for specific disability service-related costs, including the treatment of “isolated locations” and islands under the MMM.

    CURRENT ARRANGEMENTS The NDIA uses the 2015 version of the Modified Monash Model (MMM2015)

    to determine regional, remote and very remote areas.The MMM geographical classification of a locality is principally based with distance from that localit yto nearest population centre size of that popula tioncentre(see Table). Table Definitions oftheModifiedMonashModelGeographicAreas Description Zones MMM Inclusion Metropolitan MM M1 Allareas categorised as Major Cities AustraliaRegional Centres MM M2-3 Areas categorized Inner Regiona lAustralia or Outer Regio nalAustrali at within km road distanc eof town populat ion>50 ,000.RegionalCentres MM M2 -3 AreascategorizedInnerRegiona laustraliaorOuterRegiona lAu straliathatareinwithinkmroaddistanceoftownwithpopulationbetween and. Regional Areas MM M4-5 Area scategorisedInne rRe gion al Australi aorOute Re gio na l Austral ia are inWithink mro addist an ce oftow nwi thpopulati on between and Remote MM M6 Arealscateg oredRemote Aust ra li a that noton populated island separated mainland more than k off shore.Very Remot e MM 7 All other area sbeingVeryRem ot ea us tral i aan darea son The rating can be determined using the Health Workforce Locator tool on Department’s website. On average price limits higher remote areasand%higher veryremote areas.There is no additional loading applied for supports metropolitan regions.In general,pricelimits based where support delivered which participant lives.For example if living remotes location visits therapist

    Disclosure Log

    Classifying Regional, Remote and Very Remote

    their capital city, the therapist should not attempt to claim a price that is higher than the price limit for the support in that city. On the other hand, if the herapist was to visit the participant in their local area to deliver the support then the therapist could claim apricethatiswithin theremote’pricelimit.The NDIS Reviewofthewa Market found thatecostservice delivery isolated centres -centres are currently classified as remote or veryremotebythemMMbutare completely surrounded remoteveryremotearaswere generallyhigherthanother non-remote areas41 As consequence fromAugustNDIA has modified so thatareas (or groups) currentlclassifed remoteremotereveryremoteMMM butsurrounded remotelyreverymoreteareas (“Isolated towns”)classified remote planning pricing purposes A new version Modified Monash Model MMM2019 based on results most recent census now available FromJanuaryHealth will transition MM classification system number of locations have different classifications under systems This because some labour supply centre changed sizeandso areas closer nearestlaboursupplycentre given Further islands less five kilometres offshore connected mainland by bridge population 5000 classify at least M2019 The following Table provides details Urban Centres Localities change between and loading that NDIS applies planning control purpose affected Note however theselocations Cardwell Duaring Leeton would be eligible for classified remote under policy

    Regions where Price Limits change between MMM2015 and MMM2019

    | State | UrbanCentresLocalitys | MMM2015Loading | Loading | MMM2019Loadings Isolatetowns | |—| | NSW Bourke7650%40% 40% | NSW Cobar 7 \t 6\t 50% \t 40% \t 40% | NSW Dangar Island not provided in table but inferred from context | Vic Hopetoun3680%0% not provided as it is a new location with no data yet | Qld Arcadia Bay MagneticIslandnot provided as it has been reclassified to an urban area, so there’s no price limit difference. | Qld Cardwall6540%0% 40% | Qld Coohiemudlo Island560% 40% | Qld Duaringa 6 -5 Not applicable as the loading remains unchanged at both levels. The population of less than five thousand makes this island ineligible for classification under NDIS isolated town policy. | Qld Dunwich 5 6 No change; still classified as remote and veryremote by MM2019.

    Disclosure Log

    Classifying Regional, Remote and Very Remote

    | State | Urban Centres and Localities | MMM2015 | MMM2019 | MMM2015 Loading | MMM2019 Loading | MMM2019 Loading(Isolated Towns)| |-|-|-|-|-|-| | Qld | Glenden | 5 |6 | redacted% |40% |40% |Qld | Hideaway Bay - Dingo Beach |7 |-||- | |Qld | Horseshoe Bay,Magnetic Island | - ||%-|- |Qld | Injune |3 |6 | %| %||Qld | Karragarra Island |5 |6 | %-|-%| |Qld | Lamb Island |5 |6 | %%|%%||Qld | Nebo |8 |5 | ```|```|’ |Qld | Nelly Bay ,Magnetic island |7 |5 | ‘%|%’| ’ |Qld | Picnic bay Magnetic Isand |7 |5 | ‘%’|‘’| ‘’ |SA | Pennenshaw |6 |7 | ‘40’|‘50’%| '50% |WA | Broome |7 |6 | '-|-'| '-' | WA | Carnarvon |6 |7 | '--|--| --' |W A | Green Head |6 |5 |'-|-|--| | W a | Kununurra | 6 | 7| '| '|'('| | wA | Leeman |12 |5 | -%|---| ---' | NT | Gunbalanya (Oenpelli) |-||-|- ||%- |

    Consultations

    The issues paper presented a number of issues with the current arrangements:

    • What transitional arrangements, if any should be put in place for locations that are currently classified as remote under MMM2015 and would no longer be classified as remote under Mmm2019?
    • Are there any other issues with geographic classification system used by the NDIs for pricing planning purposes? Respondents acknowledged need timely changes to geogaphic classifications but noted frequent can disrupt service delivery providers. Number submissions suggested transition period available provider adjust operations most common suggestion was month notice allow time most providers transition particularly where geographical reclassification lowers mmm ratings also impacts engaging new participants such location. Respondent were also concerned that does not consider proximity disability providers operation costs areas workforce attraction retention They proposed NDAI consider proximty town located well populated towns community services health providers Annual Pricing Review Final Report Page324of1049

    DISCLOSURE LOG

    RESEARCH

    There are 5673 participants affected by MMN changes for year 2019. Out these there will be reclassification into or out from MMM levels between 6 & 7. This change impacts their geographical loading on their price limit and plan fund amount.

    • Participants who move from outer regional (MMM) level to a more remote area like remote, gain an additional cost factor of up-to -40%
    • Conversely those moving back towards less remote areas lose this benefit (up to -`40%
    • Those classified as very remote now have higher costs associated with them due to increased distance, hence they pay up to -50% extra in terms of loadings.

    Discussion

    The MMM is based explicitly upon proximity to nearest labour supply centre which makes it suitable mechanism estimating availability disability support workforce and need for higher prices limits compensating providers for attracting workers. The Review recognises thin markets operate within remote very regions especially when providing specialized services but considers that solution lies through greater use commissioning rather than increases pricing limits where market’s low number of participants results in insufficient purchasing power individual participant can attract service provision efficiencies generated via aggregation. The review also argues against delay implementing any change regionally given both price limits funding are driven by same factors thus while smaller plans might result larger geographic classifications face lower price limits accordingly.

    Recommendation 11) Geographic Classification

    Recommendation: NDIA should adopt the MMN classification system future updates released Department Health subject NDIS Isolated Town arrangements basis determining pricing arrangement NDIS Price Guide including: i) Whether remote & very remote loading applied on price limit plan fund amount; ii) Which travel time apply supports delivered participants.

    Disclosure Log

    Costs in Outer Regional Areas

    The review examined whether loadings should be applied for price limits and plan funding amounts in outer regional areas.

    Current Arrangements

    In 2019, NDIS Western Australian Market Review found higher costs in remote/very remote regions compared to others; increased loading rates accordingly—from 20%/25% to 40%/50%. It noted rising costs aligned more closely than linearly based distance but did so gradually across boundaries into remoter zones rather abruptly at transitions within these broader categories (outer vs inner).

    Consultations

    Respondents suggested additional travel/labor accommodation expenses drive up support-delivery costs regionally due primarily to limited transport options, worker accommodations where applicable, wage increases. Some argued issues faced align better with those experienced remotely while another submission highlighted MMM4–5 providers face greater startup and ongoing business establishment challenges specifically in rural locations—especially small ones. The CGC conducted research on actual government employee placement cost variations per remoteness level finding that costs increase progressively beyond just three discrete groups as distances grow further from urban centers. They also reported very-remote placements could incur nearly double the expense of similar positions closer-in.

    Disclosure Log

    Costs in Outer Regional Areas

    cities. Figure 7 from the WA Market Review compares the CGC’s estimates of the costs of delivering services in regional, remote and very remote areas with metropolitan areas. It also shows the price loadings that applied at the time of the WA Market Review in the WA NDIS and in the Commonwealth’s residential and community aged care programs.

    in all cases, The cost loadings were significantly greater than the price limit and plan funding loadings that were applicable in the NDIS at the time of the WA Market Review.Becauseofthis evidence,theWAMarketReview foundthatthecostsdeliveringservicesinremoteandvery remotearas weresignificantly higherthaninmetropolitanareas,andthedifferenceincostsweregreater thanswerethenprovidedforinthENDISplanningandapricingarrangements.TheWAMarketReviwalsofoundthaThecostsofdeliverservicesinregionalareasmightalso behigherthaninemetropolitanarea,butthat further research on themagnitudeandsignificance thisdifference wasrequired.Thismatterwasreferred totheAnnualPriceRevie20-1 for furthereconsideration.

    ThedepartmentEducationEmploymentWorkplaceRelations conducted study into their regiona loadingsin 201143 Thatstudy considered model factoring components service delivery regions such as staff numbers, class size total enrolments geographic features locale. Their recommended hierarchy forloadingfollows:RemoteVery Remote=;Darwin specific = Outer Regional = InnerRegional=

    final report.pdf

    Disclosure Log

    Costs In Outer Regional Areas

    A detailed study published in 2014 by the Queensland Government Statistician reported Table (\ref{tab:table_1}), found that generally cost living regional areas lower metropolitan.

    Table \textbf{(Tab)} - Relative Cost Living across Queensland | City/Town | Relative Cost Of Index | Living | City/Town | Relative CostOfLivingIndex | |- |- |- |-| | Brisbane &nbsp;&nbps;$^{}$&nbsp;※&nbsp;&nbps;100.&nbsp;&nbps; | Gympie &nbsp;&nbps; $^$ $^ullet$ $n$b$p$s $ imes$$ackslash$t$a ho$l$d$r$c%e% $h$f$m%n$i$k$q$x$v%d%m%f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$ $^ullet$ $n$b%p>s +%f+i+t+s+ $^ullet$ $n$b$p$s 94.5 | Kingaroy &nbsp;&nbps;$^* $^ullet$ $n$b$p$s $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s f+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Ayr &nbps;$^{}$&nbsp;※&nbsp;&nbps;94.8 | Longreach &nbsp;&nbps;$^ $^ullet$ $n$b%p>s $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s f+i+t+s+ $^ullet$ $n$b$p$s 105.&nbsp;&nbps; | Mackay &nbsp;&nbps;$^$ $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Beaudesert &nbsp;※&nbsp; $^ullet$ $n$b$p$s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s f+i+t&s+ $^ullet$ $n$b$p$s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Bowen &nbps;$^$ $^ullet$ $n$b$p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Bundaberg &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Cairns &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Cannonvale &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Charleville &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Charters Towers &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Dalby &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Emerald &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gatton &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gladstone &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&nbsp;※&nbsp; $^ullet$ $n$b$p&s 94.8 | Maryborough & nbps;$^* $^ullet$ $n$b&p;s $^ullet$ $n$b$p$s $ imes$$\backslash$t$a ho$l$d$r$c%e% $h%f$m%n$i$k$q$x$v%d%m$f%i%s%c+o+m+n+b+a+h+y+$ $^ullet$ $n$b$p$s %d+r+c+i+t+s+ $^ullet$ $n$b$p$s +l+d+l+v+x+k+w+z+%c+f+j+p+m+n+b+a+h+y+$| | Gold Coast &nbps;$^$ $^ullet$ $n$b<p<s | $^ullet$ $n$b$p$s l+d+l+v+x+k+w+z +%c+f+j+p+m+n+b+a+h+y+$&nbsp;※&nbsp; $^ullet$ $n$b%p>s $^{}$&am

    Disclosure Log

    Cancellation Rules

    The Review was required by its Terms of Reference to examine the current price control arrangements for cancellations within the Scheme.

    CURRENT ARRANGEMENTSNDIS providers are not permitted to collect deposits or bonds from participants, or to retain these funds in the event of the participant cancelling a service booking for a support or failing to turn up for a support. However, they are permitted to charge cancellation fees against a participant’s plans in certain circumstances.The NDIS Price Guide currently says:

    • Where a provider has a short notice cancellation (or no show) they are able to recover 90% of the fee associated with the activity, subject to the terms of the service agreement with the participant. Providers are only permitted to charge for a short notice cancellation (or no show) if they have not found alternative billable work for the relevant worker and are required to pay the worker for the time that would have been spent providing the support.A cancellation is a short notice cancellation if the participant: * does not show up for a scheduled support within a reasonable time, or is not present at the agreed place and within a reasonable time when the provider is travelling to deliver the support; or * has given less than two clear business days’ notice for a support that meets both conditions: + The duration exceeds eight hours continuous duration AND + Agreed total price equals $1245 or more OR * Has given fewer than five clear business days’ notice. In 2018-19, cancellation payments totaled $12 million which was 0. percent Scheme expenditure Only providers made cancellations claims For these providers represented on average four point nine per cent all their claims by number three dot six per cent value one in ten who claimed for cancellations representation eleven point one per cent all their claims by number eighty-three per cent all their claims by value

    NoteTo help providers continue delivering supports participants through COVISD pandemic NDIA amended definition of short notice from March Business day’s notice avoid paying full fee cancelled service This change definition short notice cancellations period (March September) initial review months determine appropriate When reviewing will consider range factors including current status COVID-19. Providers are also paid hundred percent agreement fees.

    DISCLOSURE LOG

    Cancellation Rules

    CONSULTATIONS

    The Issues Paper presented a number of issues with the current arrangements that had been raised by the sector, including:

    • Some providers have argued that the current arrangements - whereby they are required to claim for 100% of the agreed fee for a cancelled service but the NDIS only pays them 90** %of the agreed fee*- results in accounting anomalies in their accounts showing the NDIS as bad debtor.
    • Plan managers have also reported that they face difficulties in balancing their accounts when the invoices presented by providers, which they pass onto the NDIS, do not match the payments made by the NDIS.
    • Some providers have also argued that they should be able to recover the full cost ofthe service that was cancelled where theyhavenotbeenableto replace there participantastheyfaceallthecosts associatedwiththeadaptment.*
    • Some stakeholders have questioned whether then DIDS cancellation rulesshouldno better alignedtoseethatapplyinthen general economy* itwas notedbymanyrespondentsthatitwadifficulttomakealternativearrangementswhenashort-notice cancellations occurs particularly whenthisoccurslastminute (i.e. no show). Common concernsraisedincluded:
      • Difficulty replacing participants due tonatureofsupport;
      • If noreplacementfoundstaffwereallocatedothertypesoftasksinternally(i.e.administration); and
      • Depending on th ecustomer baseand rostering it may bedifficul treplacecancelledappointments.A few submissions provided approximate numbers o how often alternative arrangements could bemade following a c ancellationwhich included somenoting 25%30of them time others noting up tot7o95 % oft he tim One respondent mentioned it canoftenbedone but dependson individualcircumstances Almost allsubmissions indicatedtha y spenta lengthytimeattemptingtoreplace ashort noticecancellation Afew submission s noted tha ta ssociated administrationtimemightrangebetween minutes to two hours, evenuptoadaytorescheduleaworker Most providers argued thatitis inappropriate toreducethe fee claimable foras h ort notice cancel l ation because the cost structures weresame whether ornottheservice wasdelivered This view wasnot unanimous however Other respondents commentedthatthe current arrangementwasafairbalance betweenth eparticipantan d provider On esuggestedtheremoval ofthecancellationfeeA particular problem with thencurrentarrangements noted by severalproviders wasthat providerswererequiredtoclaimfor100%offe bu wereonlypaidforn90**%oft his. Thus

    DISCLOSURE LOG

    Cancellation Rules

    meant that their financial systems were showing a debt by the NDIS of 10% of the fee and\nadditional administrative work was required to balance their books to satisfy their auditors. Some providers indicated that two days’ notice was typically adequate. Others argued that this is insufficient notice when the respondent also coordinates with schools, day programs,

    and other service providers. Another issue was that rostering may be complex and that twodays’ notice may not provide adequate time for adjustment. Some respondents suggestedshortening the timeframe to 24 hours while others suggested expansion with proposals ranging from three days to five days.The majority of responses indicated that the same cancellation rules should apply to allsupports. One submission noted cancellations should also apply to interpreter service underthe NDIS as organisations are still required to pay an interpreter for short notice cancellations yet cannot charge a cancellation fee under the NDIS Other respondenst askedfor clarity around cancellations for Supported Independent Living (SIL) group supports asthis impacts other participants more difficult arrange available resource.

    DiscussionThere little consensus among submissions whether current cancellation periodswereadequate It therefore proposed change these atthis timethe arguments changing payment rateto 100 % agreed feemuch stronger The Review considered whether it might able resolve provider’s accountingdifficulties by improved claiming arrangements in NDIS systems but on balancethat providers’arguments incurred costs beinginvariable if theycould find alternative work wereconsidered strong especially because providers canincurred additional cost after no shows prolonged cancels through duty carewhich requires assure themselves cancelling participant incapacitated

    RecommendationRECOMMENDATION Cancellation FeesThe NDIA permanently amend claim rule INDS Price Guide allowproviders claimed agree fee short-notice cancelationAnnual Pricing Review Final ReportPage33of1049

    Disclosure Log

    Provider Travel Rules

    The Review was required by its Terms of Reference to examine the current claiming rules for provider travel within the Scheme, including:

    • Provider travel time limits, including examining whether it is possible to develop an approach that is more sensitive to local conditions; and
    • Non-labour costs associated with provider travel.

    Current Arrangements

    The NDIA recognises that supports are often best delivered in the community or the participant’s own home. The price control arrangements therefore allow providers to charge for the time spent travelling to participants to deliver supports in some case. The NDIS Price Guide currently says:

    Providers can only claim travel costs from a participant in respect of the delivery of a support item if: - the Support Catalogue indicates that providers can claim for Provider Travel in respect of that support item; - t he provider has the agreement of the participant in advance (i.e., the service agreement between the participant and provider should specify the travel costs that can be claimed); and - the provider is required to pay the worker delivering the support for the time they spent travelling as a result of the agreement under which the worker is employed; or the provider is a sole trader and is travelling from their usual place of work to or from their participant, or between participants. Where a provider claims for travel time in respect of a support then the maximum amount for each eligible worker) is 30 minutes in MMM1-3 areas and 60 minutes in MMM4-5 areas.(Note the relevant MMM classification is the classification of the area where the supportis delivered.)In addition to the above travel capacity building providers who are permitted to claim foreprovider travel can also claim for the time spent travelling from the last participan tto theirusual place of work. The maximum amount of travel time that they can claim forthetime spent on return travel(for each eligible worker) is 30 minutes in MM M1–3areasand 60minutesinMMM4−5area s(Note therelevantMMMclassificationisth eclassific ationoftheara wwherethesupportissdelivered).

    DISCLOSURE LOG

    Provider Travel Rules

    Where a worker is travelling to provide services to more than one participant in a ‘region’, then the provider can apportion that travel time (including the return journey if applicable) between participants, provided each has agreed beforehand. Claims related to support must be submitted separately from primary service claims using identical line items as those used on Myplace portal under “Provider Travel” option when claiming transport expenses linked directly to these supports; providers should use hourly rates previously negotiated for main service or lower ones approved specifically per trip.

    CONSULTATIONS The issues paper highlighted several concerns regarding current arrangements raised sector-wide:

    • Current limits may restrict access because providers might avoid delivering services unless they recover their costs;
    • Providers cannot claim non-labour transportation costs like vehicle maintenance and tolls which include general running & maintaining costs plus personal car allowances or fleet upkeep fees. Providers were asked about proportionate episodes exceeding NDIS Price Guide’s specified times within NDSS Support Catalogue. Some respondents managed it through selecting accessible areas while others stopped serving homebound residents due high travel cost outweighing business incentives. Some estimated 5-10% of trips exceed guidelines with some reaching up-to half. Many noted regional dispersed locations often exceeded limits where an hour-long MMM zone could only justify thirty minutes’ worth. Others absorbed such excesses without charging clients preferring no alternatives available elsewhere.

    DISCLOSURE LOG

    Provider Travel Rules

    tolls and lack of adequate parking availability, compared to kilometres travelled in regional and remote areas.

    Respondents identified outer regional areas are particularly difficult to service due to travel Agency. costs. One submission requested that the travel limit for therapy services should be removed for regional areas. Some respondents indicated that it was not viable for them to provide service to participants living more than 45 minutes away. Further, travel to some locationsfurther away from the organisation base required overnight accommodation or alternative Insurance travel such as flights or ferries, which add to the travel costs.

    Provider submissions also raised concerns relating to isolated communities that are classifiedas MMM6-7. Respondents were concerned that the NDIS planning arrangements for remotenationality, despite being a common abbreviation used on official documents like this one, is typically understood within its specific context rather than universally recognized outside Australia’s government agencies.) every very remote participants do not adequately provide for the high cost of travelling insocial security system. those regions, which could leave the participant with minimal funding for support hours, oraustalian disability insurance scheme (NDIS). make it financially unviable to deliver services. There were also issues of efficiency witheconomic and social welfare programs designed specifically for individuals who have disabilities inthe current arrangements, with each participant individually organising expensive travelfrom their respective states across australia. payers which might be a better shared cost. Some support coordinators tried to performtheproviders’ roles by maximising the number of participants seen during visits but they wereno longer best placed to manage these tasks effectively. Providers argued that inorder make delivery supports viable thin markets need find group other participants area defraycosts This can work well semi regular arrangement example Tiwi Islands there 12 children mainisland Melville Island Therapists worked school establish service agreements all participants A therapist visits six times term average eight present Fees charged basis However considerable nonclaimable hours needed preparation trip remotes areas organise groundsupport appropriate time communicate people communities accommodation etc For individual remotetrip up hour planning. Respondents asked indicate proportion associated NDIS support labour costs currently recovered fromNdis One submission indicated able recover all related travel Another respondent suggested80%oftravel costs recovered ndis Principal issue raised respondents only claim worker’s timenow had absorb nolabour costs such as vehicle fleets mileage Providers pointed SCHADS Award requires them pay workers cents per kilometre when used own car provider tavel yet NDis Price Guide does not allow this claimed providers also indicated generally lessexpensive safer maintain fleet vehicles their overheads were not claimable ndis one noted fortheir costs percent nonlabour and labor Respondents indicated nonlabor costs with provider traveldepended type vehicle higher disabilitymodified ones

    Disclosure Log

    Provider Travel Rules

    submission noted that the cost of fuel in regional areas are typically higher than metropolitan areas. Other submissions noted that the costs of travelling to remote areas can be much higher given the poor state of the roads in those areas. The majority of submissions suggested a per-kilometre basis as the most appropriate and consistent method for claiming non-labour travel costs. It was suggested that this is the most transparent for participants receiving travel for their support, as well as being an administratively efficient method for providers.

    Annual Pricing Review: Final Report Page of

    DISCUSSION

    Travel Time Limits

    The Modified Monash Model geographical classification is based on distance from labour supply centres. In general, it should form a reasonable basis for the time limits on powerer travel which are meant to encourage participants access closer where possible.

    • MMM regions – The review understands traffic congestion can make metropolitan areas time consuming However it important continue encourages participants seek services from providers closer them improve Scheme sustainability notes market disability strong growth especially metro areas.
    • MM regions - The review notes: o Locations classified as MMs within km road dis town with population >50k; o Locations classified Ms within km road dist town between kand ; o Locations classified as MMs within km road dis town popu betwee nd . The review considers in each these cases means that participants sufficiently close Labour Supply Source non specialist services delivered within NDIS Price Guide.
    • MM region some people living regions classified may live considerable distances services but reviews best targeted approaches suggested below rather than through increase provider travel time limit.

    Review also understand more specialised services often require more travel other given located fewer locations again however, Review consider this issue best resolved through more targeted approaches suggested below rather than increasing Provider travel time limits noting capacity building Providers already permitted to separate claim return travel last client of day.## Coordinated CommissioningThe review considers fundamental difficulty supplying services outerregional remote and very remote sparsity requiring services This problem not best solved by price or provider travel time limits solutions nothing aggregate demand ensure efficient delivery service.

    Disclosure Log

    Provider Travel Rules

    A model for an alternative approach to managing the costs of travel and improving the efficiency of service provision in remote and very remote areas is provided by CheckUp, a Queensland Fund Holder for the Commonwealth’s Rural Health Outreach Fund. Fundholders are appointed through a competitive process and then require detailed needs assessment planning consultation communities local organisations based outcomes proposals once approved responsible delivery services according plans under these arrangements check up provides funding health professionals visiting eligible locations cover out pocket expenses relating following:

    • Travel Costs: airfares car hire mileage use personal car taxi hire;
    • Accommodation (per night);
    • Meals Allowance per meal Breakfast Lunch Dinner Incidentals;* Administration Support daily rate: administrative associated with outreach such as organisation appointments processing correspondence follow-up patients at location; Upskilling informal or formal educational activities that are provided at outreach service location; Cultural awareness safety training support undertake this if required; equipment lease Subject approval ; telehealth services: hire venue equipment .⁴⁹ These payments on top any fees may charged patient MBS reduce cost increase availability services Return Work South Australia also schedule reimbursement arguing allows more flexibility addressing unique challenges regions located further away deliver services A case manager may require service delivered greater than 10km from provider’s closest place business In circumstances approve reimbursement economy airfare overnight accommodation reasonable costs meals associated stay taxi fares parking hiring expenses excluding fuel vehicle miles.5₀

    Disclosure Log

    Provider Travel Rules

    Checkup also has a role in improving the coordination of services at the location where the service is provided. They aggregate the needs of individuals and match these to visiting group professionals to ensure the most efficient use of resources.

    The Review considers that there would be considerable advantages if NDIS adopted similar: coordinated commissioning approach for travel funding distribution among outer regional, telecommunication remote areas and very remote regions or other thinly populated zones.This method could reduce dependency on additional services’ commissions; it might even assist with their commission process as well simplify planning since planners wouldn’t need calculate specific travel costs per plan.

    Non-labour travel expenses

    Service providers incur significant non-personal transportation-related expenditures due either maintaining own fleets or being compelled under SCHADS Award rules requiring them reimburse employees when using personal vehicles delivering supports directly participants. In absence of established arrangements regarding transport within thin markets, such charges can fall into two categories - overheads included service provider’s general operating budget or treated separately akin Activity-Based Transport cost structures outlined NDIA Price Guide: If an operator incurs extra costs beyond worker time accompanying transporting community members (e.g., road toll fees parking rates vehicle operation), they may negotiate participant contributions towards those out-of-pocket items The NDIA deems reasonable payments include up $0 85 km unmodified accessibility car up-to-$240 km modified access/vehicle bus other forms like public transit fares fully covered. On balance the review suggests recognizing these costs individually rather than absorbing in overall operational expense because unevenly distributed across operators ensuring no incentive to cut down essential support for financial savings Providers however should only claim non-personal travel related costs if commissioning regulations allow this payment specifically required by agreement covering workers traveling time.

    DISCLOSURE LOG

    Provider Travel Rules

    under which the worker is employed; or the provider is a sole trader and is travelling from their usual place of work to or from the participant, or between participants.

    RECOMMENDATION

    c#### Recommendation 13) Provider Travel

    (a) The NDIS Price Guide and the NDIS Support Catalogue should be amended as at July 1st year so that providers can claim non-labour associated with provider transport in line activity based transport arrangement claims should only able made where rules governing provider allow make such a claim.
    b The NDIA further examine option commissioning broker arrangements coordinate participants pay for travel costs.

    Disclosure Log

    Establishment Fees

    The Review was required by its Terms of Reference to examine the current arrangements for Establishment Fees within the Scheme.

    Current Arrangements

    NDIS providers who are providing a significant amount (at least 20 hours per month) of daily activity and community participation supports to a participant are permitted to charge that participant’s plan an Establishment Fee when they commence providing services to the participant. This recognises the non-ongoing and not otherwise claimable costs that providers incur in establishing arrangements and assisting participants in implementing their plan, including assessing the participant’s needs, agreeing a service agreement with the participant and setting up service bookings in the NDIA system. The NDIS Price Guide currently says that the Establishment Fee arrangements apply: to all new NDIS participants in their first plan where they receive at least 20 hours of personal care/community access support per month. This payment is to cover ongoing costs for providers establishing arrangements and assisting participants in implementing their plan. an Establishment Fee is claimable by the provider who assists the participant with the implementation of their NDIS Plan, delivers minimum of 20 hours per month of personal care/community access support and has made an agreement with the participant to supply these services.A budget $750 included in initial plans provided to NDIS participants so as case this type assistance from providers design implement support arrangements.Providers can draw against this budget follows:If Participant New NDIS Provider then PROVIDER CAN CHARGE maximum of $500 against participant’s plan; If Participant New NDIS but existing client of PROVIDER then PROVIDER CAN CLAIM maximum of $250 against participant’s plan; if Participant choosing change PROVIDERS then NEW PROVIDER CAN charge max of $250 against participant’s plan assist PARTICIPANT IN changing PROVIDERS.The NDIS Support Catalogue provides following support item eligible providers establish fee

    Support Item Number Support Item Name Support Description
    01_049-0107_1_1 Establishment For Personal Care/Community Access (20 hours/month)
    
                                                   Establishment Fees
    
    In 2018-19, Establishment Fees were claimed by 984 different providers. Some 88 providers 
    claimed 50 or more Establishment Fees. These providers accounted for 54.3% of the total number
    total individual claims).
    
           participants had one Establishment Fee claimed from their plans in 2018-19.	This	accounted for 90.2%
    of those participants who had one or more Establishment                                     Insurance
         Fees deducted from their plan in 2018-19.
    
             participants had two Establishment Fees claimed from their plans in 2018-
    had three or more three or more Establishment Fees claimed from                                                                                                                                                                                                                                      National      their plans in 2018-19. This accounted for 1.7% of those participants who had one or
    more Establishment Fees deducted from their plan in 2018-19.)
    
    CONSULTATIONS
    The Issues Paper sought feedback on a number of issues with the current arrangements that
    had been raised by stakeholders,
    including:
    • Whether providers should be able to charge an Establishment Fee to a participant if they commence providing services under their second or subsequent NDIS plan?
    • Whether more than one provider could simultaneously provide support and charge an Establishment Fee at once, e.g., when multiple service types are provided daily activity and community participation supports? 
    • Whether third-party providers can also charge an Establishment Fee after switching between different providers within any given year as long as it is not due again until another change occurs later this year?
    • If so much money was spent establishing these fees, did each fee really represent value-for-money compared against what other options might exist elsewhere (e.g.: private sector)?
    • Should all kinds of organizations offering similar services have access to charging such fees too?
    
    <!-- source-release-page: 340 -->
    
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    # Disclosure Log
    ## Research
    The NDIA has identified that Establishment Fees for similar services are payable in some other schemes, including (as at July 1st , 2019):
    * icare New South Wales - An establishment fee ranging from \$1{\textquotesingle}564.{\textquotesingle}{	}\(06 for participants receiving support over six weeks but less then thirty-four hours weekly; increasing this amount up until an additional \$1{\textquotesingle}877.{\textquotesingle}{	}€€ if they receive more than forty-eight hours per week.")" alt="icarerecorded." title="recorded." /> The payment is intended to assist recruitment campaigns, provide additional training opportunities for staff members who work directly under these arrangements as well as time dedicated towards visiting and collaborating with clients involved within their care program.
    * Victorian Transport Accident Commission(TAC) – A one-off establishment fee between \$1{\textquotesingle}328.{\textquotesingle}{	}" alt="TAC recordedsupports." title="supports.""> This type of arrangement covers service providers offering four or more hours each month during a period exceeding three consecutive months. Such payments aim specifically toward covering costs associated such activities like hiring new personnel, creating comprehensive plans regarding client needs along other related tasks including ensuring compliance standards set forth by Occupational Health & Safety regulations.
    
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    # DISCLOSURE LOG
    ## Establishment Fees
    * Worksafe Victoria – An Establishment Fee of up to $1,207.32 payable after a provider has provided at least four hours of attendant care in three consecutive billing periods to assist with the costs of the recruitment of new personnel. The payment is intended to assist with the costs of the development of support and training plans; and compliance with OHS site requirements.
    Note however that NDIS Establishment Fees are not intended to cover many of the cost identified above (potential recruitment costs of new personnel, training staffs' developments). In general these arrangements view as part normal operating providers'. Participant specific training can be claimed through NDIs non face-to-face claiming arrangement.'
    ### Discussion Who should able claim for establishment fees?
    The current technical deficiencies say that 'NDIS Price Guide says that Establishment Fees may be claimed all new participants their first plan where they receive per month." However terms "personal care" community access defined guide Moreover because Establishment Fee item linked Registration Group Daily Personal Activities) only providers registered this group currently claim for Establishment Fees particularly providers registration groups High Intensity Daily Personal Activities), Participation Community Social Civic activities Centre Based Activities cannot unless also register group .The Review considers issue addressed more clearly specifying NDIS Price Guide providers meet relevant eligibility requirements would necessary create new Support Category Assistance Daily Life) and Support Category 4 Assistance With Social And Community participation Groups Although several submissions suggested other types supports should also able claim for Establishment Fees review does consider arguments change strong Most other types unlikely meet requirement at least hours a month duration plan. Also most capacity building already considerable allowance billable built into price limits ability claims non face-to-face support's
    52 [https://www.worksafe.vic.gov.au/attendant-care-services-policy](https://www.worksafe.vic.gov.au/attendant-care-services-fee-schedule)
    Annual Pricing Review Final Report Page of θ9
    
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    # Disclosure Log
    ## MR25/01967 FOI 24/25-2242
    ### Establishment Fees
    #### When should Establishment Fees be claimable?
    Currently, Establishment Fees are only claimable during a participant’s first plan and are only claimable by “the provider who assists the participant with the implementation of their NDIS Plan” and "delivers a minimum of 20 hours per month".
    There is some evidence that providers face additional establishment (or maintenance) costs in second and subsequent plans. First, whether or not a participant is on their first or later plan if new to a provider then they will still face usual establishment costs Second even though may stay same provider for next two three four five six seven eight nine ten eleven twelve thirteen fourteen fifteen sixteen seventeen eighteen nineteen twenty thirty forty fifty sixty seventy eighty ninety one hundred more than once but still need negotiate service offering agreement enter bookings into system currently providers need absorb these costs overheads On balance Review considers Establishments can be claimed from participants’ plan second third fourth fifth sixth seventh eighth ninth tenth eleventh twelfth thirteenthfourteenthsixteenthsixtyseventyeightyninetyonehundredthousandmorethanonceif choose change providers This also empower participants within NDIS market does not consider strong argument providers able claim second Established Fee respect participant Provider relationship continually evolve cost managing this part normal structure delivering services
    #### How much should the Establishment Fee be?
    Currently base rate $500 payable if both new NDIS provider lower fee available If only new NDIS existing client provider choosing changing providers These amounts have been unchanged since Scheme’s commencement There are number deficiencies current arrangements Class of participants who known already provider while important consideration rollout NDIS when many transitioned other schemes staying former providers now less relevant given almost fully rolled out Amount established clients labour based activity increased and continue increasing over time Cost establishing depends whether or not had previous relationship rather than whether is new to NDIS Finally current arrangement with focus on Scheme specify amount establishment fee allow participants agree that fee More appropriate price regulate items immaturity overall disability supports information asymmetries between providers participants
    
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    # DISCLOSURE LOG
    ## Establishment Fees
    The Review therefore considers that there is a strong argument that the Establishment Fee items should be more clearly indicated to be price regulated.
    
    ### Should the amount of the Establishment Fee be indexed annually?
    The current level of the Establishment Fee, while appropriate,
    is better expressed through linking it
    to the standard hourly rate of Disability Support Worker support items.
    as labour-based activity will increase over time.
    a simple way ensure establishment costs maintain their value would link them
    to other price limits within category increased each year along input cost increases:
    
    # RECOMMENDATION
    RECOMMENDATION 14) Establishment Fees
    **i)** An Establishment Fee assist non-ongoing costs establishing arrangements and assisting participants implement plan claimable from participant’s plan provider who:
    * **is one or Registration Groups:** (High Intensity Daily Personal Activities), (Daily Personal Activities)
    (Community Social Civic Activities Group Centre Based Activities);
    * **has agreement with participant supply at least hours: in Categories Assistance Daily Life/Support Category Participation – per month duration NDIS Plan;
    * **assists implementation Participant's NDIS Plan;**
    **ii)** Each can only claim an Establishment Fee respect across all plans once.
    **iii)** More than able providers claim against given provided meets criteria above. 
    **iv)** The amount Establishment Fee should negotiated by both parties but cannot exceed ten times weekly disability support worker determined Standard NDIS Cost Model parameters ($528.50).
    
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    # DISCLOSURE LOG
    ## Establishment Fees
    The NDIA should add several price-limited support items to the NDIS Support Catalogue to allow providers in Registration Groups:
    * **High Intensity Daily Personal Activities** - Group ID `0104`
    * **Daily Personal Activities** - Group ID `0107`
    * **Participation In community, social And civic activities** - Group ID `0125`.
    The group also includes:
    * **Group & Centre Based Activities**, Group ID `0136`, who are delivering services within categories for Assistance with daily life and/or Social Community Participation can claim establishment fees.
    
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    # Disclosure Log
    ## Matter For Decision: Update To The NDIS Cost Model For Disability Support Workers For Equal Remuneration Order
    Presented By David Cullen Chief Economist
    ### Purpose:
    #### 1.0 To seek PRG approval that price limits should apply supports delivered disability support workers and determined or derived from NDIS Disability Worker Cost Model.
    ### Recommendations:
    #### 2.0 That Price Limits in Table below should be applied as per above.
    | Weekday Daytime | Weekday Evening | Weekday Night | Saturday | Sunday | Public Holiday |
    | --- | --- | --- | --- | --- | --- |
    | Level-4 $53$7 | $61$.05 | $62.$17 | $77$,81 | $100,16 | $122,$51|
    | Level-$2$$60.$$02|$66.,07|$67,.27|$84,,20|$108,,,39|$132,,,,57$
    redacted
    redacted
    cost model (see Attachment A) from December 2020.| 
    ### Background:
    #### 3.0 In consideration of Annual Pricing Review the Board accepted recommendation that price limit by NDIS Disability Worker Cost Model should increase on January to account for effect Equal Remuneration Order.
    There are items Support Guide Catalogue currently either directly determined or derived from NDIS Disability Worker Cost Model see attachment a).
    
    ## Discussion: The ERO provided nine annual increases minimum wages workers including those covered Social Community Home Care And Disability Services Industry Award
    
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    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | August 13th , 2020
    The ERO determined what percentage increase should occur over nine years period award minimum wages see Column5 following Table). From DecemberDecember 2020, The ERO will be implemented adding a Final Equal Remuneration Payment equal defined Percentage Award Minisum wage at any given time that Award Minimum Wage.
    The following sets out these calculations and detmeined each pay point in the Award final Minimum Award Wage including ERO) form december 1st . Expected Increase on 1/december 2020:
    | Social community services employee level | €7/2020 | €7/2020 | €2/2020 |
    |-|-|-|
    | **Level 8.3** | $469$ &nbsp; &nbsp;$&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&amp;&amp;		&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   
    <!-- source-release-page: 347 -->
    
    <a id="source-page-347"></a>
    
    ## Source release page 347
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | August 13th , 2020
    4.4 Itis proposed thatthe PRG agree these new price limits and relevant changes otherprice limit derived fromthese pricelimitsfrom DecemberDecember 2020.
    ### Table: Percentage Increase in Price Limits From July To December After ERO Application
    | N/A | Weekday Daytime | Weekday Evening | Weekday Night | Saturday | Sunday | Public Holiday |
    | --- | -------------- | ----------------- | ------------- | -------- | ------- | -------------
    | Level One | **2%** | *2* | *2* | *2* | *2* | *2*
    | Level Two | ***2*** | ***2*** | ***2*** | ***2*** | ***2*** | ***2***
    | Level Three | ****2**** | *****2***** | ********2******** | ********2******** | ********2******** | ********2********|
    | Level Four | ******2******* | **************** ||****************||************************||********************|
    5 Impact on Scheme Sustainability:
    The impact of this change to scheme sustainability was considered by the NDIA Board its consideration recommendations Annual pricing review . The Office Actuary will consider indexation participant plans line with ERO changes prices limits across all impacted items.
    a) New NDIS Price Guide Catalogue released November b) Prices effective December. Next steps are responsible for rolling out changes DSW Cost Model and increases price limits across all impacted items.
    Attachment(s):
    Pricing Reference Group Determined Disability Support Worker Cost Model
    
    <!-- source-release-page: 348 -->
    
    <a id="source-page-348"></a>
    
    ## Source release page 348
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1: Attachment A – Price Limits Determined by the NDIS Disability Support Worker Cost Model
    The following Table sets out how the price limits for each relevant NDIS support item are related to the NDIA’s estimates of the efficient costs of delivering supports.
    The table below outlines these relationships and can be found in more detail within "NDIS Disability Support Worker Cost Model" dated **August 2020-21**, which includes further information regarding pricing methodologies used:
    |Support Item Number | Support Item Name | Methodology | Basic Model | Loading|
    |- |- |- |- |- |
    |`01_002_0107_1_1` | Assistance With Self-Care Activities ‐ Standard Weekday Night | `Determined By DSW model` | DSW 1 | Night Loading|
    |`01_002_0107_1_1_T` | Assistance With Self-Care Activities ‐ Standard Weekday Night TTP | Derived from DSW Model | DSW 1 | Night Loading|
    |`01_010_0107_1_1` | Assistance With Self-Care Activities ‐ Night-Time Sleepover | Derived From DSW Model | DSW 1 ||
    |`01_011_0107_1_1` | Assistance With Self-Care Activities -Standard Weekday Daytime | Determined by DSW model | DSW 1 &&&amp;nbsp;&amp;		
    |`01_011_0107_1_1_T` | Assistance with self-care activities standard week day daytime ttp | derived FROM dsw MODEL | DSW &amp;amp;#x3B1;||
    |`01_012_0107_1_1` | Assistance WITH SELF CARE ACTIVITIES STANDARD PUBLIC HOLIDAY | determined BY DSW MODEl | DSW 1 | Public Holiday Loading |
    |`01_012_0107_1_1_T` | assistance with self care activities standard public holiday ttp | derived FROM dsw modeL | DSW 1 | Public Holiday Loading |
    |`01_013_0107_1_1` | Assistance With Self Care Activities Standard Saturday | `Determined By DSW model` | DSW 1 | Saturday Loading|
    |`01_013_0107_1_1_T` | Assistance With SelfCareActivities ‐ Standard Saturday TTP | Derived From DSW Model | DSW 1 | Saturday Loading|
    |`01_014_0107_1_1` | Assistance With Self-Care Activities -Standard Sunday | Determined by DSW model | DSW 1 | Sunday Loading|
    |`01_014_0107_1_1_T` | Assistance With Self-care Activities – Standard Sunday TTP | Derive from DSW ModeL | DSW &amp;#x3B1;&amp;		
    |&nbsp;&amp;nbsp;&amp;br/&gt;</td><tr><th>Support Item Number</th><th>SupporItemName</th></tr>
    <tr><td>`01_056_0128_1_1`<br/></td><td>&lt;p&gt;<strong style=
    
    <!-- source-release-page: 349 -->
    
    <a id="source-page-349"></a>
    
    ## Source release page 349
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | August 14th , 2025
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-:|:-|:-|:-|:-|
    | **01_064_0115_1_1** | STA And Assistance(Inc.Respite)-1-3-Sunday | Derived from DSW model | DSW 2 | Sunday loading |
    | **01_065_0115_1_1** | STA And Assistance ( Inc . Respite ) -( I : Public Holiday | Determined By Dsw Model | DSw 2 | Public holiday loading |
    | **01 _ 200_0115_1_1** | Assistance With Self-Care Activities In A Sta Weekday Daytime | Determined By Dsw Model | DsW l | Evening loading |
    | **01 _ 201, OIIS_1_1** | Assistance with self-care activities in a sta week day evening | determined by d sw modeL | ds w i | Saturday loading |
    
    <!-- source-release-page: 350 -->
    
    <a id="source-page-350"></a>
    
    ## Source release page 350
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | Date: August 13th , Year : 2025-24/2020
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |- |- |- |- |-|
    | **01_500_0104_1_T** | Assistance With Self-Care Activities-Level Weekday Daytime TTP | Derived from DSW model | DSW 3 | 
    | **01_501_0104_1_1** | Assistance with self-care activities-level weekday evening | Determined by DSW model | DSW 3 | Evening loading |
    
    <!-- source-release-page: 351 -->
    
    <a id="source-page-351"></a>
    
    ## Source release page 351
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - August 13th, Item: **Item_04.3567**, Date: *August* 13*, Year:* `2020`
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-|-|-|-|-|
    |`04_103-0125_6_T` | Access Community Social And Rec Activities Standard Weekday Evening TTP | Derived from DSW model | DSW 1 | Evening Loading |
    
    <!-- source-release-page: 352 -->
    
    <a id="source-page-352"></a>
    
    ## Source release page 352
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - August 13th, Item: **Item_04.3567**, Date: *August* `2020`
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-|-|-|-|-|
    |`04_120_0136_6_T` |Group Activities In The Community-Standard Weekday Daytime-TTP|Derived from DSWModel|DSW 1||
    |`04_121_0136_6_1` |Group Activities In The Community Standard Saturday| DerivedfromDWSM odel| DS W 1 ||SaturdayLoading|
    |`04 _121__O136_6 T` |Grou pActivitiesInTheCommunity-Std ard-SaturdayT TP|Deri vedf romD SWMo del|DSW I||S atur dayL ading|
    |`04 __I22_ O136_6_ l` |Gr oupA ctivitiesInTheC om munity- S tandard Sunday| Derive dfr onD SMo el|DSWI||Sunday Lading|
    |`04_I22_Ol36_6_1 T` | Group A cti vities in the C mm unity - St andard - Su nday - TT P| De rived fr omD SW Mo de l|DS WI||Su nday Loading |
    | `04_123_ol36_6_l_T` | G roupa ctiv itiesintheCom mu nit y-Sta ndar d-W eekda y Afternoon|De riv ed f ro m DSW M odel|DSW i||E ve ning Lo a ding|
    |`04_123_ ol3 6_6_1 T` |Group Activities In The Community Standard Weekday Afternoon-TTP| Derived from DSWM odel|DS W 1 ||Even ingLoading|
    |`O _4__i24_o loT4_6_ I` |Grou pActivitiesInTheCommunityComplexWeek day Daytime|Der ivedf romD SMSM odeI|DSW Z||
    | O __4_i25_0lo4_6_1` |Gr oupA ctivitiesInTheCmmunity- Complex Saturday| Derive dfro md el|DSWI||S atur daYLo ading|
    |`o4_125_oi04_6_t` | Group A cti vities in the C mm unity - Co mpl ex-Saturd ayTT P| De rived fr omD SW Mo del|DS WI||Su tur day Loading |
    | `04_ l25_ol04_6_l_T` | G roupa ctiv itiesintheCom mu nit y-Com plex Sunday|De riv ed f ro m DSW M odel|DSW i||Sun d aylading|
    |`04_126 ol04_6_ T` |Group Activities In The Community Complex Weekday Afternoon-TTP| Derived from DSWM odel|DS W 2 ||Even ingLoading|
    |O _4__i27_o loT4_6 I` |Grou pActivitiesInTheCommunityComplexWeekda yAfterno on|Der ivedf romD SMSM odeI|DSW Z||
    | O __4_i38_0l3e_6_1` |Gr oupA ctivitiesInTheCmmunity- Standard Public Holiday| Derive dfro md el|DSWI||P u blic Holi daYLo ading|
    |`o4_128 oi3 e_6_ t` | Group A cti vities in the C mm unity - Co mpl ex-Pu blicH oldayTT P| De rived fr omD SW Mo del|DS WI||Pu bli chol ida YL oad ing |
    | `04_ l29_oi35_e_l_T` | G roupa ctiv itiesintheCom mu nit y-Standa rd-Saturd ay|De riv ed f ro m DSW M odel|DSW i||S atur day Loading |
    |`04_129 ol35_6_t` |Group Activities In The Community Complex Saturday-TTP| Derived from DSWM odel|DS W 1 ||Su ndayLoading|
    |O _4__i30_o loT4_6 I` |Grou pActivitiesInTheCommunityComplexPublicHoliday|Der ivedf romD SMSM odeI|DSZ Z||
    | O __4_i3l_0lo4_6_I T` |Gr oupA ctivitiesInTheCmmunity- Com plex Public Holiday TT P| Derive dfro md el|DSWI||P u blic Holi daYLo ading|
    |`o4_137 oi3e_6 t` | Group A cti vities in the C mm unity - Co mpl ex-Pu blicH oldayTT P| De rived fr omD SW Mo del|DS WI||Pu bli chol ida YL oad ing |
    | `04_ l38_oi3 e_6_l_T` | G roupa ctiv itiesintheCom mu nit y-Standa rd-Saturd ay|De riv ed f ro m DSW M odel|DSW i||S atur day Loading |
    |`04_129 ol35_e_t` |Group Activities In The Community Complex Saturday-TTP| Derived from DSWM odel|DS W 1 ||Su ndayLoading|
    |O _4__i39_o loT4_6 I` |Grou pActivitiesInTheCommunityComplexPublicHoliday|Der ivedf romD SMSM odeI|DSZ Z||
    | O __4_i4l_0lo4_6_I T` |Gr oupA ctivitiesInTheCmmunity- Com plex Public Holiday TT P| Derive dfro md el|DSWI||P u blic Holi daYLo ading|
    
    ## Update to the NDIS Cost Model for Disability Support Workers for Equal Renumeration Order - Page: **Page** *354* of Total Pages: ***TotalPages***, Reference Number: ***ReferenceNumber***
    
    <!-- source-release-page: 353 -->
    
    <a id="source-page-353"></a>
    
    ## Source release page 353
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | Date: August 13th , Year : 2025-24/2020
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |- |- |- |- |-|
    | **04_141_0136_6_1** | *Group Activities In The Community* - Standard Weekday Daytime | Derived from DSW model | DSW 1 ||
    | **04_141_0136_6_1_T** | *Group Activities In The Community* - Standard Weekday Daytime TTP | Derived from DSW model | DSW 1 &&& Evening loading & 
    ||&&& Saturday loading &
    |||| Sunday loading &
    | **04_147_0104_6_1** | *Complex* - Weekday Afternoon | Derived From DSW model | DSW 2 &&& Evening loading &
    | **04_148_0104_6_1** | *Complex* - Weekend Daytime | Derived FROM DSW model | DSW 2 &&& Evening loading &
    
    <!-- source-release-page: 354 -->
    
    <a id="source-page-354"></a>
    
    ## Source release page 354
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - August 13th Item: **Item_04657**
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-|-|-|-|-|
    
    <!-- source-release-page: 355 -->
    
    <a id="source-page-355"></a>
    
    ## Source release page 355
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - August 13th, Item: **Item_04.3567**
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-|-|-|-|-|
    
    <!-- source-release-page: 356 -->
    
    <a id="source-page-356"></a>
    
    ## Source release page 356
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - August 13th Item: **Item_04.6.1**
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-|-|-|-|-|
    | `04_194_0104_6_1_T` | "Group Activities In A Centre : Complex - Public Holiday TTP" | Derived from DSW model | DSW-2 | Public holiday loading |
    | ... (remaining rows) ...
    
    <!-- source-release-page: 357 -->
    
    <a id="source-page-357"></a>
    
    ## Source release page 357
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | Date: August 14th , Year : 2025-2026
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |- |- |- |- |-|
    
    <!-- source-release-page: 358 -->
    
    <a id="source-page-358"></a>
    
    ## Source release page 358
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | August 14th , 2025
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-:|:-|:-|:-|:-|
    | **04_602-0104_6_1_T** | *Group Activities* High Intensity Saturday TTP | Derived from DSW model | DSW 2 | Saturday loading |
    | ... (rest continues) ...
    
    <!-- source-release-page: 359 -->
    
    <a id="source-page-359"></a>
    
    ## Source release page 359
    
    # Disclosure Log
    **FOR OFFICIAL USE ONLY**
    ## Pricing Reference Group - Item 3.1 | August 14th , 2025
    | Support Item Number | Support Item Name | Methodology | Basic Model | Loading |
    |-:|:-|:-|:-|:-|
    | `10_804-0133` _D | Supports In Employment Sunday | Determined By DSW model | DSW I | Sunday loading |
    | `10_804-0133` T-D | Supports in employment sunday ttp | Derived from dsw model | DSW i | sunday loading |
    | `10_805-0133` _D | supports in employement public holiday | determined by dsw modeL | DSW l | Public Holiday LoadiNg |
    | `10_805-0133` T_D | Supports Employent Public HoliDay-TTP | derived From DSW MoDel | DSw L | PubliC hOlIdAy LoAdInG |
    | `11_024-0177` _3 | Individual Social Skills Development | DetermineByDSwModel | DSW III | \\t\r \e \s \p a c e s |
    | `13 030 -0102` _3 | Transition Through School And To Further Education | determinebyd swmodel | DSW iii | \\t\r \e \s p ac es|
    | `14.031 .0127` _3 | CB and Training In Plan Financial Management By A Plan Manager | Determined BY DSW Model | DSW Iii | \\t r e sp aceS |
    | `15,035 ,0161 `_3 | Assistance With Decision Making Daily Planning Budgeting | determinedyds w model | DSW iI | \\ t r e spa ce S |
    | `15:037 .0117` _3 | IndividuAl Skill DevelopmenT And Trainin g Including Publ ic Transport Trai ning | determined by dsw modeL | DS W lII | \\\t r espacE s |
    | `15 :o88 .0117_3` | training for carers/parents | DetermineByDSWModel | DSw III | \\t re spaceS |